O’Donnell & Sons, Inc., on behalf of itself and all persons similarly situated v. New York State Department of Taxation and Finance, et al.

District Court, S.D. New York·Decided July 27, 2026·No. 7:25-cv-08874·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------------------x O’DONNELL & SONS, INC., on behalf of itself and all persons similarly situated,

Plaintiff, OPINION & ORDER ON MOTION TO DISMISS - against - No. 25-CV-8874 (CS) NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE, et al.,

Defendants. -------------------------------------------------------------x

Appearances: John F. Harnes Law Offices of John F. Harnes PLLC Pawling, New York

Paul Quartararo Paul Quartararo, Esq., PLLC Millbrook, New York Counsel for Plaintiff

Stephanie Costa Assistant Attorney General New York, New York Counsel for Defendants

Seibel, J. Before the Court is Defendants’ motion to dismiss Plaintiff’s Amended Complaint. (ECF No. 18.) For the reasons set forth below, the motion is granted.1 I. BACKGROUND For purposes of the motion, I accept as true the facts, but not the conclusions, set forth in Plaintiffs’ Amended Complaint. (ECF No. 15 (“AC”).)

1 Plaintiff also filed a letter motion requesting oral argument. (ECF No. 22.) That motion is denied. Facts On November 9, 2023, Plaintiff O’Donnell & Sons, Inc., a New York corporation, obtained a mortgage on real property located in Dutchess County, New York, from TEG Federal Credit Union (“TEG”). (AC ¶ 1.) As part of that transaction and under its mortgage commitment letter with TEG, Plaintiff paid $5,570 pursuant to New York Tax Law §§ 253 and

253-a, also known as New York’s Mortgage Recording Tax (the “MRT”). (Id. ¶¶ 1, 29, 38-39.) The MRT imposes “a tax of fifty cents for every $100 of principal debt” upon the recording of a mortgage of real property situated within New York State. N.Y. Tax Law §§ 253(1), 257. (See AC ¶ 16.) New York’s courts have long determined that the MRT is not a tax on the mortgage itself but on the “privilege” of recording the mortgage. (See AC ¶¶ 17-22 (detailing the state constitutional issue that led to this interpretation of New York law).) The statute does not say who is required to pay the tax, but Plaintiff alleges that the “legal incidence” of the tax most naturally falls on the lender. (Id. ¶ 23.) Other provisions in New York’s tax code prevent a mortgage from being recorded, released, discharged, received into

evidence, assigned, or extended if the MRT has not been paid, and New York treats any unrecorded mortgage as void against a subsequent good faith purchaser or lienholder. (Id. ¶ 24.) As a result, a mortgage issued without payment of the MRT, and therefore without being recorded, is “worthless” to the lender who issues it. (Id.) To enforce the collection of the MRT, the New York Attorney General may maintain an action against the lender or, where the borrower and lender have agreed that the borrower will pay, against the borrower. (Id. ¶ 25.) Typically, federal credit unions (“FCU”s) like TEG require as a contractual term of their mortgage commitments that borrowers procure a lenders’ title insurance policy and pay all required fees, including the MRT, to obtain the mortgage loan. (Id. ¶¶ 28-29.) Plaintiff says that this term effectively means that borrowers are paying the MRT “involuntarily” and “under compulsion,” even though FCUs as lenders should be “solely answerable” for the tax. (Id. ¶ 29) The problem with this passing through of the MRT, as Plaintiff sees it, is not only that borrowers are footing the bill for FCUs, but also that a federal statute prevents New York from

taxing FCUs in the first place. (Id. ¶ 35.) The Federal Credit Union Act (“FCU Act”) established the framework to create and regulate FCUs, which are member-owned and managed cooperative associations that, among other activities, offer credit to members. (Id. ¶ 30.) Most loans that FCUs issue are mortgage loans. (Id. ¶ 32.) The FCU Act provides, in pertinent part, that FCUs and “their property, their franchises, capital, reserves, surpluses, and other funds, and their income” are “exempt from all taxation now or hereafter imposed by . . . any State,” except that their “real property and any tangible personal property” may be taxed. 12 U.S.C. § 1768. (See AC ¶ 34.) New York nevertheless continues to require payment of the MRT in connection with mortgages issued by FCUs. (See AC ¶¶ 38-39.) But FCUs like TEG have little incentive to

challenge the MRT because they can pass responsibility onto borrowers like Plaintiff. (See id. ¶ 64.) In 2008, however, Hudson Valley Federal Credit Union sought to challenge the MRT by arguing that the FCU Act exempted FCUs from paying the MRT and that they were immune from state taxation as an instrumentality of the federal government. (Id. ¶¶ 40-41.) At all three levels of New York’s courts, Hudson Valley lost its challenge. (Id. ¶¶ 43-45, 50.) In Hudson Valley Federal Credit Union v. N.Y. State Department of Taxation & Finance, 20 N.Y.3d 1 (2012) (“Hudson Valley”), the Court of Appeals rejected Hudson Valley’s arguments. (Id. ¶ 50.) First, it found that the FCU Act does not prohibit taxing FCUs’ mortgages because mortgages are not included in the list of property exempted from the tax – unlike other statutes that specifically exempt mortgages – and because mortgages are not “property” under the FCU Act. See Hudson Valley, 20 N.Y.3d at 2-5. (See also AC ¶ 51.) It further concluded that FCUs are not federal instrumentalities exempt from taxation under the Supremacy Clause. See Hudson Valley, 20 N.Y.3d at 6-7. (See also AC ¶ 52.) In what Plaintiff describes as an “enigmatic footnote,” (AC

¶ 53), the court – based on its prior holdings that the MRT was a tax on the privilege of recording, not on the mortgage – distinguished two cases that had held that a tax on the recording of an entity’s instrument was the same as a tax on the entity. See Hudson Valley, 20 N.Y.3d at 5 n.5. On Plaintiff’s read of the case, this footnote renders the rest of the opinion dictum, because if the MRT is a tax on recording a mortgage, not on the mortgage itself, it is irrelevant whether the FCU Act prohibits taxes on FCUs’ mortgages or whether FCUs are federal instrumentalities. (AC ¶¶ 53-54.) In that footnote, the Court of Appeals reaffirmed long-held New York precedent about how the MRT is properly characterized, and observed that three federal courts had reached

conflicting conclusions about similar types of taxes – two agreeing with Hudson Valley and one supporting the court’s view. See Hudson Valley, 20 N.Y.3d at 5 n.5. (See also AC ¶¶ 53-54.) Since Hudson Valley, however, federal courts have rejected similar reasoning when analyzing what Plaintiff asserts is comparable language in other federal statutes applied to comparable tax schemes. (AC ¶ 58.)2 Further, the federal case on which the Court of Appeals relied in its

2 Most, if not all, of these cases involve taxes on the sale or transfer of real property imposed on the Federal National Mortgage Association (“Fannie Mae”) and the Federal Home Loan Mortgage Corporation (“Freddie Mac”). See, e.g., Bd. of Cnty. Comm’rs of Kay Cnty., Okla. v. Fed. Hous. Fin. Agency, 754 F.3d 1025, 1027 (D.C. Cir. 2014); Town of Johnston v. Fed. Hous. Fin. Agency, 765 F.3d 80, 82 (1st Cir. 2014). The statute granting Fannie Mae and Freddie Mac tax exemptions is “similar [but] not identical” to the FCU Act’s tax exemption. footnote was vacated and remanded. See County of Oakland v. Fed. Hous. Fin. Agency, 716 F.3d 935, 944 (6th Cir. 2013). (See also AC ¶¶ 59-60.) Plaintiff says federal courts have “skewered” Hudson Valley’s logic and found that “it fails to comport with common sense.” (AC ¶¶ 61, 63.) Plaintiff now brings the instant action to challenge the MRT in connection with its 2023

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O’Donnell & Sons, Inc., on behalf of itself and all persons similarly situated v. New York State Department of Taxation and Finance, et al., (S.D.N.Y. 2026).

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