59 N.Y.2d 947 (1983)

When a state law amends a state statute concerning a matter of state concern, it does not violate home rule principles even if it affects local concerns.

Summary

This case addresses the dispute over the transfer of authority for motor vehicle services from Westchester County to the State Department of Motor Vehicles. The New York Court of Appeals held that an amendment to the Vehicle and Traffic Law, which explicitly included Westchester County in the list of counties subject to the transfer, was legally effective. The court found that the amendment did not violate home rule principles, as it concerned a matter of state concern despite affecting local interests, and that the dispute was moot due to the statutory change.

Facts

The central issue revolved around the transfer of authority and responsibility for providing motor vehicle services from Westchester County to the State Department of Motor Vehicles. The Westchester County Clerk opposed the transfer. The State Legislature then amended subdivision 1 of section 205 of the Vehicle and Traffic Law to specifically include Westchester County in the list of counties subject to the transfer. This amendment was signed into law by the Governor on June 6, 1983.

Procedural History

The case originated from a dispute regarding the statutory authority for the transfer of motor vehicle services. The Appellate Division contemplated a statutory amendment to resolve the issue. After the amendment was enacted, the case reached the New York Court of Appeals. The Court of Appeals reversed the Appellate Division’s order and directed the Supreme Court to dismiss the action as moot, given the statutory amendment that resolved the underlying dispute.

Issue(s)

Whether the amendment to the Vehicle and Traffic Law, transferring authority for motor vehicle services from Westchester County to the State Department of Motor Vehicles, is valid despite the county clerk’s assertion that it requires a referendum as per the New York State Constitution.

Holding

No, because the amendment to the state law did not constitute an amendment to the Westchester County Charter or Administrative Code, and it addresses a matter of state concern, not violating home rule principles.

Court’s Reasoning

The Court of Appeals reasoned that the amendment to the Vehicle and Traffic Law was effective immediately and resolved the dispute. The court rejected the county clerk’s argument that the amendment required a referendum, clarifying that the amendment did not directly alter the County Charter or Administrative Code. Specifically, section 265.01 of the Administrative Code, which outlines the County Clerk’s powers and duties, remained unchanged. The court emphasized that while the *substance* of the clerk’s duties was altered, this resulted from amending state law (Vehicle and Traffic Law § 205), not the county’s own laws.

The court further held that the amendment addressed a matter of state concern and therefore did not violate home rule principles. The court cited *Matter of Kelley v. McGee, 57 N.Y.2d 522, 538*, stating that a state statute dealing with a matter of state concern does not implicate local government home rule powers, even if it affects local concerns. The court distinguished the clerk’s duties performed as a county officer from those performed as an agent of the Commissioner of Motor Vehicles, noting that the amendment only affected the latter.

The court stated, “It is true that the substance of those duties is changed in consequence of the enactment of chapter 281. What is determinative, however, is that that substantive change was accomplished not by amendment of the wording of section 265.01, but by amendment of State law, namely, subdivision 1 of section 205 of the Vehicle and Traffic Law.”