Clair v. City of New York

The New York Appellate Division upheld regulations adopted by the New York City Taxi and Limousine Commission (TLC) intended to make half of the City’s taxi fleet wheelchair-accessible. The petitioners—all of whom were taxicab medallion owners—argued unsuccessfully that the accessibility regulations, which imposed requirements to purchase wheelchair-accessible vehicles, were in irreconcilable conflict with a New York City law enacted in 2005 requiring TLC to approve one more hybrid electric vehicle models that “shall be eligible” for immediate use. The petitioners cited the City Council's legislative findings that use of alternative fuel vehicles, especially taxis, was important to the City's goals of improving air quality and conserving fuel. The legislative findings also cited the burning of fossil fuels as a major source of greenhouse gas emissions contributing to global warming. The petitioners contended that the accessibility regulations were in conflict with the hybrid law because no hybrid electric vehicle model met accessibility requirements. The Appellate Division said that TLC had fulfilled the statutory hybrid electric mandate in 2014 when it approved certain hybrid electric vehicles for use as taxicabs, making them immediately eligible for use. The court said that the statute did not require purchase or lease of a hybrid electric vehicle every time a vehicle was to be purchased by a medallion owner. The court also noted that a law enacted by the City in 2006 required TLC to develop a plan to increase the number of both clean air and accessible vehicles, demonstrating that the sole focus was not on increased deployment of hybrid electric vehicles. The court also found that TLC had not acted arbitrarily and capriciously in adopting and implementing the accessibility regulations because the rules “facilitate the goal of increasing the number of accessible taxicab vehicles available for passengers with mobility issues while realistically furthering the equally important goal of increasing the number of clean air cabs available in New York City.”

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