Madison County Industrial Development Agency v. State Authorities Budget Office

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The Court of Appeals held that the determination of the New York State Authorities Budget Office (ABO) denying the request of Petitioners - Madison County Industrial Development Agency (MCIDA) and Madison Grant Facilitation Corporation (MGFC) - to file consolidated audit reports was not irrational, arbitrary and capricious, or contrary to law. ABO informed MCFC that it must comply with the reporting requirements of the Public Authorities Accountability Act (PAAA) as a corporation legally affiliated with MCIDA, an industrial development agency (IDA) and a “local authority” subject to the PAAA. MCIDA asked that the ABO treat MGFC as its subsidiary and allow the two entities to file consolidated reports. The ABO denied MCIDA’s request after the Attorney General issued a formal opinion concluding that an IDA is not authorized to create a subsidiary. Petitioners then commenced this N.Y. C.P.L.R. 78 proceeding challenging the ABO’s determination. The Court of Appeals affirmed, holding that the ABO’s narrow record-keeping determination was not contrary to law, nor was it irrational or arbitrary and capricious. View "Madison County Industrial Development Agency v. State Authorities Budget Office" on Justia Law