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May 28, 2019

Challenging an unsatisfactory annual performance rating


An educator [Petitioner] challenged his unsatisfactory annual performance review rating but Supreme Court granted the appointing authority's cross-motion to dismiss the proceeding Petitioner brought pursuant to CPLR Article 78. The Appellate Division unanimously affirmed the lower court's action.

The Appellate Division said:

1. The Petitioner has failed to show that the U-rating was arbitrary and capricious, or made in bad faith;

2. The record established that there was a rational basis for the determination to uphold petitioner's U-rating, which was based on insubordination and unprofessional conduct during the relevant school year; and

3. The Petitioner failed to demonstrate that there were procedural deficiencies in the performance review process resulting in the U-rating that undermined the integrity or fairness of the process.

The decision is posted on the Internet at:


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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