Glen Oaks Vil. Owners, Inc. v. City of New York

Summary

The Court of Appeals held that the Climate Leadership and Community Protection Act does not expressly or impliedly preempt the field of regulating greenhouse gas emissions, so New York City's Local Law No. 97 remains valid against the field-preemption challenge. The court concluded that the Act's statewide goals, savings clause, and preservation of existing authority reflect an intent to permit complementary local regulation rather than require uniformity. Because the action sought declaratory relief, the proper result was a declaration in defendants' favor rather than dismissal of the preemption cause of action.