People v. Prasarn

2019 NY Slip Op 52208(U)
CourtIthaca City Court
DecidedSeptember 30, 2019
DocketIndex No. CR-4600-18
StatusUnpublished

This text of 2019 NY Slip Op 52208(U) (People v. Prasarn) is published on Counsel Stack Legal Research, covering Ithaca City Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Prasarn, 2019 NY Slip Op 52208(U) (N.Y. Super. Ct. 2019).

Opinion

People v Prasarn (2019 NY Slip Op 52208(U)) [*1]
People v Prasarn
2019 NY Slip Op 52208(U)
Decided on September 30, 2019
City Court Of Ithaca, Tompkins County
Miller, J.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and will not be published in the printed Official Reports.


Decided on September 30, 2019
City Court of Ithaca, Tompkins County


People of the State of New York, Plaintiff,

against

Paul Prasarn, Defendant.




Index No. CR-4600-18

Attorney for Defendant: Robert C. Kilmer, Esq.; Attorney for City of Ithaca (People): Robert A. Sarachan, Esq., Assistant City of Ithaca Attorney Scott A. Miller, J.

Defendant moves for dismissal of the accusatory instrument charging Defendant with a violation of Ithaca City Code, §219-2(A)(1), which prohibits hunting within city limits, on the basis that the Local Law is preempted by New York State Law. Ithaca City Code §219-2(A)(1) provides:

No person shall hunt, pursue or kill with a gun or firearm any wild animals, fowl or birds or engage in hunting within the city.
In short, §219-2(A)(1) completely bans all manner of hunting anywhere within the City of Ithaca.

The People allege that Defendant committed the offense of "Hunting Within City Limits in violation of section 219-2, subdivision A(1) of the New York State, City of Ithaca Local Law. A violation level offense." The Accusatory Instrument, based on an Ithaca Police Officer Cosgrove's direct knowledge, affirms:

On or about the 21st of November 2018, at about 8:35 am, While located along the southern edge of Cayuga Lake, north of the Hangar Theater at 801 Taughannock Boulevard, Ithaca, NY 14850, a person is guilty of hunting within the city limits by: No person shall hunt, pursue or kill with a gun or firearm any wild animals, fowl or birds or engage in hunting within the city. To Wit: At the aforesaid date, time and location the defendant did: engage in hunting waterfowl at the location listed above, which falls within the City of Ithaca, NY's boundaries.


The DEC Amicus letter states that Mr. Prasarn was in a boat on Cayuga Lake within the City's boundaries (January 18, 2019 Letter from Joseph Sluzar, Region 7 Attorney), and none of the parties has disputed this. The City Attorney states, also without contradiction, that Mr. Prasarn was duck hunting with a shotgun within the boundaries of the City (People's Sur-reply May 13, [*2]2019). It is unclear if Mr. Prasarn actually discharged his shotgun at any time.

Preemption Doctrine:

Preemption analysis is mainly a question of legislative intent, whether the legislative body is the US Congress or the New York state Legislature (State ex rel Grupp v. DHL Exp(USA), Inc., 19 NY3d 278 [2012]; Garcia v. New York City Dept of Health and Mental Hygiene, 31 NY3d [2018]). A notable treatise on municipal corporations enumerates three types of preemption:

Between the state and a municipality, as between the state and federal laws, there are three generally recognized types of preemption: (1) express or explicit preemption, where the statute includes a preemption clause, the language of which specifically bars local authorities from acting on a particular subject matter; (2) conflict preemption, where the local enactment irreconcilably conflicts with or stands as an obstacle to the execution of the full purposes of the statute; and (3) field preemption, where analysis of the entire statute reveals the General Assembly's implicit intent to occupy the field completely and to permit no local enactments.
McQuillin Mun. Corp. § 15:19 Conformity to state and federal laws—Types and tests for preemption, 5 (3d ed.) Emphasis added.

Defendant argues both conflict and field preemption, but not express preemption. Indeed, the New York State Constitution and the ECL enabling statutes do not contain express preemption or superseder clauses. NY Const, art XIV; NY ECL 1-0101 et seq.

As part of home rule, the City has the power to "maintain order, enforce the laws, ... preserve and care for the safety, health, comfort and general welfare of the inhabitants of the city and visitors thereto," including "waterfront and waterways and adjacent property" (NY General City Law §20, see NY Mun Home Rule Law §10 ). In addition to the "powers granted in the statute of local governments or any other law, every local government [has] the power to adopt and amend local law" as long as it is not "inconsistent with the provisions of this constitution or any general law relating" to its property, affairs or government and a list of enumerated subjects, including "the government protection, order, conduct, safety, health and well-being of persons or property therein"(NY Const. Art.IX§2). Neither environmental conservation nor hunting is one of the enumerated subjects, and, therefore preemption analysis is required.

The Court of Appeals has acknowledged the power of local governments to protect the welfare of its residents under home rule as long as the local law 1) does not conflict with or 2) is not preempted by State law. The Court has stated:

The constitutional home rule provision confers broad police power upon local government relating to the welfare of its citizens (see, People v. De Jesus, 54 NY2d 465, 468). However, it places two firm restrictions on their use: (1) the local government (here, the City of New York) may not exercise its police power by adopting a local law inconsistent with constitutional or general law; and (2) the City may not exercise its police power when the Legislature has restricted such an exercise by preempting the area of regulation. The legislative intent to preempt need not be express. It is enough that the Legislature has impliedly evinced its desire to do so and that desire may be inferred from a declaration of State policy by the Legislature or from the legislative enactment of a comprehensive and detailed regulatory scheme in a [*3]particular area. Similarly, with respect to inconsistency, we have stated that there need not be an express conflict between State and local laws to render a local law invalid. Rather, inconsistency "has been found where local laws prohibit what would have been permissible under State law or impose 'prerequisite "additional restrictions" ' on rights under State law, so as to inhibit the operation of the State's general laws." New York State Club Ass'n, Inc. v. City of New York, 69 NY2d 211, 217 (1987).


"The preemption doctrine embodies 'the untrammeled primacy of the Legislature' to act *** with respect to matters of State concern.'" Albany Area Builders Assn. v Town of Guilderland, 74 NY2d 372, 377 (1989) (quoting, Wambat Realty Corp. v. State of New York, 41 NY2d 490, 497 (1977)). In Albany Area Builders Assn. at 377, the Court further explained, "[w]here the State has preempted the field, a local law regulating the same subject matter is deemed inconsistent with the State's transcendent interest, whether or not the terms of the local law actually conflict with a State-wide statute."

Judge Ecker, in

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Related

Wambat Realty Corp. v. State
362 N.E.2d 581 (New York Court of Appeals, 1977)
State ex rel. Grupp v. DHL Express (USA), Inc.
970 N.E.2d 391 (New York Court of Appeals, 2012)
People v. De Jesus
430 N.E.2d 1260 (New York Court of Appeals, 1981)
Consolidated Edison Co. of New York, Inc. v. Town of Red Hook
456 N.E.2d 487 (New York Court of Appeals, 1983)
New York State Club Ass'n v. City of New York
505 N.E.2d 915 (New York Court of Appeals, 1987)
Albany Area Builders Ass'n v. Town of Guilderland
546 N.E.2d 920 (New York Court of Appeals, 1989)
Woodbury Heights Estates Water Co. v. Village of Woodbury
37 Misc. 3d 180 (New York Supreme Court, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
2019 NY Slip Op 52208(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-prasarn-nyithacacityct-2019.