New York Law Review

Tag: Stoll v. NYS College of Veterinary Medicine

  • Stoll v. New York State College of Veterinary Medicine, 94 N.Y.2d 162 (1999): Determines FOIL applicability to Cornell’s Statutory Colleges

    Stoll v. New York State College of Veterinary Medicine, 94 N.Y.2d 162 (1999)

    Records related to disciplinary actions against faculty at Cornell University’s statutory colleges are not subject to disclosure under the Freedom of Information Law (FOIL) because Cornell acts independently in these matters, not as an agent of the State.

    Summary

    This case addresses whether Cornell University, while administering New York State’s statutory colleges, is subject to the Freedom of Information Law (FOIL) regarding faculty disciplinary records. The Court of Appeals held that Cornell acts independently in these matters, not as an agent of the State, and therefore is not subject to FOIL. The Court reasoned that while the state provides funding and owns the property, Cornell maintains sufficient autonomy in its operations to be considered a private entity for the purposes of faculty discipline. The dissent argued that Cornell acts as a representative of the State University Trustees and thus should be subject to FOIL.

    Facts

    The plaintiff sought records concerning disciplinary actions taken against a professor at the New York State College of Veterinary Medicine, a statutory college administered by Cornell University. Cornell denied the request, claiming it was not an “agency” subject to FOIL. The statutory colleges are funded by the state, and the state owns the buildings and property. Cornell, however, manages the colleges, including faculty appointments, disciplinary actions, and educational policies.

    Procedural History

    The Supreme Court initially granted the petitioner’s application, ordering Cornell to release the documents. The Appellate Division reversed, holding that Cornell was not an agency subject to FOIL. The Court of Appeals granted leave to appeal.

    Issue(s)

    Whether Cornell University, in administering the New York State statutory colleges, acts as an “agency” of the State and is therefore subject to the Freedom of Information Law (FOIL) regarding records of faculty disciplinary proceedings.

    Holding

    No, because Cornell University, while administering the statutory colleges, acts with sufficient independence and is not considered an agent of the state for purposes of faculty disciplinary proceedings; therefore, it is not subject to FOIL regarding these records.

    Court’s Reasoning

    The Court reasoned that the key inquiry is whether the entity is performing a governmental function. While the statutory colleges receive state funding and the state owns the property, Cornell maintains significant autonomy in administering the colleges, particularly concerning faculty matters. The Court emphasized that the day-to-day operations and academic decisions are controlled by Cornell, and the disciplinary actions against faculty are internal matters managed by the university’s own policies and procedures. The Court distinguished the statutory colleges from other state agencies, noting Cornell’s unique position as a private university managing state-funded institutions.

    The dissent argued that Education Law explicitly grants Cornell authority to administer the statutory colleges “as the representative of the state university trustees.” To exempt Cornell from FOIL regarding disciplinary actions would undermine the transparency intended by FOIL and contradict the statutory framework. The dissent also distinguished the cases cited by the majority, arguing that they did not involve the specific provisions of the Education Law relating to statutory colleges.