In Community Bd. 7 v. Schaffer, 84 NY2d 148 (1994), a community board sued to obtain the records of the Department of City Planning under the New York State Freedom of Information Law [FOIL]. The community board argued that the records were necessary for the board to formulate its recommendation under the City Charter's Uniform Land Use Procedure (ULURP). New York City Charter, Chapter 8, Section 197-c. The Court of Appeals reiterated the fundamental principle that "a creature of the state... [e.g., a community board] has no power other than that given to it by the Legislature, either explicitly or by necessary implication". (Community Board 7 v. Schaffer, Id. at 156.) In Community Board 7 v. Schaffer, supra, the Court noted that: "Petitioner's lack of capacity to bring suit may readily be inferred from the terms and history of its own enabling legislation, as well as from its limited role in the land use planning process." (Community Board 7 v. Schaffer, Id. at 157.)