New York Law Review

Tag: Flanagan v. Mount Eden General Hospital

  • Flanagan v. Mount Eden General Hospital, 61 N.Y.2d 905 (1984): Interpreting Statutory Time Limits for Claims Against CUNY

    Flanagan v. Mount Eden General Hospital, 61 N.Y.2d 905 (1984)

    When interpreting statutes, courts must give effect to the plain meaning of each provision and read seemingly conflicting provisions together to give each effect according to its express terms.

    Summary

    This case addresses the interpretation of statutes governing the time limitations for filing claims against the City University of New York (CUNY). The Court of Appeals held that the 30-day waiting period mandated by Education Law § 6224(2) did not extend the 90-day period for filing a claim under Court of Claims Act § 10(3). Instead, the 30-day waiting period is carved out of the 90-day period. The court emphasized that both sections must be read together and given effect according to their express terms, further noting a 1982 amendment that clarified the inclusion of time limitations from the Court of Claims Act.

    Facts

    The claimant, Flanagan, sustained injuries on November 15, 1979. She filed a claim with the Court of Claims on February 29, 1980. The claim was filed more than 90 days after the injury occurred. The claimant argued that the 30-day waiting period required before filing a claim against CUNY effectively extended the 90-day filing deadline.

    Procedural History

    The lower courts concluded that the 30-day waiting period in Education Law § 6224(2) extended the 90-day filing period in Court of Claims Act § 10(3). The Court of Appeals reversed, holding that the filing was untimely. The case was remitted to the Court of Claims to consider the claimant’s motion for permission to file a late claim.

    Issue(s)

    Whether the 30-day waiting period prescribed in Education Law § 6224(2) operates to extend the 90-day period of limitation for filing claims (or notices of intention to file claims) prescribed in Court of Claims Act § 10(3)?

    Holding

    No, because the two sections are to be read together, and the 30-day waiting period is carved out of the 90-day period within which the claim or notice thereof must be filed.

    Court’s Reasoning

    The Court of Appeals reasoned that both Education Law § 6224(2) and Court of Claims Act § 10(3) must be given effect according to their express terms. The court stated, “The two sections are to be read together, and each is to be given effect according to its express terms. In substance, the 30-day waiting period (presumably to afford an opportunity for prelitigation settlement) is carved out of the 90-day period within which the claim or notice thereof must be filed.” The court also emphasized the 1982 amendment to Education Law § 6224(4), which explicitly included time limitations from the Court of Claims Act. The amendment stated that claims against senior colleges of CUNY should be determined “in the same manner and to the extent provided by and subject to the provisions of the court of claims act with respect to claims against the state”, with the addition of the phrase “including time limitations”. The court found that even if there was doubt before, this amendment clarified that the Court of Claims Act’s time limitations applied without extension due to the 30-day waiting period. This case highlights the principle that statutes should be interpreted to give effect to all their provisions, and that later amendments can clarify the legislature’s intent regarding earlier laws.