Association of American Medical Colleges v. Carey

482 F. Supp. 1358, 205 U.S.P.Q. (BNA) 42, 1980 U.S. Dist. LEXIS 10980
CourtDistrict Court, N.D. New York
DecidedJanuary 22, 1980
DocketCiv. A. 79-CV-730
StatusPublished
Cited by15 cases

This text of 482 F. Supp. 1358 (Association of American Medical Colleges v. Carey) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Association of American Medical Colleges v. Carey, 482 F. Supp. 1358, 205 U.S.P.Q. (BNA) 42, 1980 U.S. Dist. LEXIS 10980 (N.D.N.Y. 1980).

Opinion

MEMORANDUM — DECISION AND ORDER

McCURN, District Judge.

In this action for declaratory and injunctive relief, plaintiff, Association of American Medical Colleges, challenges the legality and constitutionality of certain provisions of the New York Standardized Testing Act, Article 7-A of the New York Education Law, as they apply to its Medical College Admission Test (“MCAT”) and to unpublished studies, evaluations and reports pertaining to the MCAT. The lawsuit is presently before the Court on plaintiff’s motion for a preliminary injunction. 1

Plaintiff is a non-profit educational association whose members comprise 125 United States Schools of Medicine, 418 teaching hospitals, 68 academic societies and over 1,700 individuals.

Defendant, Hugh L. Carey, is the Governor of the State of New York, and is being sued both individually and in his capacity as Governor.

Defendants, Black, Genrich, Clark, New-comb, Griffith, Kendall, Batista, Yavner, Chodos, Bareli, Bongiorno, Matteoni, Meyer, Reed-Delaney and Caraballada, are members of the Board of Regents of the University of the State of New York and are defendants in this action both individually and in their official capacity. 2

Defendant, Gordon M. Ambach, is the Commissioner of Education for the State of New York and is named as a defendant both individually and in his official Capacity-

Defendant, Robert Abrams, is the Attorney General for the State of New York and *1360 named as a defendant individually and as Attorney General.

Jurisdiction is alleged pursuant to 28 U.S.C. §§ 1331, 1338(a) and 1343(3). Declaratory relief is sought pursuant to 28 U.S.C. §§ 2201 and 2202.

BACKGROUND

On July 13, 1979, Governor Carey signed into Law Article 7-A of the Education Law, popularly referred to as the “Truth in Testing” Law. (N.Y.Ed. Law §§ 340 et seq.) Effective January 1, 1980, the Law applies to “any test that is given at the expense of the test subject and designed for use in the process of selection for post-secondary or professional school admissions.” [N.Y.Ed.Law § 340(1)]. The MCAT given by plaintiff is specifically included under the Law. [§ 340(1)].

In addition to provisions which set forth various notice requirements (§ 343) and requirements for disclosure of test results by test agencies (§ 344), the Law imposes certain obligations on test agencies with regard to disclosure of studies, background reports and statistical data pertaining to the tests (§ 341) 3 and of the contents of the tests themselves (§ 342). 4 It is these last two provisions which plaintiff finds unacceptable.

Plaintiff alleges the advancement of medical education and health care in the United States as its sole reason for existence. In furtherance of this purpose plaintiff has, for almost fifty years, sponsored a testing program for medical school applicants. This program includes the development and administration of the MCAT. 5

In connection with its sponsorship of the MCAT, plaintiff also prepares or causes to be prepared, on an ongoing basis, confidential unpublished studies, evaluations and reports pertaining to the MCAT. These include studies of the performance of graduates of particular undergraduate schools and reports consisting of evaluations of test subject’s performance on individual questions for use in developing new questions. Both of these types of studies are prepared on a confidential basis.

*1361 Detailed security procedures govern all phases of development of the MCAT, including test book assembly, printing and distribution. Beginning with the April 1978 MCAT, plaintiff has registered every test form with the Register of Copyright in conformity with the deposit procedures set forth at 37 C.F.R. § 202.20(c)(2)(vi). 6

In 1979, the MCAT was administered four times, on consecutive Saturdays and Sundays in the Spring and Fall at approximately 450 test centers throughout the world, including 26 in the State of New York. The test was taken by approximately 48,000 individuals, 5,000 of whom took the test in New York State. Plaintiff has indicated that a similar schedule had been planned for 1980. Plaintiff has made clear that it does not intend to administer the MCAT in New York State in 1980 if forced to comply with Sections 341 and 342 of the Testing Act. 7

DISCUSSION

In seeking to enjoin enforcement of Sections 341 and 342 of the “Truth in Testing” Law, plaintiff alleges that the Act violates the federal Copyright Act, and furthermore, that it is, in fact, preempted by the Copyright Act. Plaintiff also raises constitutional issues under both the United States and New York State Constitutions, alleging specifically a denial of due process and equal protection rights.

Claiming that it will suffer irreparable harm if forced to comply with the challenged provisions, plaintiff asks the Court to grant a preliminary injunction, enjoining enforcement of Sections 341 and 342 pending a determination on the merits.

Opposing the motion, defendants raise threshold jurisdictional questions concerning applicability of the Eleventh Amendment as a bar to this action, ripeness and whether proper defendants have been named in the action. In addition, defendants allege laches on the part of plaintiff in commencing this action, which according to defendants precludes issuance of a preliminary injunction. 8 Jurisdiction

A.

Defendants, citing Edelman v. Jordan, 415 U.S. 651, 94 S.Ct. 1347, 39 L.Ed.2d 662 (1974) and Alabama v. Pugh, 438 U.S. 781, 98 S.Ct. 3057, 57 L.Ed.2d 1114 (1978), assert that the Eleventh Amendment to the Constitution bars this action against the State officials named as defendants. 9

*1362

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Bluebook (online)
482 F. Supp. 1358, 205 U.S.P.Q. (BNA) 42, 1980 U.S. Dist. LEXIS 10980, Counsel Stack Legal Research, https://law.counselstack.com/opinion/association-of-american-medical-colleges-v-carey-nynd-1980.