Chavis v. New York Temporary State Commission on Lobbying
The petitioners, led by Dr. Benjamin Chavis on behalf of the Coalition for Fairness, initiated a CPLR article 78 proceeding against the New York Temporary State Commission on Lobbying and its Executive Director, David Grandeau. They sought to compel the Commission to adopt rules for adjudicatory proceedings compliant with the State Administrative Procedure Act (SAPA) and to nullify a prior determination regarding a failure to file a semiannual report. The court ruled that the Commission was not an "agency" under SAPA due to a lack of rulemaking authority and the power to make final adjudicatory decisions. However, the court converted the proceeding to a declaratory judgment action and declared sections 1-n (b) and (c) of the Lobbying Act unconstitutional for violating federal and state Due Process Clauses by failing to provide notice and a hearing prior to determining a knowing and willful violation. The Commission's subsequently issued guidelines were deemed insufficient to rectify this statutory defect.