17 N.Y.3d 180 (2011)
When interpreting a settlement agreement, the court must discern the parties’ intent from the plain meaning of the language within the four corners of the document, considering the agreement as a whole, to determine when monitoring obligations began, particularly in the context of mandated mental health services for inmates.
Summary
This case concerns a dispute over when a settlement agreement requiring New York City to provide mental health services to jail inmates began. The plaintiffs sought to extend the agreement, arguing that the five-year term had not yet expired when they filed their motion. The City argued that the term had already expired, based on when monitoring by compliance monitors began. The Court of Appeals held that the monitoring period began on the implementation date of the agreement, June 3, 2003, when discharge planning services were actually provided to inmates, making the plaintiffs’ motion timely.
Facts
The plaintiffs, representing mentally ill inmates in New York City jails, sued the City in 1999, alleging inadequate discharge planning services. A settlement agreement was reached, requiring the City to provide individualized discharge planning. The agreement stipulated that compliance monitors would oversee the City’s compliance. The agreement was approved on April 4, 2003, with an implementation date of June 3, 2003. The settlement agreement stated that it would terminate five years after monitoring began. The monitors were appointed on May 6, 2003, and began some preliminary reviews. The dispute arose over whether the five-year term started when the monitors were appointed or when the City was required to be in substantial compliance, that is, June 3, 2003.
Procedural History
The plaintiffs moved for a temporary restraining order and preliminary injunction in May 2009, alleging noncompliance by the City. The City cross-moved to dismiss, arguing the settlement had expired. Supreme Court denied the City’s motion, finding the plaintiffs’ motion timely. The Appellate Division reversed, holding that the term began when the monitors first acted affirmatively. The Court of Appeals reversed the Appellate Division, reinstating the Supreme Court’s order.
Issue(s)
Whether the five-year term of the settlement agreement commenced when the compliance monitors were appointed and began preliminary reviews, or on the implementation date when the City was obligated to provide discharge planning services.
Holding
No, because the five-year term began on the implementation date of June 3, 2003, when the City was required to provide discharge planning services, and monitoring of that compliance could not occur before the service was required to be provided.
Court’s Reasoning
The Court of Appeals reasoned that the settlement agreement must be interpreted as a whole, focusing on the monitors’ fundamental purposes: to monitor the provision of discharge planning and the City’s compliance. The court emphasized that “Discharge Plan” refers to a plan for individual inmates to receive mental health treatment upon release, not the preliminary planning by the City. The monitors could not assess the City’s compliance before the City was obligated to provide discharge plans. The court noted that compliance monitoring could not begin before compliance was required by the agreement. The court reasoned that the agreement gave the plaintiffs five years of monitored mental health service discharge planning for inmates. The court noted that the parties stipulated that monitoring should begin “no later than the Implementation Date.” The dissenting opinion argued that the agreement contemplated monitoring could begin before the implementation date, as the monitors were to be appointed in time to perform their duties no later than the implementation date.