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Jun 5, 2025

Termination of employee by the New York City Police Commissioner following a disciplinary hearing unanimously confirmed by the Appellate Division

The New York City Police Commissioner terminated Petitioner's service with the New York City Police Department [NYPD] after Petitioner was found guilty disciplinary charges that alleged that he struck his wife, brandished a pistol at her, threatened her and his minor son, and failed to report his arrest to the NYPD's Operations Unit.

Petitioner appealed the Commissioner's decision and the penalty imposed by the Police Commissioner.

The Appellate Division unanimously confirmed the Commissioner's decision, noting that the Hearing Officer's determinations that:

1. Hearsay statements of Petitioner's wife and son were credible;

2. Petitioner's testimony was not credible; and 

3. That the photograph introduced by NYPD was sufficiently authenticated.

The court, citing Matter of Benjamin v Department of Housing Preserv. & Devel. of City of N.Y., 187 AD3d 433, also pointed out that Petitioner may not rely on a notification of disposition from the NYPD Transit Bureau's internal investigation, submitted for the first time with his petition, because "judicial review is limited to the facts and record adduced before the agency".

The Appellate Division also noted that it did not have the discretionary authority to review Petitioner's unpreserved challenges to the admission of sealed arrest records at the hearing, NYPD's reliance on Civil Service Law §75, or the Hearing Officer's representation of the evidence.

Considering Petitioner's challenge to the penalty imposed, termination of his employment with NYPD, the Appellate Division opined that "The penalty of termination does not shock one's sense of fairness in light of [Petitioner's] egregious conduct", citing Matter of Marks, 234 AD3d at 413; and Matter of Castillo v Shea, 226 AD3d 531lv dismissed 42 NY3d 1071.

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


NYPPL Publisher 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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