In Matter of Town of Wallkill v. Civil Serv. Empty. Ass'n, Inc. (Local 1000, AFSCME, AFL-CIO), 19 N.Y.3d 1066, 979 N.E.2d 1147, 955 N.Y.S.2d 821 (2012), the Court of Appeals held that police discipline may not be the subject of collective bargaining under the Taylor Law when the Legislature has expressly committed disciplinary authority over a police department to local officials, and concluded that the Town properly exercised its authority to adopt a local law, pursuant to Town Law § 155, setting forth disciplinary procedures for police officers different than those outlined in their collective bargaining agreement.

The Court reasoned that since "Town Law § 155, a general law enacted prior to Civil Service Law §§ 75 and 76, commits to the Town the power and authority to adopt and make rules and regulations for the examination, hearing, investigation and determination of charges, made or preferred against any member or members of such police department,' . . . the subject of police discipline resides with the Town Board and is a prohibited subject of collective bargaining .. (19 N.Y.3d 1066, 1069, 979 N.E.2d 1147, 955 N.Y.S.2d 821).