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August 27, 2024

Submission of an incomplete record to the Appellate Division results in the court dismissing the appeal

In a proceeding pursuant to CPLR Article 78 to review a determination dated terminating the petitioner's [Member] membership in the respondent Fire Department [Department], the Member appealed from a judgment of the Supreme Court denying Member's Article 78 petition and dismissing the proceeding.

Member challengd the Supreme Court's decision but the Appellate Division dismissed Member's appeal to it, with costs.

Citing Klein v Richs Towing, 213 AD3d 920, the Appellate Division noted "CPLR 5526 requires that a record on appeal contain the papers and exhibits upon which the order appealed from was founded".

Here, said the Appellate Division, the record does not contain the member's underlying reply affirmation or the audio recording of the meeting at which her membership was terminated, both of which were considered by Supreme Court in rendering its determination with respect to Member's petition. 

Although Member's argument before the Appellate Division was that the Supreme Court should have annulled Department's termination of her membership, the Appellate Division opined that it is "the obligation of the appellant to assemble a proper record on appeal", explaining "the record is inadequate to allow it to render an informed decision" and thus Member's appeal must be dismissed.

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


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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.
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