## Facts

- The New York City Transit Authority (NYCTA), a public employer, and the Transport Workers Union of America (TWU) were parties to a collective bargaining agreement covering NYCTA transit employees.
- TWU members engaged in a work stoppage/strike.
- New York’s Taylor Law prohibits public-employee strikes and authorizes sanctions against a public employee organization that “causes, instigates, encourages, or condones” a strike, including fines and loss of dues checkoff.
- After the strike, NYCTA sought statutory determinations and penalties against TWU, including forfeiture of dues checkoff and related relief.
- Lower proceedings addressed the permissible scope and duration of the requested sanctions and their relationship to the collective bargaining agreement.

## Issues

1. Whether Civil Service Law § 210 provides an exclusive set of penalties for a public employee organization’s unlawful strike activity.
2. Whether § 210 authorizes permanent, indefinite, or otherwise expanded forfeiture of dues checkoff beyond the statute’s terms.
3. Whether a public employer and union may modify, extend, or waive the statute’s strike-penalty scheme through a collective bargaining agreement.
4. Whether courts or administrative bodies have authority to impose or structure strike penalties beyond those specified in § 210.

## Decision

- The Court of Appeals held that the Taylor Law prescribes the authorized penalties for a union’s unlawful strike activity and that adjudicators must apply the statute as written.
- The Court recognized dues checkoff forfeiture as a statutory penalty, but held it is limited by the conditions and duration set by § 210 and cannot be enlarged by judicial construction or employer request.
- The Court held that the statutory strike-penalty scheme cannot be altered by collective bargaining agreement to impose different or additional consequences.
- The Court rejected attempts to impose sanctions exceeding the statute’s framework, leaving any expansion of penalties to the Legislature.

## Legal Principles

- Penalties for unlawful public-sector strikes by employee organizations are governed by the Taylor Law and are limited to those the statute authorizes.
- Dues checkoff is a statutory mechanism; its forfeiture and restoration are controlled by statute rather than by collective bargaining terms.
- Public employers, unions, courts, and administrative bodies lack authority to create additional strike penalties or extend statutory forfeitures beyond the statutory scheme.
- Contractual provisions cannot supersede or reconfigure legislatively prescribed remedies implementing public policy in public-sector labor relations.

## Conclusion

The Court of Appeals held that Taylor Law strike sanctions, including dues checkoff forfeiture, are statutory and exclusive; neither the parties nor adjudicators may expand or restructure those penalties beyond Civil Service Law § 210’s terms.


N.Y.C. Transit Auth. v. Transp. Workers Union of Am., 14 N.Y.3d 119 (N.Y. 2010)