Evans v. Carey, 40 N.Y.2d 1008 (1976)

When the rights and interests of government employees as citizens are balanced against the rights and interests of the government as an employer, a financial disclosure requirement designed to eliminate inefficiency and deter official corruption, which are significant public interests, does not infringe upon individual employees’ constitutional rights.

Summary

This case concerns the constitutionality of Executive Order No. 10, which required financial disclosure by certain New York state employees. The plaintiffs challenged the order, arguing it violated their right to privacy. The Court of Appeals upheld the order, distinguishing it from cases involving broader privacy rights and relying on precedents that balance the rights of government employees against the interests of the government as an employer. The court found that the executive order served significant public interests by aiming to eliminate inefficiency and deter corruption, and that it did not unconstitutionally infringe upon employees’ rights.

Facts

Executive Order No. 10 mandated financial disclosure by certain public employees in New York. The aim of the order was to deter corruption and eliminate inefficiency within the government. Several employees subject to the order challenged its constitutionality, asserting that it violated their right to privacy.

Procedural History

The Appellate Division upheld the constitutionality of Executive Order No. 10. The case was then appealed to the New York Court of Appeals.

Issue(s)

Whether Executive Order No. 10, requiring financial disclosure by public employees, unconstitutionally infringes upon the employees’ right to privacy, considering the government’s interest in eliminating inefficiency and deterring official corruption.

Holding

No, because the rights and interests of government employees, as citizens, were balanced against the rights and interests of the government, as employer, and the financial disclosure requirement was designed to eliminate inefficiency and deter official corruption, which are significant public interests.

Court’s Reasoning

The Court of Appeals affirmed the Appellate Division’s decision, finding the Executive Order constitutional. The court distinguished the case from Griswold v. Connecticut, which recognized a broad right to privacy, noting the vastly different context. Instead, the court relied on precedent such as United Public Workers v. Mitchell and Civil Serv. Comm. v. Letter Carriers, which involved balancing the rights of government employees against the interests of the government as an employer. The court emphasized that the Executive Order was designed to eliminate inefficiency and deter official corruption, which are significant public interests. The court stated that the order “does not infringe upon individual employees’ constitutional rights.” The court acknowledged the cogent justification presented by the Presiding Justice at the Appellate Division, supporting the constitutionality of financial disclosures by public employees. The concurring judges highlighted the importance of the public interest in deterring corruption and promoting efficiency within government. The court implicitly found the Executive Order was a reasonable means to achieve these ends.