Two New York counties—Rockland and Orange [Plaintiffs]—sued the Triborough Bridge and Tunnel Authority and the Metropolitan Transportation Authority, [Defendants] alleging that New York City’s congestion-pricing program imposed an unauthorized tax, unconstitutionally restricted the right to travel, and violated the Due Process, Equal Protection, and Excessive Fines Clauses of New York State's and the U.S. Constitution. The district court granted Defendants’ motion to dismiss for failure to state a claim.
United States Court of Appeals for the Second Circuit summarized its decision in the instant appeal challenging the District Court's ruling in County of Rockland v. Triborough Bridge & Tunnel Authority, as follows:
New York City’s congestion-pricing program charges a toll for vehicles entering the Central Business District in Midtown and Lower Manhattan. Assuming without deciding that the toll is not a tax under New York law, the Second Circuit concluded that the District Court correctly dismissed causes of action, noting that Orange County failed to allege that congestion pricing violates the right to travel.
In the words of the Circuit Court, "The program does not create invidious distinctions among drivers or impose more than a minor restriction on the right to travel".
Accordingly, the Circuit Court, observing that it had reviewed the unresolved issues the District Court's ruling "only for reasonableness", opined that Orange County failed to allege that the challenged toll is an unreasonable user fee, noted that:
1. Plaintiffs failed to state Due Process or Equal Protection claims because the congestion-pricing program is rationally related to New York’s legitimate interests in raising funds for mass transit and reducing vehicular congestion; and
2. "Rockland County does not plausibly allege that the toll is an unconstitutionally excessive fine".
Accordingly, the Second Circuit affirmed "the judgments of the district court".
Click HERE to access the Circuit Court's ruling posted on the Internet.