Smithson v. Ilion Housing Authority
Opinion of the Court
unanimously affirmed, without costs. Memorandum: In an executive session, the Board of Commissioners of respondent Authority (Board) voted by secret ballot to dismiss petitioner from his position as Executive Director/Secretary of the Authority. Petitioner commenced a CPLR article 78 proceeding to annul that determination and for reinstatement, contending that he was terminated for a constitutionally impermissible reason and that the meeting was conducted in violation of the Open Meetings Law. (Public Officers Law § 100 et seq.)
Petitioner specifically claimed that he was dismissed because he had commenced a libel action against one of the Board members and because petitioner had attempted to compel another Board member to repay part of an advance for travel expenses for the reason that such expenses had not been incurred. He contended that he was punished for exercising his constitutional rights of free speech and access to the courts. Supreme Court rejected these claims, finding that in commencing the libel action petitioner was not seeking to secure a protected property interest and that an at-will employee has no cause of action for retaliatory discharge because he attempted to "blow the whistle” on allegedly improper conduct (134 Mise 2d 400, 402-403).
The constitutional right to access to the courts is protected as a liberty and property interest under the Fourteenth Amendment (see, Mt. Healthy City Bd. of Educ. v Doyle, 429 US 274, supra; Northern Pa. Legal Servs. v County of Lackawanna, 513 F Supp 678), and First Amendment freedoms are recognized as a liberty interest (Mt. Healthy City Bd. of Educ. v Doyle, 429 US 274, 283, supra). A lawsuit may itself be a form of expression (see, National Assn. v Button, 371 US 415, where the action was instituted to express a political belief) or an action may be commenced to enforce or protect an underlying constitutional right, such as freedom of association (In re Primus, 436 US 412) or the right to petition government (Harrison v Springdale Water & Sewer Commn., 780 F2d 1422; McCoy v Goldin, 598 F Supp 310). The commencement of petitioner’s libel action against a Board member does not encompass any of these liberty interests. The record reveals no more than a private action against a private individual for an alleged defamatory statement. There is no claim that the statement was made in the defendant’s capacity as a Board member or with the Board’s authority or knowledge and thus, the lawsuit is not a petition to the government for redress of grievances. Petitioner’s libel action is not by itself protected speech nor does it purport to protect or enforce some other
The use of a secret ballot for voting purposes was improper. When action is taken by a formal vote at open or executive sessions, the Freedom of Information Law and Open Meetings Law both require open voting and a record of the manner in which each member voted (Public Officers Law § 87 [3] [a]; § 106 [1], [2]). We find, however, that this error does not warrant annulment of the Board’s determination and reinstatement of petitioner as a sanction for the statutory violation (see, Matter of Sauna v Lindenhurst Bd. of Educ., 85 AD2d 157, affd 58 NY2d 626; Matter of Britt v County of Niagara, 82 AD2d 65). Since the Board clearly had the authority to determine the employment issue at executive session (Public Officers Law § 105 [1] [f]), petitioner’s claim that the Board would have voted differently had they done so in open session is of no consequence. (Appeal from judgment of Supreme Court, Herkimer County, Tenney, J.—art 78.) Present— Dillon, P. J., Callahan, Boomer, Balio and Davis, JJ.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.