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Apr 2, 2026

Plaintiff's CPLR Article 78 petition seeking a court order annulling employer's decision to discontinue the services of a probationary employee rejected

Supreme Court denied Plaintiff's petition seeking to obtain a court order annulling the New York City Department of Education's [DOE] decision to discontinue Plaintiff's probationary employment, rejecting Plaintiff's argument that her termination was made in retaliation for her filing a complaint with Office of Equal Opportunity. Plaintiff appealed, but the Appellate Division unanimously affirmed the Supreme Courts decision.

The Appellate Division explained that Petitioner's challenge of the lower court's decision to discontinue her probationary employment was properly denied as Plaintiff failed to show that her termination before the completion of her maximum period of probation:

a. Was for a constitutionally impermissible purpose; or

b. Was in violation of law; or

c. Was made in bad faith.

The Appellate Division opined that Plaintiff's argument that her termination was in retaliation for filing a complaint with the Office of Equal Opportunity was speculative, given the evidence of her misconduct, insubordination, and performance issues which had been discussed with her at meetings with administrative officials and her union representative which predated her filing of her Human Rights Law complaint. The Court held that that the record supports the conclusion that DOE's decision to terminate Plaintiff's probationary employment was due to Plaintiff's professional misconduct and insubordination. 

Addressing Plaintiff's "motion to renew" presented to Supreme Court, the Appellate Division said that Supreme Court "providently denied the motion to renew" because Plaintiff did not present any new evidence that could not have been presented in [the Plaintiff's] petition or that would have rendered a different result".

The Appellate Division noted that "No appeal lies from that part of the Supreme Court's order which denied [Plaintiff's] motion to reargue."

Click HERE to access the Appellate Division'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.

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