N.Y. Laws » CHAPTER General Municipal / ARTICLE Conflicts of Interest of Municipal Officers and Employees
New York Consolidated Laws

N.Y. General Municipal Law § 809 (2026)

Disclosure in certain applications

✓ text as retrieved May 2026 (this copy records no edition or section history)
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§ 809. Disclosure in certain applications. 1. Every application,
petition or request submitted for a variance, amendment, change of
zoning, approval of a plat, exemption from a plat or official map,
license or permit, pursuant to the provisions of any ordinance, local
law, rule or regulation constituting the zoning and planning regulations
of a municipality shall state the name, residence and the nature and
extent of the interest of any state officer or any officer or employee
of such municipality or of a municipality of which such municipality is
a part, in the person, partnership or association making such
application, petition or request (hereinafter called the applicant) to
the extent known to such applicant.
  2. For the purpose of this section an officer or employee shall be
deemed to have an interest in the applicant when he, his spouse, or
their brothers, sisters, parents, children, grandchildren, or the spouse
of any of them
  (a) is the applicant, or
  (b) is an officer, director, partner or employee of the applicant, or
  (c) legally or beneficially owns or controls stock of a corporate
applicant or is a member of a partnership or association applicant, or
  (d) is a party to an agreement with such an applicant, express or
implied, whereby he may receive any payment or other benefit, whether or
not for services rendered, dependent or contingent upon the favorable
approval of such application, petition or request.
  3. In the county of Nassau the provisions of subdivisions one and two
of this section shall also apply to a party officer.  "Party officer"
shall mean any person holding any position or office, whether by
election, appointment or otherwise, in any party as defined by
subdivision four of section two of the election law.
  4. Ownership of less than five per cent of the stock of a corporation
whose stock is listed on the New York or American Stock Exchanges shall
not constitute an interest for the purposes of this section.
  5. A person who knowingly and intentionally violates this section
shall be guilty of a misdemeanor.
Notes of Decisions
Cited in 9 cases, 1985–2012 · leading case: Zagoreos v. Conklin, 109 A.D.2d 281 (N.Y. App. Div. 2d Dep't 1985).
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Zagoreos v. Conklin, 109 A.D.2d 281 (N.Y. App. Div. 2d Dep't 1985). “Nonetheless, O & R itself appears to have violated General Municipal Law § 809, which, inter alia, requires that every application for a variance list the name of any municipal officer *287 or employee who is also an employee of the applicant.”
Haberman v. Zoning Bd. of Appeals of City of Long Beach, 94 A.D.3d 997 (N.Y. App. Div. 2d Dep't 2012). “If Morelli was, as alleged, a tenant of Xander and, therefore, had a personal interest in the fate of the building permit to the extent that he would benefit from its revocation, the second cause of action sufficiently alleged that he should have disclosed this interest (see…”
Rosenfeld v. Zoning Bd. of Appeals of the Town of Ramapo, 6 A.D.3d 450 (N.Y. App. Div. 2d Dep't 2004). · cites it 2× “Contrary to the petitioners’ contention, the determination of the Zoning Board dated January 17, 2002, did not have to be annulled based on an alleged conflict of interest between the chairman of the Zoning Board and the respondent Congregation Mesifta Ohel Torah (hereinafter…”
Ahearn v. Zoning Bd. of Appeals of Shawangunk, 158 A.D.2d 801 (N.Y. App. Div. 3d Dep't 1990). “Petitioner concedes that there has been no direct conflict of interest of the type forbidden by General Municipal Law § 809. Rather, he claims that he has submitted evidence which establishes, at a minimum, the need for an adversarial hearing to unearth the "silent and…”
Friends of Hammondsport v. Vill. of Hammondsport Plan. Bd., 11 A.D.3d 1021 (N.Y. App. Div. 4th Dep't 2004). “Petitioner’s further contention that the Chairman of the Planning Board had an impermissible conflict of interest is without merit (see Matter of DePaolo v Town of Ithaca, 258 AD2d 68, 72 [1999], lv denied 94 NY2d 751 [1999]; see generally General Municipal Law § 809 [2]).…”
Heustis v. Town of Ticonderoga Plan. Bd., 11 A.D.3d 868 (N.Y. App. Div. 3d Dep't 2004). “General Municipal Law § 809 (2) provides as follows: “[A]n officer or employee shall be deemed to have an interest in the applicant when he, his spouse, or their brothers, sisters, parents, children, grandchildren, or the spouse of any of them .”
Schupak v. Zoning Bd. of Appeals of the Town of Marbletown, 31 A.D.3d 1018 (N.Y. App. Div. 3d Dep't 2006). “In our view, no conflict of interest requiring her recusal existed (see General Municipal Law § 809 [2]; Matter of Parker v Town of Gardiner Planning Bd.”
Lexjac, LLC v. Beckerman, 72 A.D.3d 748 (N.Y. App. Div. 2d Dep't 2010). “The decision of the federal court makes it clear that its factual determinations that the October 2005 resolution fell within General Municipal Law § 809 and not General Municipal Law § 801, and that any conflict of interest was cured by Entel’s recusal from the vote on it, was…”
Hyde Park Fire & Water Dist. v. Van Wagner's Bard Builders, Inc., 147 Misc. 2d 25 (N.Y. Sup. Ct. 1990). · cites it 2× “The third and fourth and fifth causes of action allege his and Bard’s violation of General Municipal Law § 809 in failing to disclose Lynch’s interest in the applications which he made on Bard’s behalf.”
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