Heimbach v. State, 59 N.Y.2d 891 (1983)

Courts will generally not intrude into the internal affairs of the legislature, and a tax statute will be upheld under equal protection scrutiny if it has a rational basis, even if its application results in some unevenness.

Summary

Plaintiffs sought a declaratory judgment challenging the validity of a roll call vote in the Senate and the constitutionality of a tax law, arguing it violated the equal protection clause. The Court of Appeals affirmed the lower court’s decision, holding that the Legislative Law precluded judicial review of the roll call vote and that the tax law had a rational basis, despite potential disparate effects. The court emphasized the separation of powers and judicial restraint, stating it’s not the court’s role to direct the legislature. Even a “flagrant unevenness” in application of the tax will not invalidate the law.

Facts

Plaintiffs initiated an action seeking a declaratory judgment regarding two issues: first, whether a roll call vote taken in the Senate was correctly registered; and second, whether Chapter 485 of the Laws of 1981 (Tax Law, § 1109) violated the equal protection clause of the Fourteenth Amendment because it had a disparate effect on certain regions of the Metropolitan Commuter Transportation District.

Procedural History

The case originated in a lower court, where the plaintiffs sought a declaratory judgment. The Appellate Division’s order was appealed to the New York Court of Appeals. The Court of Appeals affirmed the Appellate Division’s decision.

Issue(s)

1. Whether Section 40 of the Legislative Law precludes judicial review of the propriety of a roll call vote to effect legislative action?

2. Whether Chapter 485 of the Laws of 1981 (Tax Law, § 1109) violates the equal protection clause of the Fourteenth Amendment due to its disparate effect on certain regions?

Holding

1. Yes, because Section 40 of the Legislative Law provides that the presiding officer’s certificate showing the date and requisite votes for passage of a bill shall be “conclusive evidence” that the bill was validly enacted.

2. No, because the statute has a rational basis, as residents of the affected counties use MTA services subsidized by the tax revenues.

Court’s Reasoning

The court based its decision on two primary grounds: separation of powers and rational basis review. Regarding the roll call vote, the court cited Section 40 of the Legislative Law, which makes the presiding officer’s certificate conclusive evidence of a bill’s valid enactment, thus precluding judicial review. Furthermore, the court emphasized that it would not intrude into the internal affairs of the Legislature, quoting, “‘[I]t is not the province of the courts to direct the legislature how to do its work’.” (New York Public Interest Research Group v Steingut, 40 NY2d 250, 257). As for the equal protection challenge, the court applied a rational basis test, noting that even a “flagrant unevenness” in the application of the tax would not render it unconstitutional. The court found that because residents of Suffolk and Orange Counties use MTA services subsidized by the tax, the statute had a rational basis. The court cited Matter of Long Is. Light. Co. v State Tax Comm., 45 NY2d 529, 535, to support the rational basis review.