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December 29, 2011

Stopping the hearing creates a problem

Stopping the hearing creates a problem
Swanteson v. City School District of the City of New York, 88 A.D.2d 907

A person serving as a hearing officer may be tempted to terminate or “shorten” a hearing because one or more of the participants becomes unruly or abusive.

A hearing officer did stop the hearing before the employee had an opportunity to make a “statement” specifically permitted by the controlling rules of procedure because of “personal vituperation and ... abrasive behavior, despite repeated warnings.”

The hearing officer then sustained the employee’s unsatisfactory service rating, which was later affirmed by the Chancellor of the Board of Education.

Swanteson sued, arguing that the Board had failed to follow its own procedures.

The Appellate Division agreed and reversing a lower Court, holding that the failure to provide Swanteson with the “Review Format” was an abuse of the chairperson’s discretionary powers to make necessary “adjustments” in the format and insure an “expeditious and non-repetitious presentation ... denied (Swanteson) a substantial right.”

The matter was then sent back to the District with instructions that Swanteson “be given the opportunity to exercise his right to make a presentation and statement on his own behalf as provided in the Review Format.”

The termination of a hearing because of “disruptive behavior” apparently will not be considered a reasonable and proper exercise of discretion.

CAUTION

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NYPPL Blogger Harvey Randall served as Principal Attorney, New York State Department of Civil Service; Director of Personnel, SUNY Central Administration; Director of Research, Governor’s Office of Employee Relations; and Staff Judge Advocate General, New York Guard. Consistent with the Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations, the material posted to this blog is presented with the understanding that neither the publisher nor NYPPL and, or, its staff and contributors are providing legal advice to the reader and in the event legal or other expert assistance is needed, the reader is urged to seek such advice from a knowledgeable professional.
New York Public Personnel Law. Email: publications@nycap.rr.com