Hoesl v. Kearns
Petitioner, a police officer and president of the Garden City Police Benevolent Association, initiated a CPLR article 78 proceeding seeking a judgment to prevent the Chief of the Garden City Police Department from allowing "Special Police Officers" to drive departmental vehicles with police markings. Petitioner contended this practice violated Vehicle and Traffic Law § 396(2), which restricts such operation to members or employees of a duly organized police department. The respondent cross-moved for dismissal, citing various procedural grounds including the Statute of Limitations. The court treated the proceeding as one in the nature of mandamus, denied the dismissal on procedural and Statute of Limitations grounds, and addressed the merits. The court found that "Special Police Officers," despite serving without remuneration, are considered "members" or "employees" under relevant statutes and departmental rules, and their use of marked departmental vehicles for official business is not prohibited by Vehicle and Traffic Law § 396(2). Consequently, the court dismissed the petition.