Declining to pursue a grievance submitted by an individual in the relevant collective bargaining unit

In Flowers v District Council 37, 2025 NY Slip Opinion 02720, the Appellate Division, First Department, opined that an employee organization's decision not to pursue a grievance submitted by an individual in the collective bargaining unit it represents as the employee organization's "mere refusal ... to proceed with [the] grievance does not in itself establish a breach of the duty of fair representation".

The Appellate Division's decision is set out below.  

Flowers v District Council 37

2025 NY Slip Op 02720

Decided on May 06, 2025

Appellate Division, First Department

Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.

This opinion is uncorrected and subject to revision before publication in the Official Reports.

Decided and Entered: May 06, 2025
Before: Webber, J.P., Scarpulla, Mendez, Rodriguez, Pitt-Burke, JJ.

Index No. 161683/13|Appeal No. 4284|Case No. 2023-05339|

[*1]Swayne Flowers, Plaintiff-Appellant,

v

District Council 37, et al., Defendants-Respondents.

Law Offices of Sandra D. Parker, New York (Sandra D. Parker of counsel), for appellant.

Robin Roach, New York (Terry Buck of counsel), for District Council 37, AFSCME, AFL-CIO, respondent.

Muriel Goode-Trufant, Corporation Counsel, New York (Melanie T. West of counsel), for New York City Health + Hospitals Corporation, respondent.

Order, Supreme Court, New York County (Judy H. Kim, J.), entered September 26, 2023, which granted the motions of defendants District Council 37 AFSCME, AFL-CIO (DC 37) and New York City Health and Hospitals Corporation (H+H) for summary judgment dismissing the complaint, unanimously affirmed, without costs.

The court properly dismissed plaintiff's claims against DC 37, an unincorporated association, because plaintiff failed to plead and prove that the union's "entire membership authorized and later ratified [the union's] actions," as required by the Martin rule (Dowlah v American Arbitration Assn., 221 AD3d 426, 427 [1st Dept 2023], lv denied 41 NY3d 910 [2024]; see Palladino v CNY Centro, Inc., 23 NY3d 140, 146 [2014]; Martin v Curran, 303 NY 276, 280 [1951];General Associations Law § 13). Plaintiff failed to raise an issue of fact as to DC 37's unincorporated status, which was not a matter solely within the union's knowledge.

DC 37 did not waive its right to assert the Martin rule at summary judgment by failing to raise it as an affirmative defense. The Martin rule establishes "pleading and evidence requirements" for plaintiff to satisfy to "maintain[] [this] action" (Salemeh v Toussaint, 25 AD3d 411, 411 [1st Dept 2006]). DC 37's asserted defense that the "[c]omplaint fails to state a claim against [DC 37] upon which relief may be granted" encompassed DC 37's later argument that plaintiff failed to meet his burdens, including under the Martin rule (see Morton v Mulgrew, 144 AD3d 447, 448 [1st Dept 2016]; Salemeh, 25 AD3d at 411-412).

The court also properly dismissed plaintiff's breach of contract claim against his employer, H+H, because his employment was subject to a collective bargaining agreement (CBA) that contained a grievance procedure. "[O]nly when the union fails in its duty of fair representation can the employee go beyond the agreed procedure and litigate a contract issue directly against the employer" (Matter of Board of Educ., Commack Union Free School Dist. v Ambach, 70 NY2d 501, 508 [1987], cert denied sub nom. Margolin v Board of Educ., Commack Union Free Sch. Dist., 485 US 1034 [1988]).

Plaintiff failed to raise an issue of fact as to DC 37's fair representation of him. Evidence that plaintiff's union representative promised to work on plaintiff's complaints but then ignored his communications and failed to attend meetings does not suggest that the union's "activity . . . was deliberately invidious, arbitrary or founded in bad faith" (Matter of Sapadin v Board of Educ. of City of N.Y., 246 AD2d 359, 360 [1st Dept 1998] [internal quotation marks omitted]). The president of plaintiff's local expressly notified plaintiff of the union's decision not to pursue his grievance, and its "mere refusal . . . to proceed with [his] grievance does not in itself establish a breach of the duty of fair representation" (id. at 359). The CBA provision permitting plaintiff to pursue grievances on his own, as well as his deposition testimony [*2]that he had previously done so, undermine his assertion that he was never made aware that he had that right.

THIS CONSTITUTES THE DECISION AND ORDER OF THE SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT.

ENTERED: May 6, 2025

New York State Comptroller Thomas P. DiNapoli Releases Audits

 On April 30, 2025, New York State Comptroller Thomas P. DiNapoli announced the following audits of state departments and agencies have been issued.

Click on the text highlighted in color to access the complete audit

Department of Motor Vehicles – Language Access Services (Follow-Up) (2024-F-33)

New York State Executive Law expanded the State’s language access policy requiring translation of vital documents into the 12 most common non-English languages and Executive agencies to publish a Language Access Plan (Plan) to ensure meaningful access to services for Limited English Proficiency New Yorkers. The Department of Motor Vehicles (DMV), one of the agencies required to develop and follow a Plan, operates 31 public-facing offices and 100 public-facing office locations operated by the County Clerks (County DMVs). A prior audit, issued in October 2023, found that some offices were not using Language Line for interpretation services, as required by the Plan. Auditors also determined that, due to gaps in the law, DMV did not have sufficient authority to enforce its language access policies at County DMVs despite these offices accounting for over 75% of the total customer-facing DMV offices. DMV officials made some progress in addressing the five recommendations in the initial audit report, implementing two and partially implementing three.

New York City Department of Transportation – Street Construction-Related Permits (Follow-Up) (2024-F-20)

The New York City Department of Transportation’s (DOT) issues 150 different types of sidewalk and roadway construction permits. A prior audit, issued in June 2022, found that DOT did not perform all required inspections, did not set a time frame for inspectors to return to reinspect after issuance of Corrective Action Requests or Notices of Immediate Corrective Action, and did not ensure that applicants complied with registration and permit application requirements. DOT officials made some progress in addressing the initial report’s nine recommendations, implementing two, partially implementing six, and not implementing one.

Metropolitan Transportation Authority – Management and Maintenance of Non-Revenue Service Vehicles (Follow-Up) (2024-F-16)

Under the Metropolitan Transportation Authority (MTA), New York City Transit (Transit) is responsible for operating the subways and most of the public bus service throughout New York City, and MTA Bus Company (MTA Bus) provides bus service in portions of the Bronx, Queens, and Brooklyn, and express routes from those boroughs to Manhattan. Transit and MTA Bus are responsible for the acquisition, maintenance, disposition, and preventive maintenance of the non-revenue service vehicles in their fleet. A prior audit, issued in January 2023, found that Transit and MTA Bus did not always adhere to their own guidance or practice to provide annual service and service based on mileage intervals as part of preventive maintenance on their vehicles. The MTA made some progress in addressing the 11 recommendations in the initial audit report, implementing four, partially implementing two, and not implementing five.

Empire State Development – Oversight of Select High-Technology Projects (Follow-Up) (2024-F-19)

Empire State Development (ESD) is the chief agency responsible for the coordination of the State’s economic development programs. ESD supports high-technology (high-tech) sectors—highly valued targets of economic development—by providing loans and grants and administering tax credit programs. A prior audit, issued in August 2020, found that, while ESD had effective practices for monitoring specific programs, it had not adequately monitored other high-tech projects within the SUNY Polytechnic and/or Buffalo Billion portfolio to ensure that taxpayer money was effectively spent and was producing the intended results. Despite millions of dollars of State funding, selected high-tech projects had yet to create the expected number of jobs. ESD officials made progress in addressing the initial report’s three recommendations, implementing one and partially implementing two.

Hudson River–Black River Regulating District – Security Over Critical Systems (Follow-Up) (2025-F-5)

The Hudson River–Black River Regulating District (HRBRRD) is a New York State public benefit corporation that regulates the flow of streams or rivers when required by public welfare. HRBRRD must adhere to the Office of Information Technology Services’ (ITS) policies, including ITS’ Information Security Policy and Acceptable Use Policy, for its IT assets and abide by Payment Card Industry Data Security Standards (PCI DSS). A prior audit, issued in January 2024, found that HRBRRD could improve in some areas to better meet PCI DSS requirements, including documenting certain policies and procedures. HRBRRD officials made significant progress in addressing the issue identified in the initial audit report, implementing the one recommendation from the initial report.

Proposed Supplemental Military Leave Benefits [I.D. No. CVS-18-25-00006-P]

On May 7, 2025, the State Register reported that "notice has been given of the following proposed rule":

Proposed Action: This is a consensus rule making* to amend sections 21.15 and 28-1.17 of Title 4 NYCRR. 

Purpose: To extend the availability of supplemental military leave benefits for certain New York State employees until December 31, 2025. The full text of the proposed rule is posted at the following State website:

 https://www.cs.ny.gov/commission/calendars/April25cal-web.pdf

The proposed rule amends sections 21.15 and 28-1.17 of the Attendance Rules for Employees in New York State Departments and Institutions to continue the availability of the single grant of supplemental military leave with pay and further leave at reduced pay through December 31, 2025, and to provide for separate grants of the greater of 22 working days or 30 calendar days of training leave at reduced pay during calendar year 2025.

Union represented employees already receive these benefits pursuant to memoranda of understanding (MOUs) negotiated with the Governor’s Office of Employee Relations (GOER). The proposed rule merely amends section 21.15 of the Attendance Rules consistent with the current MOUs, and amends section 28-1.17 to extend equivalent benefits to employees serving in positions designated managerial or confidential (m/c). 

Under current statute, section 242 of the New York State Military Law provides that public officers and employees who are members of the organized militia or any reserve force or reserve component of the armed forces of the United States may receive the greater of 22 working days or 30 calendar days of leave with pay to perform ordered military duty in the service of New York State or the United States during each calendar year or any continuous period of absence.

Text of proposed rule and any required statements and analyses may be obtained from: Jennifer Paul, NYS Department of Civil Service, Empire State Plaza, Agency Building 1, Albany, NY 12239, (518) 473-6598, email address: commops@cs.ny.gov

Data, views or arguments may be submitted to: Eugene Sarfoh,  Counsel, NYS Department of Civil Service, Empire State Plaza, Agency Building 1, Albany, NY12239, (518)473-2624, email: public.comments@cs.ny.gov

Public comment will be received until: 60 days after publication of this notice, which was posted on on the Internet on May 7, 2025.

* Consensus Rule Making Determination Section 6(1) of the Civil Service Law authorizes the State Civil Service Commission to prescribe and amend suitable rules and regulations concerning leaves of absence for employees in the Classified Service of the State. As no person or entity is likely to object to the rule as written, the proposed rule is advanced as a consensus rule pursuant to State Administrative Procedure Act (SAPA) §202(1)(b)(i).

News from the New York State and Local Retirement System

The New York State and Local Retirement System noted that the week of May 5, 2025, is week is Public Service Recognition Week, and we proudly celebrate more than 713,000 members and 522,000 retirees of the New York State and Local Retirement System (NYSLRS) for their service to the people of New York State.

Public Service Recognition Week was created in 1985 to honor those who serve our nation as federal, state, and local. Click here to Read more »

 

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