New York Law Review

Tag: special education

  • Grumet v. Pataki, 93 N.Y.2d 677 (1999): Establishing a School District Favoring a Religious Group Violates the Establishment Clause

    93 N.Y.2d 677 (1999)

    A law that enables a village comprised of members of a single religious sect to create a separate school district for its disabled children, when the law has the primary effect of advancing that religion, violates the Establishment Clause of the First Amendment.

    Summary

    This case examines the constitutionality of a New York law (Chapter 390) that allowed the village of Kiryas Joel, a village of Satmar Hasidic Jews, to create a separate school district for its disabled children. Previous attempts to create such a district were struck down as violating the Establishment Clause. The plaintiffs argued that Chapter 390, like its predecessors, favored a specific religious group. The New York Court of Appeals affirmed the lower court’s decision, holding that the law violated the Establishment Clause because it had the primary effect of advancing the Satmar Hasidic religion by delegating governmental power to a religious group in a way that was not equally available to other communities. The court emphasized that the law effectively benefited almost exclusively one religious community.

    Facts

    Kiryas Joel is a village populated by Satmar Hasidic Jews who adhere to a strict religious lifestyle.
    Due to the community’s unique needs, Kiryas Joel sought a separate school district to provide special education services to its disabled children.
    Previous legislative attempts to create such a school district were found unconstitutional because they were seen as favoring a single religious group.
    After the Supreme Court decision in Agostini v. Felton, the state attempted a new statute.

    Procedural History

    Plaintiffs, citizen taxpayers, filed suit against the Governor and other officials, challenging the constitutionality of Chapter 390.
    The trial court granted summary judgment to the plaintiffs, declaring the law unconstitutional.
    The Appellate Division affirmed, agreeing that the law applied to only two municipalities and was not a truly religious-neutral law.
    The case then went to the New York Court of Appeals.

    Issue(s)

    Whether Chapter 390 of the Laws of 1997, which enables Kiryas Joel to create a separate school district for its disabled children, violates the Establishment Clause of the First Amendment of the United States Constitution?

    Holding

    No, because the legislation has the impermissible effect of advancing one religious sect, therefore, it is unconstitutional.

    Court’s Reasoning

    The Court reasoned that while Chapter 390 set forth facially neutral criteria, its actual effect was to benefit almost exclusively the Village of Kiryas Joel, a religious community.
    The Court relied on previous Supreme Court cases, including Board of Education of Kiryas Joel Village School District v. Grumet, which held that the state cannot delegate discretionary authority over public schools to a group defined by its religious character.
    The Court found that Chapter 390 was not a law of general applicability because it was designed to accommodate the needs of a specific religious community, and the class of beneficiaries was not sufficiently broad.
    The Court distinguished this case from Agostini v. Felton, noting that Chapter 390 did not simply provide aid to a parochial school, but delegated to a religious group the power to form its own public school district.
    The Court concluded that the legislative history and context of Chapter 390 indicated that it was intended to provide the residents of Kiryas Joel with an exclusively Satmar “public school” environment at taxpayer expense.
    The Court determined that, even after Agostini v. Felton, which eliminated the obstacle that prevented the education of handicapped children in an exclusive Satmar setting, the enactment of Chapter 390 would likely be perceived as a religious preference.
    The dissent argued that the law was constitutional because it removed previously adjudicated constitutional defects, was neutral in application, and enjoyed a presumption of constitutionality. The dissent contended that the majority’s reliance on legislative history and the lack of a “broad spectrum” of beneficiaries was misplaced.

  • Matter of New York Assn. of Learning Disabled Children v. Ambach, 48 N.Y.2d 518 (1979): Upholding Commissioner’s Discretion in Setting Tuition Rates for Special Education

    Matter of New York Assn. of Learning Disabled Children v. Ambach, 48 N.Y.2d 518 (1979)

    The Commissioner of Education has broad discretion in determining allowable tuition rates for private schools providing services under Article 89 of the Education Law, and such determinations will be upheld if they have a rational basis.

    Summary

    This case concerns a challenge to the New York State Commissioner of Education’s determination to impose a 4.5% ceiling on teacher salary increases for private schools serving learning-disabled children. The Court of Appeals held that the Commissioner’s determination was neither arbitrary nor capricious because it relied on data from the PERB research office indicating an average 4.5% salary increase for public school teachers in the NYC metro area. The court also clarified that while the Commissioner must adhere to regulations concerning cost reimbursement, not all cost limitations need to be established via formal administrative regulations. Finally, the court agreed that the Commissioner of Education, not the Commissioner of Social Services, should determine tuition reimbursement rates for the Summit School.

    Facts

    Several private schools and organizations representing learning-disabled children challenged the Commissioner of Education’s method for determining tuition reimbursement rates. A key point of contention was the Commissioner’s imposition of a 4.5% ceiling on teacher salary increases. The Commissioner based this ceiling on salary data for public school teachers in the New York City metropolitan area. The Summit School, one of the respondents, also disputed whether the Commissioner of Education or the Commissioner of Social Services had the authority to set its tuition reimbursement rates.

    Procedural History

    The petitioners initially sought to overturn the Commissioner’s determination in Supreme Court, Albany County, which dismissed the petition. The Appellate Division reversed, granting the petition for the Summit School, and remitting the matter to the Commissioner of Education for recomputation of Summit School’s tuition. The Court of Appeals then heard the case.

    Issue(s)

    1. Whether the Commissioner of Education’s imposition of a 4.5% ceiling on teacher salary increases for private schools serving learning-disabled children was arbitrary or capricious.
    2. Whether Section 4405(3)(e) of the Education Law requires all reimbursable cost limitations to be established through formal administrative regulations.
    3. Whether the Commissioner of Education or the Commissioner of Social Services has the authority to determine allowable tuition reimbursement rates for the Summit School.

    Holding

    1. No, because the Commissioner’s determination was based on a rational basis, namely the average salary increase for public school teachers in the relevant geographic area.
    2. No, because the provision merely requires the Commissioner to adhere to any regulations he may promulgate, not to create regulations for every cost limitation.
    3. The Commissioner of Education, because the Summit School provides services under Article 89 of the Education Law.

    Court’s Reasoning

    The Court reasoned that the Commissioner’s 4.5% salary cap was not arbitrary or capricious because it was based on data from the PERB research office, indicating an average 4.5% salary increase for public school teachers. The Court emphasized the limited scope of judicial review in such matters, stating that it could not further inquire as long as the determination had a rational basis, citing Matter of De Vito v Nyquist, 43 NY2d 681. The court interpreted Section 4405(3)(e) of the Education Law as requiring the Commissioner to adhere to existing regulations, not to create new regulations for every cost limitation. The Court stated, “Rather, we read the provision as merely requiring the commissioner to adhere and conform to any regulations he may promulgate in connection with the statutory cost reimbursement scheme.” As for the Summit School, the Court deferred to the Appellate Division’s conclusion that the Commissioner of Education, not Social Services, had jurisdiction, since Summit School provided services under Article 89 of the Education Law, and the interpretation of the statute presented a purely legal issue not requiring exhaustion of administrative remedies. The court also cited Matter of De Vito v Nyquist, 56 AD2d 159, 161, affd 43 NY2d 681, supporting this point.