Erie County Water Authority v. Kramer
The Erie County Water Authority initiated an Article 78 proceeding to prevent the New York State Labor Relations Board from asserting jurisdiction over an unfair labor practice complaint. The Authority, a state agency, argued its exemption from the New York State Labor Relations Act, despite a provision in the Public Authorities Law stating it is an 'employer.' The court reviewed relevant labor and civil service laws, as well as prior case law concerning state agencies and collective bargaining. Ultimately, the court determined that the Authority, as an agency of the state, falls under the exemptions of Labor Law Section 715, thus not subject to the collective bargaining requirements of Article 20 of the Labor Law. Therefore, the application to enjoin the Board's actions was granted due to lack of jurisdiction.