Forum
U.S. District Court for the Northern District of New York
Case Status
Decided
Docket Number
1:03-cv-00413-NPM-RFT
Case Updates
U.S. District Court for the Northern District of New York addresses preemption of state law by National Labor Relations Act
September 07, 2011
Previously, the U.S. District Court for the Northern District of New York ruled that it is not bound by the Second Circuit's mandate in light of the Supreme Court's decision in Chamber of Commerce v. Brown. In 2006, the Second Circuit overturned a district court ruling that a New York law restricting employers from using state money to encourage or discourage union organizing is preempted by federal labor law, and remanded the case back to district court for factual development.
On 9/7/11, the District Court held that N.Y. LAB. LAW § 211-a is preempted by the National Labor Relations Act under the doctrine of Machinists preemption, and the state is permanently enjoined from implementing or enforcing the statute.
Amicus brief filed with district court 11/12/03. Oral argument on motion to dismiss held 9/13/04. Amicus letter filed with district court 11/9/04. Decided 5/17/05. Notice of appeal filed 5/25/05. Amicus brief filed with Second Circuit filed 12/7/05. Decided 12/5/06. Subsequent amicus brief filed 9/16/08, after Supreme Court's decision in Chamber v. Brown. District court ruling on remand 3/23/10. Amicus brief on remand filed 5/28/10. Decided 9/7/11.
Case Documents
- Healthcare Association of New York State, Inc., et al. v. Pataki, et al. (NCLC Amicus Letter, District Court).pdf
- Healthcare Association of New York State, Inc., et al. v. Pataki, et al. (NCLC Brief on Merits, Second Circuit).pdf
- Healthcare Association of New York State, Inc., et al. v. Pataki, et al. (NCLC Brief on Chamber v. Brown, District Court).pdf
- Healthcare Association of New York State, Inc., et al. v. Paterson, et al. (NCLC Brief on Summary Judgment, District Court).pdf
- Healthcare Assn v Cuomo decision.pdf