Donohue v. Mangano, 886 F. Supp. 2d 126

Plaintiffs are public employee unions (Donohue, Jaronczyk, Carver) representing Nassau County employees; consolidated federal actions challenge LL 8-2012 (LL 315-12) as violative of the Contracts Clause and related state laws.
LL 315-12 authorized the County Executive to take actions to create $40 million in savings to fund tax certiorari judgments, including furloughs, wage freezes, contract modifications, and other measures.
County Executive Mangano proposed LL 315-12 in April 2012; Legislature approved it in May 2012; Mangano signed it into law on June 18, 2012.
Plaintiffs sought injunctive relief, alleging immediate contract impairment; the Court held hearings May 22, 2012 and June 20, 2012 and consolidated the cases.
Defendants moved for a stay but the Court denied, and the Court later addressed mootness, abstention, supplemental jurisdiction, and the merits of the Contracts Clause claim.
The Court ultimately granted a preliminary injunction enjoining execution of LL 315-12 § 2(A) actions pending final judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether LL 315-12 substantially impairs contracts.	Plaintiffs contend law unconstitutionally impairs negotiated CBAs.	Defendants argue law is a temporary measure to address a fiscal crisis and may be reasonable.	Yes; substantial impairment shown and not reasonable/necessary at this stage.
Whether the case is moot pending funding	N/A	County may fund judgments via reserves; mootness argued by amicus.	Not moot at this stage; residual effects and potential certifications prevent mootness.
Whether Younger abstention applies given parallel state proceedings	Younger should apply to bar federal relief due to ongoing state action.	State proceeding is parallel and potentially coercive; Younger may bar review.	Younger abstention does not apply; the state action here is remedial, not coercive, and not controlling.
Whether the court should decline supplemental jurisdiction over state-law claims	N/A	State-law claims are novel/complex and parallel state action exists.	Declined to exercise supplemental jurisdiction over state-law claims.
Whether a preliminary injunction should issue to block LL 315-12 § 2(A) actions	Imminent contract impairment and irreparable harm threaten bargaining and rights.	Action would be temporary and may be necessary; balance of equities uncertain.	Granted; injunction issued against taking action under LL 315-12 § 2(A) pending final judgment.

Buffalo Teachers Fed. v. Tobe, 464 F.3d 362 (2d Cir. 2006) (contracts clause analysis; substantial impairment and public purpose)
Energy Reserves Group, Inc. v. Kansas Power & Light Co., 459 U.S. 400 (Sup. Ct. 1983) (impairment must be reasonable and necessary to serve public purpose)
United States Trust Co. v. New Jersey, 431 U.S. 1 (Sup. Ct. 1977) (reasonableness/necessity test for contract impairments; self-interest cautions scrutiny)
Blaisdell, 290 U.S. 398 (Sup. Ct. 1934) (emergency public needs may justify impairments; historical contract clause standard)
Spargo v. N.Y. State Comm’n on Judicial Conduct, 351 F.3d 65 (2d Cir. 2003) (Younger abstention framework and remnant discussions in this context)
Juidice v. Vail, 430 U.S. 327 (Sup. Ct. 1977) (adequacy of state proceedings to address federal claims; avenue for federal relief)
Hawaii Hous. Auth. v. Midkiff, 467 U.S. 229 (Sup. Ct. 1984) (Younger abstention and state interests in a broad sense)
United Fence & Guard Rail Corp. v. Cuomo, 878 F.2d 588 (2d Cir. 1989) (Younger abstention considerations in state-state parallel actions)