McGrath v. Suffolk County

Issue

1. Whether Suffolk County’s imposition of administrative fees on red light camera violations exceeding the state statutory cap of $50 per violation (or $75 with a late fee) is preempted by state law and therefore invalid or illegal?

Holding

1. Yes, Suffolk County’s imposition of additional fees for red light camera violations is preempted by state law. Vehicle and Traffic Law § 1111–b expressly limits liability to $50 per violation, with an optional $25 late fee, and prohibits local governments from exceeding these limits. The Court of Appeals affirmed the lower court’s holding that the local fees extending costs beyond the $50 (or $75 with late fees) state statutory limit was unconstitutional, preempted, void, or otherwise illegal.

Facts

• The plaintiff, Robert McGrath Jr., filed a class action against Suffolk County and its Traffic and Parking Violations Agency, alleging that the County unlawfully imposed fees beyond those authorized by state law for red light camera violations.
• Suffolk County adopted Local Law No. 20-2009 to implement a red light camera program. The local ordinance included charging an administrative fee of $30 per violation in addition to state statutory penalties.
• The plaintiff argued that these additional fees were illegal under a plain reading of the state statute which sets a cap of $50 per violation and a $25 late fee.

Court’s Reasoning

1. Statutory Limits and Legislative Intent:
   • The plain language of Vehicle and Traffic Law § 1111–b explicitly caps monetary penalties for red light camera violations at $50 per violation, with an optional $25 late fee. Suffolk County’s administrative fees conflict with this statutory cap.
   • Legislative history of the state statute shows legislators debated and explicitly acknowledged an intent that local administration fees in excess of the statutory penalties are not permissible. 
2. Preemption Doctrine:
   • The New York Constitution allows counties home rule powers but limits their authority when local laws conflict with state laws. Suffolk County’s additional fees violated this principle by conflicting with state law limits.

Outcome

The court held that Suffolk County’s additional fees were invalid and preempted by state law and were unconstitutional. The court enjoined the County from collecting fees exceeding the statutory cap of $50 per violation (or $75 with a late fee).

On the same day the New York Court of Appeals decided this case, it handed down an opinion in Guthart v. Nassau Cnty., 2024 NY Slip Op 05960 (N.Y. App. Div. Nov. 27, 2024) addressing similar claims in Nassau County, NY. There too, the Court found that additional local fees exceeding the state statutory cap for red light camera violations was unconstitutional, preempted, void, or otherwise illegal.

You can read the full court opinion here.

McGrath v. Suffolk County

McGrath v. Suffolk Cnty., 2024 N.Y. Slip Op. 05973 (N.Y. App. Div. Nov. 27, 2024)