Board of Higher Education v. Carter, 14 N.Y.2d 138 (1964)

When a state agency has specific statutory authority over a particular area (like education), a general anti-discrimination law does not automatically override that specific authority unless the legislature clearly intends such a result.

Summary

The Board of Higher Education sought to prevent the State Commission for Human Rights from investigating alleged discrimination in faculty employment at Queens College, arguing that the Board had exclusive control over educational matters. The Court of Appeals held that the anti-discrimination statute applied to the Board, rejecting the argument that the Board’s educational authority exempted it. The court reasoned that the anti-discrimination law’s broad language encompassed all employers, including educational institutions, and that there was no legislative intent to create a blanket exemption for the Board. This case clarifies the scope of the State Commission for Human Rights’ jurisdiction and its interplay with other state agencies.

Facts

Anonymous charges of discrimination against Catholics in faculty employment and promotion at Queens College were made in 1958. The Board of Higher Education formed a subcommittee to investigate. While the Board’s investigation was ongoing, the State Commission for Human Rights also began an informal investigation into the same allegations. The Board asserted the Commission lacked jurisdiction, arguing its exclusive control over educational matters.

Procedural History

The Board of Higher Education initiated a proceeding to prevent the Commission from exercising jurisdiction. The lower courts initially sided with the Board, upholding its exclusive control. The Court of Appeals reversed, holding that the Commission had jurisdiction.

Issue(s)

Whether the State Commission for Human Rights has jurisdiction to investigate allegations of discrimination in employment practices at Queens College, an institution under the control of the Board of Higher Education.

Holding

Yes, because the anti-discrimination statute applies broadly to all employers, and there is no express legislative intent to exempt the Board of Higher Education.

Court’s Reasoning

The Court reasoned that the anti-discrimination law’s broad language encompassed all employers, including educational institutions under the Board of Higher Education’s control. The court emphasized the importance of combating discrimination and found no evidence that the legislature intended to create a blanket exemption for the Board. The court stated that to find an exemption, “we would have to find express language in the statute providing for such exclusion.” The dissent argued that the Education Law already provided sufficient mechanisms to address discrimination in educational institutions and that allowing the Commission to exercise jurisdiction would create unnecessary conflict and confusion. The dissent highlighted the Temporary Commission against Discrimination’s initial intent to exclude non-profit educational institutions from the Commission’s jurisdiction, stating, “The Temporary Legislative Commission… intended to exclude from the jurisdiction of that Commission the non-profit educational institutions under the jurisdiction of the Board of Regents and the State Commissioner of Education”. However, the majority found this argument unpersuasive, emphasizing the importance of a unified approach to fighting discrimination and the absence of any explicit statutory language creating an exemption for the Board. This decision underscores the principle that general statutes apply unless specific exemptions are explicitly stated.