Matter of Save America's Clocks, Inc. v. City of New York
This case involves a CPLR article 78 proceeding challenging a decision by the New York City Landmarks Preservation Commission (LPC). The petitioners sought to overturn the LPC's approval of a Certificate of Appropriateness (COA) that would allow a property owner to convert the clocktower of a historic building (346 Broadway) into a private residence, disconnect its unique purely mechanical clock from its mechanism, and electrify it. The clocktower, an interior landmark designated in 1989, houses one of the few remaining nineteenth-century nonelectrified mechanical clocks. The Supreme Court partially annulled the COA, ruling that the LPC's decision was based on an error of law and was irrational regarding the elimination of public access and the electrification of the clock. This appellate decision affirms that ruling, finding that the LPC has the authority under the Landmarks Law to regulate the clock mechanism and to require public access, and that its reliance on erroneous legal advice led to an irrational decision. The dissenting opinion argues that the LPC acted rationally and within its statutory authority, particularly considering the practical limitations of public access and the preservation of the clock's mechanism.