New York Law Review

Tag: Noscitur a Sociis

  • Matter of Brown v. Wyman, 22 N.Y.2d 433 (1968): Interpreting ‘Like Catastrophe’ in Social Services Law

    Matter of Brown v. Wyman, 22 N.Y.2d 433 (1968)

    When interpreting a statute, the term ‘other like catastrophe’ should be construed in light of the preceding terms, encompassing only events similar in nature, and an administrative agency’s reasonable interpretation of a statute it administers should be upheld.

    Summary

    A welfare recipient, Brown, sought replacement of stolen clothing and furniture after a burglary, citing Section 131-a(6) of the Social Services Law, which allows for replacement of necessities lost due to “fire, flood or other like catastrophe.” The New York City Social Services Department denied her claim, a decision upheld by the State Commissioner of Social Services. The lower courts reversed, but the Court of Appeals reversed again, holding that ‘other like catastrophe’ does not include burglary. The court reasoned that the legislative intent, as well as the administrative interpretation, limited the phrase to natural or man-made disasters similar to fire or flood, and that a burglary was too dissimilar to be included.

    Facts

    Brown, a welfare recipient and mother, had her apartment burglarized, resulting in the loss of clothing and furniture. She applied to the New York City Social Services Department for replacement of the stolen items, based on Section 131-a(6) of the Social Services Law. The Social Services Department denied her application.

    Procedural History

    The New York City Social Services Department denied Brown’s application. The Commissioner of the State Department of Social Services affirmed this denial after a hearing. Brown then initiated an Article 78 proceeding. The Appellate Division reversed the Commissioner’s decision, holding that a burglary constituted a “catastrophe” under the statute and remanded the case to determine the appropriate grant amount. The Commissioner appealed to the New York Court of Appeals.

    Issue(s)

    Whether the phrase “other like catastrophe” in Section 131-a(6) of the Social Services Law includes a burglary, thereby entitling the victim to replacement of stolen items.

    Holding

    No, because the phrase “other like catastrophe” should be construed in light of the preceding terms (“fire, flood”) and encompasses only events similar in nature, and a burglary is not sufficiently similar to a fire or flood to be included within that phrase.

    Court’s Reasoning

    The court relied on the maxims of statutory construction, ejusdem generis and noscitur a sociis, to interpret the phrase “other like catastrophe.” It reasoned that the legislature intended to include only natural occurrences, or man-made ones similar to a fire. The court deferred to the Commissioner’s interpretation, noting that the agency consistently interpreted the statute to exclude burglaries, stating that “statutory construction is the function of the courts ‘but where the question is one of specific application of a broad statutory term in a proceeding in which the agency administering the statute must determine it initially, the reviewing court’s function is limited’”. The court emphasized the importance of upholding administrative interpretations unless they are irrational or unreasonable. The court stated that, “The administrative determination is to be accepted by the courts ‘if it has “warrant in the record” and a reasonable basis in law’…‘The judicial function is exhausted when there is found to be a rational basis for the conclusions approved by the administrative body.’” The court acknowledged the unfortunate frequency of burglaries but stated that this did not justify labeling them as “catastrophes” within the meaning of the statute. Changing this interpretation would require legislative amendment, not judicial action.

  • People v. Reynolds, 16 N.Y.2d 241 (1965): Interpreting Statutes Regarding Serving Alcohol to Minors in a Private Home

    People v. Reynolds, 16 N.Y.2d 241 (1965)

    A statute prohibiting selling or giving alcohol to minors should not be interpreted to criminalize serving alcohol to minors in a private residence, absent clear legislative intent.

    Summary

    Defendant was convicted of violating a statute prohibiting the sale or provision of alcohol to minors after she permitted several minors to drink alcohol in her home. The New York Court of Appeals reversed the conviction, holding that the statute was not intended to apply to the private serving of alcohol to minors in a home. The court reasoned that the statute should be read in its entirety and considered in the context of other provisions addressing commercial activities involving children. The court applied the principle of noscitur a sociis, interpreting the statute’s scope by considering associated words and the overall purpose of the law.

    Facts

    Defendant permitted four individuals under the age of 18 to congregate in her home and served them alcoholic beverages on multiple occasions over a six-month period.

    Procedural History

    The Dutchess County Court convicted the defendant of violating section 484(3) of the Penal Law. The Appellate Term affirmed the County Court’s judgment. The New York Court of Appeals granted permission for the defendant to appeal the Appellate Term’s affirmance.

    Issue(s)

    Whether subdivision 3 of section 484 of the Penal Law, which prohibits selling or giving alcohol to persons under 18, applies to the act of serving alcohol to minors in a private home.

    Holding

    No, because the legislative intent behind section 484 was not to criminalize the serving of alcoholic beverages to minors in a private residence.

    Court’s Reasoning

    The court reasoned that statutory interpretation requires considering the entire statute to ascertain legislative intent. Section 484, titled “Permitting children to attend certain resorts,” primarily addresses commercial activities involving children. The court applied the rule of noscitur a sociis (or ejusdem generis), which suggests that the meaning of a word or phrase should be determined by the company it keeps. Therefore, the statute’s prohibition on giving alcohol to minors should be understood in the context of other provisions that forbid harmful commercial activities involving children.

    The court emphasized that interpreting the statute to criminalize serving alcohol in a private residence would be an unreasonable reading. The court noted the absence of prior prosecutions under the statute for such conduct, further supporting its interpretation.

    The court stated: “Section 484 shows an absence of legislative intent to penalize acts like defendant’s, not only by its title (“ Permitting children to attend certain resorts”) but also by the linking of subdivision 3 (supra) with six other subdivisions each of which forbids certain commercial activities with children which are thought to be harmful to the children.”