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October 02, 2023

Termination pursuant to Civil Service Law §71 held not the exclusive procedure to separate an employee who is absent due to a work-related injury

Supreme Court denied Plaintiff's petition seeking to vacate Plaintiff's termination from her position with the New York City Department of Consumer and Worker Protection [DCWP] pursuant to Civil Service Law §75. The Appellate Division unanimously affirmed the Supreme Court's decision.

DCWP had filed disciplinary charges against Petitioner and terminated her for  "incompetence" after finding her guilty of "excessive absenteeism" following a work-related injury. 

The Appellate Division, citing Wysocki v Town of Southold, 204 AD3d 811 and other decisions, said that Plaintiff's dismissal was not arbitrary and capricious or affected by an error of law, observing that the "Petitioner was continuously absent from work for over 295 days and provided no indication as to when or whether she could return to work."

Noting that Petitioner did not allege that her disability "has not permanently incapacitated her from the performance of her civil service duties" held that her contention that DCWP erred by using Civil Service Law §75 instead of §71 to discharge her is unavailing. The court explained that "neither the statute itself nor the relevant case law mandates the use of Civil Service Law §71 as the exclusive procedure to separate an employee who is absent due to injury."

Click HERE to access the Appellate Division's decision posted on the Internet.

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Disability Leave for New York public sector personnel.

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CAUTION

Subsequent court and administrative rulings, or changes to laws, rules and regulations may have modified or clarified or vacated or reversed the information and, or, decisions summarized in NYPPL. For example, New York State Department of Civil Service's Advisory Memorandum 24-08 reflects changes required as the result of certain amendments to §72 of the New York State Civil Service Law to take effect January 1, 2025 [See Chapter 306 of the Laws of 2024]. Advisory Memorandum 24-08 in PDF format is posted on the Internet at https://www.cs.ny.gov/ssd/pdf/AM24-08Combined.pdf. Accordingly, the information and case summaries should be Shepardized® or otherwise checked to make certain that the most recent information is being considered by the reader.
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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