What is the difference between a town and a fire protection district?

"New York", United States of America

The following excerpt is from Waite v. Town of Champion, 106 N.E.3d 1167, 31 N.Y.3d 586, 81 N.Y.S.3d 807 (N.Y. 2018):

1 In a fire protection district, "[n]o independent entity is created thereby; the town controls the district's operations [ ]" (Nelson v. Garcia, 152 A.D.2d 22, 24, 548 N.Y.S.2d 963 [4th Dept. 1989] ). By "contrast, where a town establishes a fire district, it creates a wholly independent political subdivision whose members, including its volunteer firemen, are employees of the district and not of the town" (id. at 2425, 548 N.Y.S.2d 963 )

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