Justia Non-Profit Corporations Opinion Summaries

Wildlife Preserves, Inc., a non-profit conservation organization, conveyed land comprising most of the Sunken Forest Preserve—a rare maritime holly forest on Fire Island, New York—to the United States government in the 1950s and 1960s. The deeds included restrictions requiring the land to be maintained in its natural state and operated as a preserve for wildlife, prohibiting activities such as hunting, trapping, and any actions that might adversely affect the environment or animal population. Over time, the National Park Service managed the property as part of the Fire Island National Seashore. In response to a significant increase in white-tailed deer, which threatened local flora and fauna, the government adopted a 2016 management plan involving exclusion fencing and deer population reduction within the Sunken Forest.Wildlife Preserves filed suit in the United States District Court for the Eastern District of New York, arguing that the 2016 plan violated the deed restrictions and triggered a reversionary interest in the property under New York law. The district court denied Wildlife Preserves’ motion for summary judgment and granted the government’s cross-motion, holding that the suit was time-barred under the Quiet Title Act’s statute of limitations due to a prior fence constructed in 1967.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision de novo. The Second Circuit affirmed the district court’s judgment, but on alternative grounds. The court held that, under New York law, the 2016 management plan did not violate the deed restrictions. The court reasoned that the plan’s fencing and deer reduction measures were consistent with the requirement to maintain the land in its natural state and operate it as a wildlife preserve, and that the restrictions must be strictly construed against the grantor. Thus, summary judgment for the government was affirmed. View "Wildlife Preserves v. Romero" on Justia Law

MMC and the government agreed that MMC is entitled to an overpayment refund and further agree on the amount of that overpayment, but disagree on the interest rate to be applied. MMC argues that, despite being organized as a corporation under New York law, it should receive the benefit of the higher interest rate applicable to non‐corporations, because it is a nonprofit corporation and the word “corporation” in I.R.C. 6621(a)(1) should be construed to refer only to for‐profit corporations. The court held that I.R.C. 6621(a)(1)'s lower interest rate applies equally to for-profit corporations and nonprofit corporations such as MMC.  Accordingly, the court affirmed the judgment of the district court. View "Maimonides Medical Center v. United States" on Justia Law