In the Matter of Stoll v. New York State College of Veterinary Medicine at Cornell University
New York Court of Appeals
94 N.Y.2d 162, 723 N.E.2d 65, 701 N.Y.S.2d 316 (1999)
Cornell University was a private university that housed four statutory colleges (defendants) created by the New York legislature. These statutory colleges were operated by Cornell on behalf of the State University of New York (SUNY). The legislature gave Cornell certain administrative control over the statutory colleges, such as creating the curriculum, hiring faculty, maintenance of discipline, and creating educational policy for the colleges. Though the SUNY Board of Directors did not have operational control over the statutory colleges, it did retain some oversight. The statutory colleges were funded with state funds, and Cornell was required to consult with SUNY concerning the colleges’ financial matters and tuition. SUNY owned the property and buildings that house the statutory colleges, though Cornell assumed the daily operations. Stoll (plaintiff) filed a request with Cornell under the Freedom of Information Law (FOIL) seeking copies of any disciplinary complaints and documents related to those complaints filed by or against any administrator, professor, or student of the four statutory colleges. The statutory colleges denied the request, and Stoll filed a lawsuit to compel production. The trial court ruled that the statutory colleges were not state agencies subject to FOIL. Stoll appealed, and the appellate court reversed the trial court’s decision, finding that the statutory colleges were subject to FOIL because they were operated on behalf of SUNY, a state agency. The statutory colleges then appealed.
Rule of Law
Holding and Reasoning (Kaye, C.J.)
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