Matter of Stoll v. New York State Coll. of Veterinary Medicine at Cornell Univ

In Matter of Stoll v. New York State Coll. of Veterinary Medicine at Cornell Univ. (94 N.Y.2d 162, 723 N.E.2d 65, 701 N.Y.S.2d 316 [1999]), the Court addressed whether Cornell University, as administrator and manager of the statutory colleges, was a state agency subject to the Freedom of Information Law (FOIL) (Public Officers Law, article 6). The Court began with the proposition that Cornell University is a private educational institution not ordinarily subject to FOIL. That said, the Court recognized that there were "public aspects" of Cornell's role as steward of the statutory colleges implicating the open government policies underlying FOIL. Noting that the Legislature had vested Cornell University with substantial private discretion over the colleges that placed many of its actions beyond state control, we determined that there remained "public aspects" of Cornell's management function that could, in some circumstances, render Cornell the equivalent of a state agency for purposes of FOIL. The Court therefore reviewed the nature of the FOIL request, concluding that where documents requested relate to subject matter over which Cornell exercises statutory authority or control, Cornell is operating in its private capacity and is not mandated to disclose the requested materials. Thus, in Stoll, the Court held that Cornell was not required to comply with a FOIL request seeking complaints filed under the Cornell University Campus Code of Conduct because the University retained authority, by statute, over disciplinary matters at the statutory colleges. Put another way, because Cornell is responsible for discipline at the statutory colleges, the Court concluded that it was not a state agency subject to FOIL.