Matter of Casino Towing Serv., Inc. v. New York City Dept. of Consumer & Worker Protection
The Appellate Division, First Department, affirmed a Supreme Court judgment that denied a petition by Casino Towing Service, Inc. to annul a determination by the New York City Department of Consumer and Worker Protection (DCWP). DCWP had suspended Casino Towing's tow truck license for three months due to violations of insurance coverage rules, specifically for modifying its policy to reduce coverage below mandated amounts and failing to report the change within 10 days. The Appellate Division found DCWP's determination to be rationally supported by the record and not arbitrary and capricious. The court further held that Casino Towing did not have a constitutional due process right to a hearing, as there is no property interest in the renewal of an expired license and adequate notice and opportunity for written submissions were provided. The penalty was also deemed not to shock the conscience.