Rivera v. Espada

193 Misc. 2d 773
CourtNew York Supreme Court
DecidedSeptember 9, 2002
StatusPublished

This text of 193 Misc. 2d 773 (Rivera v. Espada) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rivera v. Espada, 193 Misc. 2d 773 (N.Y. Super. Ct. 2002).

Opinion

OPINION OF THE COURT

Robert G. Seewald, J.

In the first captioned proceeding (Index No. 22489/2002), petitioners seek to cancel the Democratic enrollment of Pedro Espada, Jr. based on a redetermination by the Chair of the County Committee of the Bronx Democratic Party, Carl E. Heastie. In accordance with a decision by the New York State Court of Appeals (98 NY2d 422 [Aug. 30, 2002]) this proceeding was remitted to this court with the direction to remit for redetermination to Chairman Heastie. The second captioned proceeding (Index No. 23852/2002) seeks to invalidate the designating petitions of Pedro Espada, Jr., as a Democratic candidate for the public office of Member of the State Senate, 32nd Senatorial District, Bronx County, in the Democratic Party primary to be held on September 10, 2002.

In an order to show cause brought by Pedro Espada, Jr. in opposition to the first proceeding herein set forth (Index No. 22489/2002), he seeks to stay or disqualify Chairman Heastie as the Chair of the County Committee of the Bronx Democratic [775]*775Party from rendering a determination based on his alleged apparent and actual bias against Pedro Espada, Jr., both personally and politically.

The proceeding to cancel the Democratic Party enrollment of Pedro Espada, Jr. was initially returnable in this court on July 17, 2002. Thereafter, oral argument was heard by this court on July 24, 2002 and further memoranda were submitted on August 1, 2002. On August 8, 2002, this court rendered a lengthy determination directing the Board of Elections to cancel Mr. Espada’s Bronx Democratic voter enrollment.

On appeal, the Appellate Division, First Department, reversed this court’s decision by a three to two majority (297 AD2d 251 [2002]). The petitioners subsequently appealed that decision to the Court of Appeals.

On August 30, 2002, the New York State Court of Appeals rendered a per curiam decision (98 NY2d 422 [2002]), which directed this court to remit the proceeding to the Chair of the County Committee of the Bronx Democratic Party for a redetermination. By order dated September 5, 2002, this court directed the petitioners to remit the matter to Chairman Heastie since Chairman Heastie was not named as a party to the proceedings. The court notes that on September 3, 2002, in a separate election proceeding, the proposed language of the aforesaid September 5, 2002 written order was read into the record. In addition, counsel for Mr. Espada presented a proposed order for the court’s consideration. After argument by both sides, respondent moved to dismiss the proceeding which seeks to cancel his enrollment (Index No. 22489/2002). The September 5, 2002 order of this court denied that request.

Two procedural issues were raised by respondent in opposition to these proceedings.

Initially, respondent contends that the Court of Appeals, in remitting the matter back to this court for remittal back to the County Committee Chair for a redetermination, required that a new hearing be held. Chairman Heastie did not conduct a new hearing. He issued a redetermination dated September 5, 2002, based upon a review of the entire record of the proceedings held before him on June 21 and 27, 2002. Chairman Heastie stated that he purged the record of all matters related to Senator Espada’s legislative acts, majority conference participation, evidence concerning internal workings of the Senate, and publications of the Senate, in accordance with the mandate of the Court of Appeals.

In this court’s view, Chairman Heastie’s actions in not conducting a new hearing were in compliance with the direc[776]*776tion of the Court of Appeals decision. The Court of Appeals clearly used the term “redetermination,” not “re-hearing,” thereby permitting a finding that Chairman Heastie acted in accord with its mandate. Accordingly, insofar as respondent’s application seeks a new hearing prior to a redetermination being issued on the grounds that same was required by the decision of the Court of Appeals, it is denied.

The second procedural issue concerns whether Chairman Heastie was required to give Pedro Espada, Jr., notice of the redetermination prior to rendering same. A written request for such notice was forwarded to the Chairman but apparently was not honored.

A review of the determination issued by Chairman Heastie reveals that he relied only on the evidence originally presented at the hearing. As noted earlier herein, Chairman Heastie purged from the record that evidence which the Court of Appeals required be purged and specifically detailed the evidence which he considered in rendering his redetermination. As a consequence thereof, counsel had an opportunity at the hearing to raise any and all objections to each and every item sought to be considered by the Chairman. Under the circumstances, the requirements of due process do not mandate that the respondent be given further notice and an additional opportunity to be heard. Accordingly, insofar as the application seeks a rehearing based on the failure to serve notice, the application is denied.

A jurisdictional objection was raised in connection with these proceedings. It is argued that a necessary party was omitted from the remitted proceeding. The New York State Senate, although not an original party to these proceedings, sought, and was granted permission, to intervene at both the Appellate Division and Court of Appeals. The question thus becomes whether the intervenor becomes a necessary party on the redetermination and ensuing order to show cause made to this court. It should be noted that neither party noticed or served the intervenor herein.

Ordinarily, an intervenor is entitled to notice of the proceeding. In the instant matter, the intervenor sought to protect a legislator’s rights under the Speech or Debate Clause of the New York State Constitution (art III, § 11). Upon redetermination, since all items with respect to the Speech or Debate Clause have been purged, there does not appear to be any interest to be represented by the intervenor. In any event, the court finds the failure to notice the intervenor is not a [777]*777jurisdictional defect. It is apparent that all parties were aware of these proceedings and the intervenor had an opportunity to represent the legislative interest. Accordingly, the application to dismiss these proceedings based on the failure to notice the intervenor is denied.

The respondent also seeks to stay or disqualify Chairman Heastie based upon his alleged bias.

In the prior proceedings before this court, the issue of the bias of Chairman Heastie was raised based on several factors including a statement made to the New York Times on June 7, 2002 (Rivera v Espada, Sup Ct, Bronx County, Aug. 8, 2002, Index No. 22489/2002). In this court’s decision of August 8, 2002, it was recognized that there was a built-in intra-party bias in having the Chair of the County Committee decide such matters pursuant to Election Law § 16-110 (2). This statute is clear in its directive that the authority to make such determination is specifically vested in the County Committee Chair of the affected political party. In fact, the New York State Court of Appeals, in its decision of August 30, 2002, directed that this proceeding be returned by this court to Chairman Heastie for his redetermination. Neither appellate court discussed the issue of the Chair’s bias.

In the hearing before this court on September 6, 2002, Mr.

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Related

MATTER OF RIVERA v. Espada
777 N.E.2d 235 (New York Court of Appeals, 2002)

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Bluebook (online)
193 Misc. 2d 773, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-espada-nysupct-2002.