New York Law Review

Matter of North Syracuse Cent. School Dist. v. New York State Div. of Human Rights, 20 N.Y.3d 482 (2013): SDHR Jurisdiction Over Public School Discrimination Complaints

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Matter of North Syracuse Cent. School Dist. v. New York State Div. of Human Rights, 20 N.Y.3d 482 (2013)

Executive Law § 296(4), which prohibits discrimination by “education corporations or associations,” does not apply to public school districts, and therefore the New York State Division of Human Rights (SDHR) lacks jurisdiction to investigate complaints against public school districts under that provision.

Summary

The New York Court of Appeals addressed whether the New York State Division of Human Rights (SDHR) has jurisdiction to investigate discrimination complaints against public school districts under Executive Law § 296(4). Students filed complaints with the SDHR, alleging that their school districts permitted harassment based on race and/or disability. The school districts argued that they are not “education corporations or associations” under the statute. The Court of Appeals held that public school districts are not “education corporations or associations” as contemplated by Executive Law § 296(4), reversing the Appellate Division’s order in North Syracuse and reinstating the Supreme Court’s judgment, and reversing the Appellate Division’s order in Ithaca City School Dist. and reinstating the Supreme Court’s order. Therefore, the SDHR lacks jurisdiction over these complaints.

Facts

Students in the North Syracuse Central School District and Ithaca City School District filed complaints with the SDHR, alleging that their respective school districts engaged in unlawful discriminatory practices by allowing harassment based on race and/or disability.

Procedural History

Both school districts initiated CPLR article 78 proceedings seeking to prohibit the SDHR from investigating the complaints, arguing that public school districts are not “education corporations or associations” under Executive Law § 296(4). In North Syracuse, the Supreme Court initially granted the petition, but the Appellate Division reversed, stating the school district should have first exhausted administrative remedies. In Ithaca City School Dist., the Supreme Court initially annulled the SDHR’s determination of discrimination and award of damages, but the Appellate Division modified the award and confirmed the determination, concluding that public school districts are “educational institutions” over which the SDHR has jurisdiction.

Issue(s)

Whether a public school district is an “education corporation or association” as contemplated by Executive Law § 296(4), thereby granting the SDHR jurisdiction to investigate complaints against them.

Holding

No, because the legislative history of Executive Law § 296(4) indicates that the term “education corporation or association” refers to private, non-sectarian entities that are exempt from taxation under RPTL article 4, and public school districts do not fall into this category.

Court’s Reasoning

The Court of Appeals examined the legislative history of Executive Law § 296(4), tracing the term “education corporation or association” back to the Tax Law. The Court highlighted that Tax Law § 4 differentiated between the tax-exempt status of municipal corporations, like school districts, and that of private corporations or associations organized for various purposes, including education. The Court noted that the language of Executive Law § 296(4) was taken almost verbatim from Tax Law § 4(6), indicating the Legislature’s intention for the term to have the same meaning in both laws. The Court emphasized that the phrase “non-sectarian” in Executive Law § 296(4) was intended to carve out an exception for parochial schools, reserving jurisdiction for the SDHR to investigate complaints against private, non-sectarian education corporations or associations. The court rejected the SDHR’s argument to liberally construe the statute to include public school districts, finding no underlying directive to support such a construction. The Court concluded that public school districts, as part of a public system, are distinct from private, non-sectarian institutions and do not need to “hold themselves out to the public to be non-sectarian” to receive tax-exempt status.

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