Fourth Department – Education Law: Eisenhauer v. Watertown City School District

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New York State Supreme Court, Appellate Division, Fourth Judicial Department

Education Law

Funding libraries – Tax

Eisenhauer v. Watertown City School District

CA 21-00813

Appealed from Supreme Court, Jefferson County

Background: The petitioners-plaintiffs are homeowners who commenced a hybrid CPLR Article 78 proceeding and declaratory judgment action seeking to annul the results of the 2020 school district election to the extent that the voters approved Proposition 1, which imposed a new tax on real property within the school district for the purpose of raising money annually for the respondent-defendant library. They argue that Proposition 1 is invalid and was improperly enacted in violation of the library’s authorizing legislation, the Education Law, and Article IX of the New York State Constitution.

Ruling: The Appellate Division declared that Proposition 1 is not null and void. The court held that the petitioners’ claims lacked merit. Although the authorizing legislation requires the city to provide the library with at least $5,000 annually, it does not foreclose other entities from providing the library with additional funding. Further, the Education Law authorizes school districts with the authority to levy, collect, and appropriate taxes to fund a public library and to submit a proposition to raise money for the library. The Appellate Division also held that the proposition does not offend equal protection clause or due process.

William F. Ryan Jr., of Tabner, Ryan & Keniry, for the petitioners-plaintiffs-appellants; Charles C. Spagnoli, of the Law Firm of Frank W. Miller, Robert J. Slye, of Slye Law Offices and Ellen M. Bach, of Whiteman Osterman & Hanna, for the respondents-defendants-respondents.