On January 14, 2014, the Court of Appeals declined to review, without comment, the decision of the Appellate Division that the Metropolitan Commuter Transportation Mobility Tax Law, commonly known as the MTA Payroll Tax, was properly enacted and therefore constitutional. Mangano v. Silver, et al., Mo. No. 2013-1154 (N.Y. Jan. 14, 2014). The Appellate Division had reversed the trial court and rejected the argument that the statute, which imposes a payroll tax on employers and self-employed individuals to raise funds for the improvement of commuter transportation in the New York City area, had been invalidly enacted without a “home rule” message. Such a message is not required when a special law serves a “substantial state concern,” and the appeals court had found that improvement of commuter mass transit in the New York City area has already been held to be such a substantial state concern.