## Facts

- A historic 10-acre property known as Sagtikos Manor in West Bay Shore was owned by Robert David Lion Gardiner, who allowed a local historical society to give tours and maintain the property beginning in the 1960s.
- In 1985, Gardiner created a charitable foundation and conveyed Sagtikos Manor to it; the foundation’s stated purposes broadly included public education about local history and support for historical societies, without naming specific beneficiaries.
- In 2002, the foundation sold Sagtikos Manor to Suffolk County; the historical society later entered an agreement with the county to maintain and preserve the Manor.
- Gardiner died in 2004. His will provided that his residuary estate would be held in trust for his widow for life, then distributed to the foundation; after the widow’s death in 2011, the trust assets were approximately $81 million.
- The historical society demanded information and an accounting from the foundation regarding the remainder; the foundation refused, asserting the society was not a named beneficiary.
- The historical society sued the foundation and its trustees seeking declaratory and injunctive relief about the foundation’s charitable purposes and beneficiaries, an accounting, trustee removal/appointments, and monetary relief tied to the trust remainder.
- The trial court denied the foundation defendants’ CPLR 3211(a) motion to dismiss; the foundation defendants appealed.

## Issues

1. Whether a non-named, potential beneficiary of a charitable foundation has standing to sue for declaratory, injunctive, and supervisory relief concerning the foundation’s charitable purposes and administration, including an accounting and trustee removal.
2. Whether the “special interest” exception permits a private plaintiff to enforce or supervise a charitable corporation or charitable trust in these circumstances.

## Decision

- The appellate court reversed the order insofar as appealed from.
- The court granted the foundation defendants’ CPLR 3211(a) motion and dismissed the complaint as against the foundation and its trustees.
- The court held the historical society lacked standing because enforcement and supervision of charitable entities are primarily reserved to the Attorney General, and the historical society did not qualify for the special-interest exception.

## Legal Principles

- In New York, enforcement of the purposes of charitable corporations and restraint of misuse of charitable funds or property are ordinarily matters for the Attorney General, not private litigants.
- A private plaintiff may obtain standing only under a narrow “special interest” exception requiring an interest distinct from that of the general public or other potential beneficiaries, typically membership in a small, well-defined class of intended beneficiaries.
- A plaintiff is not granted special-interest standing merely because it has a long relationship with property associated with a charity or because the charity’s purposes are broadly consistent with the plaintiff’s mission, where the plaintiff is not an expressly identified beneficiary.

## Conclusion

The court dismissed the historical society’s claims against the foundation and its trustees because the society was not a named or specially situated beneficiary and therefore lacked standing to seek judicial direction, supervision, or enforcement of the foundation’s charitable purposes; such actions are generally reserved to the Attorney General absent a narrow special-interest showing.


Sagtikos Manor Historical Soc'y, Inc. v. Robert David Lion Gardiner Found., Inc., 127 A.D.3d 1055 (N.Y. App. Div. 2d Dep't 2015)