Sullivan v. Nassau County Interim Finance Authority, No. 18-1587 (2d Cir. 2020)Annotate this Case
Unions representing Nassau County employees filed suit against NIFA after it instituted a year-long wage freeze for all county employees. The unions alleged that the wage freeze, because it was a legislative act that was not reasonable and necessary to achieve NIFA's purported goal of fiscal soundness, violated the Contracts Clause of the United States Constitution. The district court held that NIFA's implementation of the wage freeze was administrative, rather than legislative, and granted summary judgment for defendants.
The Second Circuit held that NIFA's wage freeze did not violate the Contracts Clause and affirmed the district court's grant of summary judgment. The court assumed without deciding that NIFA's imposition of the wage freeze was legislative in nature, and held that the wage freeze was a reasonable and necessary means to achieve NIFA's asserted end of ensuring the continued fiscal health of the county.