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August 29, 2023

Seeking a court order in the nature of mandamus to compel a public officer or agency to perform a specified act

Among the several ancient writs which haves survived through the eons is the Writ of Mandamus.* Mandamus is sought in an effort to compel a governmental entity or officer to perform a ministerial duty.

In contrast, the Writ cannot be used to compel an act that involve[s] an exercise of judgment or discretion on the part of the public officer or entity. Citing Matter of Mensch v Planning Bd. of the Vil. of Warwick, 189 AD3d 1245, the Appellate Division explained that a discretionary act involves the exercise of reasoned judgment which could typically produce different acceptable results whereas "a ministerial act envisions direct adherence to a governing rule or standard with a compulsory result".

In this action the Appellate Division held that the Petitioners seeking a court order in the nature of mandamus "failed to establish that there existed a clear legal right to the relief sought." Rather, opined the court, Petitioners "sought to compel conduct involving the application of the discretion and judgment of the [Employer]."

Accordingly, the Appellate Division concluded that the remedy of mandamus was not available to the Petitioners.

* Other surviving ancient common law writs include the Writ of Prohibition, issued by a higher tribunal to a lower tribunal to "prohibit" the adjudication of a matter then pending before the lower tribunal on the grounds that the lower tribunal "lacked jurisdiction"; the Writ of Injunction - a judicial order preventing a public official from performing an act; the Writ of Certiorari, compelling a lower court to send its record of a case to the higher tribunal for review by the higher tribunal; and the Writ of “Quo Warranto” [by what authority].

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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