ARTIFICIAL INTELLIGENCE [AI] IS NOT USED, IN WHOLE OR IN PART, IN PREPARING NYPPL SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS

June 21, 2019

To prevail in an action challenging an unsatisfactory performance rating the individual must show that the rating was arbitrary and capricious or made in bad faith


In this CPLR Article 78 action the Petitioner challenged the "Unsatisfactory" annual performance rating she had received for the 2013-2014 academic year and [2] the calculation of her pension. Supreme Court dismissed both of these claims advanced by the Petitioner and, in addition, rejected her contention that she had suffered a "discontinuance of employment." The Appellate Division unanimously affirmed the Supreme Court's rulings.

Citing Murname v Department of Education of the City of New York, 82 AD3d 576, the Appellate Division explained that Petitioner failed to show that the U-rating she had been given for the academic year by the New York City Board of Education [Respondent] was arbitrary and capricious or made in bad faith. Rather, said the court, Respondent's determination to uphold the U-rating has a rational basis in the record, which shows repeated instances of pedagogical deficiencies during the 2013-2014 school year, as well as a failure to improve.

With respect to Petitioner's appeal concerning the calculation of her pension , the court's decision indicates  that there were two obstacles to its consideration of her complaint: [1] the Respondent was not the proper party against which to bring her claims and [2] "[t]hese claims could not in any event be entertained, because [Petitioner] failed to exhaust her administrative remedies."

Addressing Petitioner's contention that she had been "discontinued from service", the court found that "there was no discontinuance of employment." Rather, said the Appellate Division, Petitioner had voluntarily resigned from her position.

The decision is posted on the Internet at:



CAUTION

Subsequent court and administrative rulings, or changes to laws, rules and regulations may have modified or clarified or vacated or reversed the decisions summarized here. Accordingly, these summaries should be Shepardized® or otherwise checked to make certain that the most recent information is being considered by the reader.
THE MATERIAL ON THIS WEBSITE IS FOR INFORMATION ONLY. AGAIN, CHANGES IN LAWS, RULES, REGULATIONS AND NEW COURT AND ADMINISTRATIVE DECISIONS MAY AFFECT THE ACCURACY OF THE INFORMATION PROVIDED IN THIS LAWBLOG. THE MATERIAL PRESENTED IS NOT LEGAL ADVICE AND THE USE OF ANY MATERIAL POSTED ON THIS WEBSITE, OR CORRESPONDENCE CONCERNING SUCH MATERIAL, DOES NOT CREATE AN ATTORNEY-CLIENT RELATIONSHIP.
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