Court of Appeals Reaffirms Power of State Office Over Local Development Agencies
A watchdog state authority in New York that oversees the activities of local economic and industrial agencies secured a victory before the state's highest court Thursday that reaffirmed its investigatory and enforcement power over publicly formed corporations.
March 21, 2019 at 01:25 PM
6 minute read
A watchdog state authority in New York that oversees the activities of local economic development and industrial agencies secured a victory before the state's highest court on Thursday that reaffirmed its investigatory and enforcement power over publicly formed corporations.
The New York State Authorities Budget Office has the power to require those local agencies, called industrial development agencies, to file separate financial reports for each of their affiliates or subsidiaries, the Court of Appeals said in a unanimous decision.
“The ABO's narrow record-keeping determination was not contrary to law,” Chief Judge Janet DiFiore wrote in the court's opinion. “The Public Authorities Law plainly provides that a local development corporation … which is 'affiliated' with a local IDA, is also a local authority subject to [the law] and, as such, has reporting obligations.”
The question before the court was narrow in scope, but set the first legal precedent on the power of the ABO over local development agencies since the office was created as an independent entity about a decade ago. The office, which was represented by Assistant Solicitor General Robert Goldfarb, was previously part of the state Division of Budget.
“This is a good decision,” said Jeffrey Pearlman, director of the ABO. “It's important in the evolving case law that's now coming out relating to the ABO and local authorities and it helps the ABO and all the entities within its regulatory authority to understand what the role of the authorities budget office is moving forward.”
The decision is the final determination in a legal challenge against the ABO by the Madison County Industrial Development Agency, which asked if it could include the financial information of one of its subsidiaries in its mandated reports to the office. The agency had created the Madison Grant Facilities Corp. in 2013 to shield itself from potential liability involving a third-party contractor.
Soon after it was created, MGFC was told by the ABO that it had to comply with requirements under state law to file certain annual, budget and independent audit reports with the office. MCIDA asked if they could, instead, just consolidate the activities of MGFC into its own reports with the state since they're affiliated.
The ABO initially said it was concerned that including the activities of both entities in one report “will result in a loss of transparency and accountability,” according to the decision. The New York Attorney General's Office, meanwhile, issued a formal opinion at the time saying that an IDA cannot create a subsidiary under state law.
The request by MCIDA to file a consolidated report was ultimately denied by the ABO, which cited the attorney general's opinion in its decision. The office said, partly because of that opinion, it wouldn't treat MGFC as a subsidiary and required it to file separate reports.
That decision was challenged by both entities from Madison County in state Supreme Court, where their case was dismissed based on the attorney general's opinion. The Appellate Division, Third Department affirmed that opinion using similar reasoning.
The Court of Appeals did not address the question, in its decision, of whether an IDA is able to create and maintain a subsidiary or affiliate. DiFiore wrote that the Public Authorities Accountability Act would require separate reporting by each entity regardless of whether they were considered a subsidiary since they're affiliated with an IDA.
“Even if MCIDA was authorized to create a subsidiary as it asserts, this would not require invalidation of the ABO determination,” DiFiore wrote. “The PAAA does not contain a reporting exception for subsidiaries of local authorities, and petitioners have not identified any other statute or regulation that excused MGFC from its obligation to separately report.”
DiFiore's opinion outlined the broad authority prescribed by the state Legislature to the ABO to oversee the activities of local agencies, which can include economic and industrial development agencies, as well as nonprofit organizations sometimes created by municipalities for investment purposes. The former are funded partly through government grants, but mostly through projects and properties they manage.
“The Authority Reform Act [of 2009] removed the ABO from the umbrella of the Division of Budget, reestablished it as an independent entity and enhanced its powers,” DiFiore wrote. “Particularly relevant to this dispute, the ABO was given broad authority to 'request and receive from any state and local authority … such … information, books, records, other documentation, and cooperation as may be necessary to perform its duties.'”
The office also has a wide range of enforcement powers, DiFiore wrote, including the authority to act on complaints against an entity, initiate investigations, issue subpoenas and more. The vast role the ABO fills as an investigatory and enforcement entity overseeing state and local authorities gave it the power to require separate reports from MCIDA and MGFC, DiFiore wrote.
“It was not irrational for the ABO to decline to 'treat' MGFC as a subsidiary of MCIDA for the limited reporting purpose,” DiFiore wrote. “Such action was consistent with the plain language of the PAAA and the ABO's mandate to ensure transparency by compelling reporting compliance by public authorities, including affiliates of IDAs such as MGFC.”
MCIDA was represented before the Court of Appeals by Charles Malcomb, a partner at Hodgson Russ in Buffalo. Malcomb did not immediately offer comment on the decision.
READ MORE:
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllBen & Jerry’s Accuses Corporate Parent of ‘Silencing’ Support for Palestinian Rights
3 minute readTrending Stories
- 1Remembering Ted Olson
- 2Support Magistrates: Statutorily Significant
- 3Nelson Mullins, Greenberg Traurig, Jones Day Have Established Themselves As Biggest Outsiders in Atlanta Legal Market
- 4Immunity for Mental Health Care and Coverage for CBD: What's on the Pa. High Court's November Calendar
- 5Monday Newspaper
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250