Butler v. Monaghan
City police officers sought a temporary injunction and declaratory judgment to invalidate a police commissioner's rule prohibiting police force members from joining labor unions. The court addressed whether plaintiffs would suffer irreparable harm and the likelihood of their success on the merits. It found no irreparable harm, as officers could withdraw union applications or appeal disciplinary actions, leading to full restoration of rights if successful. Furthermore, the court noted that previous rulings in other states consistently upheld the commissioner's authority in such matters. The court also highlighted that the New York State Constitution's provision on employee organization was specifically amended to exclude public employees. Consequently, the motion for a temporary injunction was denied.