World Trade Ctr. Lower Manhattan Disaster Site Litig. Stanislaw Faltynowicz v. Battery Park City Auth., 892 F.3d 108

Eighteen workers sued Battery Park City Authority (BPCA), a New York public benefit corporation, alleging respiratory injuries from post‑9/11 cleanup work on BPCA‑owned sites.
Plaintiffs’ original suits were dismissed for failing to comply with New York’s notice‑of‑claim requirement; the Legislature enacted “Jimmy Nolan’s Law” to revive for one year otherwise time‑barred claims by post‑9/11 workers.
Plaintiffs refiled under the revival statute; BPCA moved for summary judgment arguing Jimmy Nolan’s Law was unconstitutional under the New York State Constitution.
The district court granted summary judgment for BPCA, finding the revival statute unconstitutional; plaintiffs appealed to the Second Circuit.
The Second Circuit certified two questions to the New York Court of Appeals about (1) whether a public benefit corporation must be treated like the State before applying the capacity‑to‑sue rule and (2) the standard governing substantive due process challenges to claim‑revival statutes.
The New York Court of Appeals answered: public benefit corporations are treated like other state entities for capacity purposes (narrow exceptions only), and a claim‑revival statute passes due process if it is a reasonable legislative response to remedy an injustice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether BPCA has capacity to challenge Jimmy Nolan’s Law under NY capacity‑to‑sue doctrine	Plaintiffs: BPCA, as a public corporation, cannot invoke the capacity rule to bar constitutional challenges; or if BPCA can, its challenge fails on the merits	BPCA: As a state entity BPCA can still sue under narrow exceptions (proprietary‑interest), here BPCA’s potential exposure to judgments implicates proprietary interests	Held: BPCA is a state entity and lacks capacity to challenge the statute because it does not fall within the narrow proprietary‑interest exception; BPCA’s challenge rejected and court vacated district judgment and remanded (merits not reached)
Standard for reviewing a due process challenge to a claim‑revival statute	Plaintiffs: Revival statute must meet State Constitution standards (argued under less deferential or more deferential tests)	BPCA: (if reached) likely argued statute fails due process under applicable standard	Held (NYCOA): A claim‑revival statute satisfies New York due process if it is a reasonable response enacted to remedy an injustice (court of appeals adopted reasonableness/remedy‑of‑injustice standard); Second Circuit did not decide merits here because BPCA lacked capacity

Matter of World Trade Ctr. Lower Manhattan Disaster Site Litig., 30 N.Y.3d 377 (N.Y. 2017) (NY Court of Appeals: public benefit corporations are treated like State entities for capacity; claim‑revival statutes pass due process if reasonable to remedy injustice)
City of New York v. State of New York, 86 N.Y.2d 286 (N.Y. 1995) (capacity‑to‑sue general rule: municipalities/state entities lack capacity to challenge state legislation)
County of Rensselaer v. Regan, 80 N.Y.2d 988 (N.Y. 1992) (proprietary‑interest exception where statute directly diverts specific funds to the State)
Clark‑Fitzpatrick, Inc. v. Long Island R.R. Co., 516 N.E.2d 190 (N.Y. 1987) (analysis on when an instrumentality should be treated like the State)
John Grace & Co. v. State Univ. Constr. Fund, 375 N.E.2d 377 (N.Y. 1978) (particularized inquiry into nature of instrumentality for capacity questions)
Gallewski v. H. Hentz & Co., 93 N.E.2d 620 (N.Y. 1950) (articulated a “serious injustice” standard historically applied in due process analysis)
Robinson v. Robins Dry Dock & Repair Co., 144 N.E. 579 (N.Y. 1924) (articulated a more deferential “reasonableness” standard in due process contexts)