ARTIFICIAL INTELLIGENCE [AI] IS NOT USED IN COMPOSING NYPPL SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS.

Mar 19, 2026

An appeal to the Commissioner of Education pursuant to Education Law §310 is appellate in nature and is not ripe for review by the Commissioner until it is final

Petitioner filed an appeal pursuant to Education Law §310 with New York State's Commissioner of Education concerning an action of the Board of Education of a school district [Respondent] involving its filling an administrative position [Coordinator Position] for which the Petitioner had earlier applied and had been interviewed.

In the instant appeal Petitioner alleged Respondent "declined to hire him for the vacant Coordinator Position in retaliation for, among other things, multiple lawsuits he commenced against a member of Respondent’s hiring committee. In addition, Petitioner alleged that Respondent had violated certain provisions of New York State's Constitution, the New York State's Civil Service Law, and board policy.

Respondent had posted a job announcement for the Coordinator Position and subsequently reposted the job announcement in which it stated that "previous applicants need not reapply" but was otherwise identical to the previous posting.

Citing Appeal of Frey, 57 Ed Dept Rep, Decision No. 17,308, and other decisions of the Commissioner of Education, the Commissioner said Petitioner's appeal "must be dismissed as premature as the Commissioner will not render an advisory opinion on an issue before it becomes justiciable". 

The Commissioner explained the Commissioner’s jurisdiction pursuant to Education Law §310 is appellate in nature and an action is not ripe for review by the Commissioner until it is final and results in an actual, concrete injury.

Noting that Respondent’s Policy 9240 requires that an interview committee recommend three or more candidates for second round interviews for administrative positions such as the Coordinator Position and Respondent reposted the Coordinator Position in an effort to obtain the requisite number of candidates and that at the time Petitioner's  appeal was filled Respondent indicated that “none of the candidates … interviewed at the first-level were rejected and as Petitioner had not submitted a reply or otherwise contested these assertions by the Respondent, the Commissioner found that Petitioner's appeal must be dismissed as premature.


The Commissioner then observed that to the extent Petitioner suggests that Respondent was required to conduct "a competitive examination of merit and fitness" to fill the Coordinator Position, such examinations are not required for positions such as the Coordinator Position that involve “the function of administration of teaching” and dismissed Petitioner's appeal.

Click HERE to access the Commissioner of Education's decision posted on the Internet.

Editor in Chief Harvey Randall served as Director of Personnel, State University of New York Central Administration; Director of Research, Governor's Office of Employee Relations; Principal Attorney, Counsel's Office, New York State Department of Civil Service; and Colonel, JAG, Command Headquarters, 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.

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.
THE MATERIAL ON THIS WEBSITE IS FOR INFORMATION ONLY. AGAIN, CHANGES IN LAWS, RULES, REGULATIONS AND NEW COURT AND ADMINISTRATIVE DECISIONS MAY AFFECT THE ACCURACY OF THE INFORMATION PROVIDED IN THIS LAWBLOG. THE MATERIAL PRESENTED IS NOT LEGAL ADVICE AND THE USE OF ANY MATERIAL POSTED ON THIS WEBSITE, OR CORRESPONDENCE CONCERNING SUCH MATERIAL, DOES NOT CREATE AN ATTORNEY-CLIENT RELATIONSHIP.
New York Public Personnel Law. Email: publications@nycap.rr.com