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New York Urban League, Inc. v. State of New York
United States Court of Appeals for the Second Circuit
71 F.3d 1031 (1995)
The State of New York proposed a 20 percent rate increase for New York City’s subways and buses. The New York Urban League, Inc. (NYUL) (plaintiff) sued the state (defendant) under a U.S. Department of Transportation regulation, promulgated pursuant to the Civil Rights Act of 1964, that prohibited discrimination under any program that received federal funding. NYUL alleged that the state’s allocation of funding between the city’s subway and bus systems and the commuter-rail system was discriminatory. Specifically, NYUL claimed that users of the subway and bus systems paid a higher share of maintenance costs for that system than users of the commuter rail paid to maintain the commuter-rail system. This was discriminatory according to NYUL because most users of the subway and bus systems were minorities and most users of the commuter rail were White. NYUL sought an injunction prohibiting the rate increase. The United States District Court for the Southern District of New York granted NYUL a preliminary injunction. The court based its finding on what were known as farebox-recovery ratios. These ratios measured the portion of each system’s costs that were recovered through rider fares. The district court found that the proposed fare increase increased the farebox-recovery ratio of the subway and bus systems by 12.2 percent but only increased the farebox-recovery ratio of the commuter rails by under 3 percent. The state appealed, asserting that although its allocation of transportation funds resulted in the subway and bus systems subsidizing the commuter rail, users of those systems obtained benefits from such subsidization. Specifically, the state pointed to decreased traffic and pollution and increased usage of the subway and bus systems—and thus increased revenues—by commuter-rail riders who would otherwise drive into the city.
Rule of Law
Holding and Reasoning (Per curiam)
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