ARTIFICIAL INTELLIGENCE [AI] IS NOT USED, IN WHOLE OR IN PART, IN PREPARING NYPPL SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS

Dec 11, 2025

The New York State's Local Government Efficiency Grants Program period for filing applications closes on February 4, 2026

$8 million is now available to partnering municipalities looking to undertake innovative projects that meet new and emerging challenges, ultimately resulting in increased affordability and more resilient communities for New Yorkers. 

The deadline for filing an application for a grant closes on February 4, 2026.

DOS is incentivizing collaborative municipal projects that prioritize:

  • Information Technology Services (ITS), including Cybersecurity
  • Emergency Services
  • Countywide or Multi-County Code Enforcement or Municipal Planning
  • Water and/or Wastewater Management Systems
  • Clean Energy Initiatives

Local Government Efficiency benefits include:

  • Long-term savings for your community
  • Grant funding that can ease municipal budget constraints and reduce government spending

A municipality could receive up to:

• $1,250,000 for implementing innovative collaborative projects (each participating municipality eligible for up to $250,000; 10% local match required)

• $100,000 for planning projects (each collaborating municipality eligible for up to $20,000; 50% local match required)

Learn more on the DOS website

Unsuccessful candidate for election to the Board of Education challenges the certification of another candidate seeking election to the position

Citing 8 NYCRR 275.16, the New York State Commissioner of Education Betty A. Rosa [Commissioner] noted that an appeal to the Commissioner must be commenced within 30 days from the decision or act complained of, unless any delay is excused by the Commissioner of Education for good cause shown. 

In this appeal to the Commissioner challenging the seating of the individual designated the successful candidate elected to the School Board, the Commissioner noted that an individual or entity possibly adversely affected by a determination in favor of the Petitioner in the action is a necessary party and must be joined as such.

The Commissioner then explained that: 

1. Joinder requires that all necessary parties be clearly named as a respondent in the caption of the petition; and

2. All necessary parties must be served with "a copy of the notice of petition and petition, informing the party to appear in the appeal and to answer the allegations contained in the petition".

Further, the Commissioner noted that "In an appeal regarding a school district election, the petitioner must join the district’s board of education as well as 'each person whose right to hold office is disputed.'" [Citations omitted.]

Petitioner commenced the instant appeal by serving the district clerk of the school district, which constitutes timely service upon school district and the district clerk. However, Petitioner did not timely serve the challenged successful candidate as the record indicates that the challenged successful candidate was served with Plaintiff's petition "more than 30 days from the election and certification of the results". 

As the Petitioner did not identify "good cause" for Petitioner's failure to timely serve the successful candidate, Dr. Rosa said considering the fact that the Petitioner disputes the successful candidate's right to hold office she was "constrained to dismiss the [Petitioner's] appeal as untimely."

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


Dec 10, 2025

Court rejects Petitioner's argument that delays in commencing the hearing prejudiced him as any delay was caused by Petitioner's own action

The New York City Housing Authority [NYCHA], after a Civil Service Law §75 disciplinary hearing, found the Petitioner guilty of 14 of the 15 charges of employee misconduct and incompetence leveled against him. The disciplinary penalty imposed: termination from employment with NYCHA. 

Petitioner filed a CPLR Article 78 challenging the NYCHA's decision contending the disciplinary charges were untimely. The Appellate Division unanimously confirmed NYCHA decision and the penalty imposed on Petitioner, ruling that the disciplinary proceedings were timely commenced pursuant to Civil Service Law §75(4) as Petitioner was served with the amended charges within 18 months of the earliest of the various charged incidents of the employee's alleged misconduct. The Court also rejected Petitioner's argument that any delay in commencing the hearing prejudiced him, observing that any the delay in holding the disciplinary hearing "was caused by [Petitioner's] own violation of NYCHA's vaccine policy."

The Appellate Division opined that "substantial evidence supported the trial officer's report sustaining 14 of the 15 charges of employee misconduct and incompetence leveled against [the Petitioner]." The Appellate Division also noted that NYCHA submitted testimony from Petitioner's former supervisors, along with multiple counseling memoranda, which showed that Petitioner repeatedly refused to comply with their directives and to perform the tasks assigned to him and testimony in the record "established that [Petitioner] became argumentative and hostile when asked to complete tasks, to the extent that his behavior required reports to NYCHA's Office of Safety and Security."

The Court also reject Petitioner's claims that NYCHA witnesses' were allegedly bias finding that "there exists no basis to disturb the credibility determinations of the trial officer".

Addressing the penalty imposed on Petitioner, dismissal from his position with NYCHA, the Appellate Division said "Termination of [Petitioner's] employment does not shock one's sense of fairness as it is not so disproportionate to the seriousness of the multiple charges of misconduct and incompetency proven" and Petitioner submitted no evidence showing that "he was terminated after engaging in protected activity, and the record was clear that he was discharged due to his own incompetence and misconduct."

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


Dec 9, 2025

Educator served with disciplinary charges alleging that she had directed a racially charged insult at a woman off school grounds

A tenured teacher [Petitioner] employed by the New York City Department of Education [DOE] was served with disciplinary charges alleging she [1] directed a racially charged insult at a woman off school grounds and [2] exhibited alleged discriminatory conduct directed at students in her classroom. 

Following a disciplinary hearing held pursuant to Education Law Section 3020-a, the Hearing Officer sustained the charges and specifications related to the language involving the woman uttered off school ground and recorded in a video of the incident and the Petitioner's discriminatory actions discovered in the course of DOE's investigation of the Plaintiff classroom conduct

Based on these findings, the Hearing Officer concluded that the Petitioner was guilty of the charges served on her and that Petitioner should be terminated from her position notwithstanding the absence of evidence of any prior discriminatory actions by Petitioner in Petitioner's employment record

Petitioner appealed but the Appellate Division, sustaining the Hearing Officer's finding and the penalty imposed, opined that the penalty of termination was supported by the record, was not disproportionate to the offense, and does not shock one's sense of fairness. 

In the words of the Appellate Division, "Supreme Court properly denied [Petitioner's] amended petition to vacate the arbitration award", and indicated that the Hearing Officer properly considered:

(1) "the gravity of the charges; 

(2) "the fact that [Petitioner] had recently participated in implicit bias training and received a copy of Chancellors Regulation A-830 which articulated DOE's anti-discrimination policy, and thus informed [Petitioner] of her duty to conduct herself professionally both inside and outside of the classroom; 

(3) "that [Petitioner] should have known that her behavior would violate the DOE anti-discrimination policy which might result in disciplinary action; and 

(4) "that [Petitioner] failed to demonstrate remorse or take responsibility for her conduct". 

The Appellate Division opined that "Notwithstanding [Petitioner's] effective record during her approximately 18-year career with DOE the penalty does not shock the conscience. Having received prior notice of the consequences of discriminatory behavior, Petitioner nonetheless engaged in a pattern of inappropriate conduct unbecoming a teacher."

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


Dec 8, 2025

New York Department of State Announces Opening of $8 Million Local Government Efficiency Program

 

Captioned "Competitive Grant Opportunity Incentivizes Municipalities Aiming to Reduce Costs and Lower Tax Burden", on December 8, 2025, The New York Department of State announced that its popular Local Government Efficiency Grant (LGEG) program is again available to municipalities with innovative ideas for supporting a more affordable New York. Applicants may apply for funding to streamline government operations and services which reduce current or future costs, resulting in savings for local property taxpayers. The $8 million initiative incentivizes two or more local governments to team up to apply to plan for or implement shared services, consolidations, and dissolutions.

“Incentivizing municipalities to find new efficiencies is a great way to create more affordable communities,” said Secretary of State Walter T. Mosley. “The Local Government Efficiency program has shown the capacity to offer great economic returns for localities and expanding it will bring even more savings to New Yorkers.”

Through the LGEG, DOS is also aiming to assist local governments to address significant current and emerging challenges. In this current funding round, Priority Points will be given to: Regional Projects; Regional or Local Projects being implemented as part of a previous LGE planning grant or that was included in a Countywide Shared Services Initiative (CWSSI) plan; or Regional or Local Projects that aim to address:

  • Information Technology Services (ITS), including Cybersecurity;
  • Emergency Services;
  • Countywide or Multi-County Code Enforcement or Municipal Planning;
  • Water and/or Wastewater Management Systems; or
  • Clean Energy Initiatives.

Some Recent Winning Communities Include:

  • Town of Hunter partnering with Greene County, the Villages of Hunter and Tannersville, and the Hunter-Tannersville Central School District: Mountaintop Community and Municipal Services Center - $1,250,000
  • Town of Carmel partnering with the Bedford, Bronxville, Eastchester, Mamaroneck, and Ossining Police Departments: Shared Police Communications Software - $1,200,000
  • Orleans County: Orleans County EMS Study $52,859
  • Tompkins County: Rapid Medical Response Team pilot program - $629,779
  • Brockport Fire District partnering with the Bergen and Churchville Fire Departments, and the Murray Joint and Hamlin-Morton-Walker Fire Districts: Mutual Aid College Student Bunk-In Program: $490,500

The LGEG Request for Applications (RFA) and additional information may be found on the DOS website at: dos.ny.gov/needtopost. RFAs must be submitted by Wednesday, February 4, 2026 at 4 pm. 


Municipal audits posted posted on the Internet by the New York State Comptroller

On December 5, 2025 New York State Comptroller Thomas P. DiNapoli posted the following local government audits on the Internet. 

Click the text highlighted in color to access the text of the audit.


Town of Lockport – Fuel Inventory (Niagara County)

The superintendent did not properly safeguard and monitor fuel usage. He also did not properly oversee the Highway Department clerk’s work. Due to the lack of controls and oversight of fuel operations, billing errors occurred and the potential for inappropriate use of town fuel to occur and go undetected was significant.


Town of Lockport – Asphalt Millings Inventory (Niagara County)

The superintendent did not properly monitor and account for the millings inventory or unscreened millings sales. As a result, there is an increased risk of fraud, abuse and misuse of millings inventories and sales revenue to occur and go undetected. The superintendent also did not update the sale price of millings in accordance with the current average market price. As a result, 483 tons of unscreened millings that were sold for $929 should have been sold for $9,875 based on average market prices at the time of the sale. In addition, because millings are a lower-cost alternative to stone and other materials used for roadway and other town projects, officials may incur added costs if the town’s millings inventory is depleted.


Town of Lockport – Building Permit Fee Collections (Niagara County)

The inspector did not properly manage permit fee collections by not always applying the board-approved permit fee and not maintaining accurate records. As a result, the town may not have received all revenues due to the town, and permit fees collected may have been lost, misused or misappropriated.


Town of Lockport – Culvert Pipe Fee Collections (Niagara County)

The superintendent did not ensure application fees and installation fees were properly collected and recorded. Therefore, officials cannot verify the accuracy or ensure accountability of the collection of those fees. This significantly increased the risk that collections could be lost, unaccounted for or misappropriated without detection.


Town of Guilderland – Information Technology (IT) (Albany County)

The town board and officials did not monitor employee internet use or establish adequate controls to safeguard IT systems. In addition, the board did not adopt an IT contingency plan to help minimize the risk of data loss or a serious interruption of services, periodically test backups or provide IT security awareness training. As a result, town officials cannot be assured that town IT assets are secured and protected against unauthorized use, access and loss, and there is an increased risk that officials could lose important data and suffer a serious interruption in operations.


Town of Guilderland – Sales Tax Revenue Allocation (Albany County)

Town officials did not properly budget for and allocate sales tax revenue totaling $14.8 million during the audit period. As a result, taxpayer inequities occurred. Auditors found that town taxpayers who lived outside the village did not receive all the benefits they should have from the county sales tax distributions, while taxpayers with real property located within the village received an extra benefit.


Town of Willsboro – Town Clerk/Tax Collector (Essex County)

The town clerk/tax collector did not properly record, deposit, report and remit collections and misappropriated more than $29,000 in collections during the audit period. The clerk concealed her misappropriation of collections by not recording collections or recording them for less than the amount received, making unsupported cash deposits, not reporting and remitting collections to the supervisor and state agencies, not returning overpayments to taxpayers and making unsupported disbursements between her three bank accounts. 

The clerk worked for the town from 2014 to 2021, having lost election in 2021. She also separately served as treasurer for the Essex County Agricultural Society, a non-profit organization that promotes agriculture through the Essex County Fair, from 2013 to 2019. 

Based upon the audit findings and subsequent investigation of the clerk’s activities at both the town and the society, the clerk was arrested in the summer of 2024 for stealing approximately $60,000 from the society and $29,000 from the town. In May 2025, the clerk pleaded guilty to felony grand larceny in the second degree for the funds stolen from the society and felony grand larceny in the third degree as a crime of public corruption for the theft from the town. 

In July 2025, the clerk was sentenced to five years’ probation and ordered to pay full restitution of nearly $90,000 for stealing funds from both the society and town.

                                                                      ###


Dec 6, 2025

Selected items posted on the Internet during the week ending December 5, 2025

New York State Workers' Compensation Board Webinar A Paid Family Leave webinar for employees is scheduled to be held on Wednesday, December 10, 2025 from 12:00 pm thru 1:00 pm. Register here

ROI You Can Prove: Making the Case for Modern Identity Systems  Modern identity systems are critical to secure, digital-first government—but funding them takes a clear business case. This guide walks through a realistic five-year cost-benefit analysis for digital identity systems in the public sector, showing how agencies can forecast ROI, reduce fraud, and accelerate digital transformation.  DOWNLOAD 

Firewalls Aren't Enough: Securing Government for the AI Era AI is changing how governments operate — and how cyber threats emerge. Traditional firewalls alone can’t keep up with modern attack surfaces, especially in decentralized, cloud-driven environments. This paper explores why a platform-based security approach is now essential, highlighting strategies like autonomous segmentation, AI model protection and centralized threat detection. DOWNLOAD

From the Trenches: Why Every Government City Manager Needs Better Meeting Documentation Poor documentation erodes trust and slows government action; modern tools help preserve institutional memory. READ NOW 

Navigating H.R. 1: A Checklist for the New SNAP Compliance Landscape  H.R. 1 raises the stakes for state SNAP programs. With rising administrative costs and penalties tied to payment errors, this checklist helps agencies pinpoint where automation and data strategies can reduce risk, support new rules, and control costs. DOWNLOAD

From Vision to Reality: Making AI Work for Smarter Cities and States In this interactive webinar, Government Technology is convening AI industry experts for a candid conversation about what it really takes to adopt and scale AI responsibly. REGISTER

From Vision to Reality: Making AI Work for Smarter Cities and States In this interactive webinar, Government Technology is convening AI industry experts for a candid conversation about what it really takes to adopt and scale AI responsibly. REGISTER 

Procuring a Modern Payment Platform Payments are a critical but often underprioritized factor in user experience. As governments work to become more responsive and resident-centric, payment strategies should emphasize enterprise platform approaches and innovative capabilities like digital wallets and recurring payment options. This paper offers practical advice for procuring modern payment solutions that support a superior user experience. DOWNLOAD 

Future Forward Government A space created for state and local IT leaders and decision-makers who are charting the course of tomorrow's public sector. EXPLORE 

Navigating H.R. 1: A Medicaid Checklist for Government Agencies New Medicaid work and reporting requirements are fast approaching. This checklist helps state agencies assess how prepared they are to verify employment, education, and life changes without creating administrative gridlock. DOWNLOAD 

AI in Construction: What’s Changing and Why It  Matters  Smarter tools are accelerating safer, more predictable jobsites and transforming construction’s future. Learn More

A New Docufilm Explores How Teamwork is Key to Restoring Critical Connections After Natural Disasters In the wake of disaster, America's cable industry knows reconnecting communities depends on planning, trust, experience, and working together when every minute counts. Watch Now

Modernize Government Payouts for Better Service Discover how agencies can deliver fast, secure and equitable payments.  READ MORE

Realizing AI's Potential in Billing and Payments Download this guide to learn how leading organizations are transforming outdated billing operations into streamlined, scalable systems that reduce overhead and improve customer service. DOWNLOAD


Dec 5, 2025

Applying the Doctrine of Legislative Equivalency,

The doctrine of legislative equivalency requires that "[t]o repeal or modify a statute requires a legislative act of equal dignity and import". 

In the instant two "companion" actions the Appellate Division affirmed Supreme Court CPLR Article 78 decisions granting the two employee applications seeking to compel the City of Schenectady to pay the two respective CPLR Article 78 Petitioners the cash value of their respective unused sick leave accruals to which they contended they were entitled upon their discontinuing their employment with the City of Schenectady. 

The Appellate Division noted that in 1986 the City of Schenectady adopted had §87-13 of the Code of the City of Schenectady providing that nonunion employees "shall be entitled to convert 75% of [their] unused sick leave [credits] up to a maximum accumulation of 240 days to cash, upon termination of [their] services as an employee with the City." 

The Appellate Division also indicated that "Subsequently, Local Law No. 2011-05 amended Chapter 13 of the City Charter to grant the City Council the authority to fix and determine salaries, compensation and benefits of all City employees and Officers" and "Separate from this authority to establish salaries in the annual budget process, the local law provides that [a]ll other compensation and benefits shall likewise be determined by the City Council pursuant to . . . General Municipal Law §92 and codified in Chapter 87 of the Code of the City of Schenectady  (emphasis supplied by the Appellate Division)"

Holding the Doctrine of Legislative Equivalency "applies to attempts to amend a [city] code or ordinance by use of a resolution", the Appellate Division ruled that the employees named in the two appeals filed by the City of Schenectady challenging the Supreme Court's Article 78 rulings were entitled to receive appropriate payments for their unused sick leave accruals upon their discontinuing their employment with the City of Schenectady as the Schenectady City Council's attempt to supersede Chapter 87 of the City Code with a resolution "is inconsistent with the doctrine of legislative equivalency".

Click HERE to access the "lead decision" appeal before the Appellate Division, Matter of Koldin, posted on the Internet.

Click HERE to access the "companion decision" appeal before the Appellate Division, Matter of Marney, posted on the Internet.


Dec 4, 2025

New York State Employees Retirement System's Online Tools and Tips

Posted on the Internet by NYSERS on December 04, 2025 


Retirement Online is the fastest and most convenient way to access your retirement account information and conduct business with NYSLRS. In many cases, you can use Retirement Online instead of sending forms through the mail or calling. For example, members can estimate their pension or apply for retirement, and retirees can get their 1099-R tax form or update their federal tax withholding.


Recent disciplinary decisions by New York City Office of Administrative Trials and Hearings Administrative Law Judges

Administrative Law Judge [ALJ] Kevin F. Casey recommended a 30-day suspension after finding that a New York City correction officer submitted a false, misleading, inaccurate, or incomplete report regarding a colleague’s use of force. 

Judge Casey, however, did not sustain a companion charge that the officer failed to intervene when the same person allegedly engaged in self-harm. 

In recommending a 30-day suspension, the ALJ noted that the evidence did not support a departure from the employer's Disciplinary Guidelines. 

Click HERE to access the text of Judge Casey's decision setting out his findings  and recommended penalty.


ALJ Orlando Rodriguez recommended termination of employment of a New York City Eligibility Specialist after the employer proved the employee failed to report to her work location for approximately four months, was absent without authorization, ignored supervisory directives, and acted aggressively and discourteously. 

Judge Rodriguez noted that although the employer only proved some of the charges, the employee’s prolonged unauthorized absence alone provided sufficient grounds to terminate her employment. 

Click HERE to access the text of Judge Rodriguez's decision setting our his findings and recommended penalty.


Judge Astrid B. Gloade recommended a 20-day suspension of a supervisor after finding that the supervisor failed to perform her duties efficiently and failed to properly supervise her subordinates. 

The ALJ had determined that the employer had proved that the supervisor sent a letter containing confidential information about an applicant to an incorrect childcare program, that the supervisor provided incorrect guidance to a subordinate and that the supervisor had failed to meet deadlines with respect to performing certain of her responsibilities. 

Judge Gloade, however, had concluded that the employer's requested penalty that the supervisor be terminated from her position was excessive given the proven charges and, in consideration of the supervisor's long service and heretofore unblemished record, recommended that the appointing authority impose a penalty of a 20-day suspension*.
 
Click HERE to access the text of Judge Gloade's decision setting out her findings and recommended penalty.

* A Reasonable Disciplinary Penalty Under the Circumstances - NYPPL's 442-page e-book focusing on determining an appropriate disciplinary penalty to be imposed on an employee in the public service in instances where the employee has been found guilty of misconduct or incompetence. Click on http://booklocker.com/books/7401.html for more information.



Dec 3, 2025

Disciplinary decision and the penalty imposed remanded for review with instructions to consider only timely charges and specifications

In this appeal of an administrative disciplinary action which found an employee of the New York State Unified Court System [UCS] guilty of the charges filed against him, the Appellate Division notes that where the issue is whether an agency complied with its own internal procedures, the appropriate standard of review is whether the determination was "made in violation of lawful procedure".

Further, opined the court, it is a "fundamental administrative law principle that an agency's rules and regulations promulgated pursuant to statutory authority are binding upon it as well as the individuals affected by the rule or regulation".

The employee [Petitioner] had been served with a notice of charges and specifications alleging that he had engaged in three specified acts of misconduct when he used biased and discriminatory language in three Facebook comments he had posted on the Internet. One such comment, however, was subsequently determined to have been "untimely" at the time it was charged and served.

The Appellate Division's decision notes that where the issue is whether an agency complied with its own internal procedures, the appropriate standard of review is whether the determination was "made in violation of lawful procedure" as it is a "fundamental administrative law principle that an agency's rules and regulations promulgated pursuant to statutory authority are binding upon it as well as the individuals affected by the rule or regulation".

The revised Hearing Officer's findings and recommendation had not distinguished between the sanction initially recommended by the hearing officer in consideration of finding the employee guilty all three alleged charges of misconduct and an appropriate reasonable sanction recommended by the hearing officer to be imposed based on the employee in consideration of the hearing officer's finding the individual guilty of the surviving two timely alleged acts of misconduct. 

The Appellate Division then remitted the matter to UCS for a new determination and recommendation of a penalty to be made by a hearing officer based solely on the two timely specified acts of misconduct, noting that "DILLON, J.P., LOVE and GOLIA, JJ., concur" while DOWLING, JJ., "voted to confirm the revised determination, deny the petition, and dismiss the proceeding on the merits, with a memorandum."

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

Dec 2, 2025

Rochester women pleads guilty to stealing nearly $13,000 from the New York State Employees' Retirement System by failing to report her mothers death

On December 1, 2025 New York State Comptroller Thomas P. DiNapoli, Monroe County District Attorney Brian Green and New York State Police Superintendent Steven G. James announced that Karen Walsh, a 68-year-old Rochester woman, pleaded guilty to stealing $12,973 in state pension payments sent to her mother, whose death had not been reported to the pension system. As part of the plea, Walsh was ordered to pay full restitution upfront.

“Ms. Walsh tried to profit off of her mother’s death and defraud the state pension system,” DiNapoli said. “Now, through my partnership with law enforcement, she has been held accountable for her actions and must repay the money she stole. My thanks to D.A. Green and the New York State Police for their work with my office to ensure justice is served.”

“The defendant’s actions represent a misuse of the New York State pension system and, by extension, an offense against the citizens who fund it,” Green said. “Allowing such conduct would undermine the integrity of a system relied upon by countless public servants who dedicated their careers to their communities. I appreciate the thorough work of the State Comptroller’s Office and the New York State Police in this investigation that assisted in today’s resolution. The Monroe County District Attorney’s Office is committed to seeking justice and accountability for all who commit economic crimes against the residents of New York State.”

“Ms. Walsh used her mother’s death to her advantage and continued to inexcusably collect the pension meant to support her mother for the remainder of her life. We will continue to aggressively investigate any case involving financial corruption and those who take advantage of the pension system. I commend the Comptroller’s Office and the Monroe County District Attorney’s Office for their partnership in this investigation,” James said.

Walsh’s mother, also of Rochester, received a monthly payment as the beneficiary of her deceased husband’s state pension. When she passed away in 2020, her pension payments should have stopped, however, Karen Walsh failed to report the death to the pension system and instead pocketed the money.  A total of $19,524 in pension payments went to Walsh’s account.

Walsh stole $12,973 by withdrawing over $4,000 from the account and transferring at least $8,000 to a second account in her mother’s name to which she also had access. She wrote checks from that second account, forging her deceased mother’s name and endorsing the back of the checks with her own signature, before depositing them into her own account. Walsh also used the second account in her mother’s name to make personal credit card payments, pay for home improvements and buy groceries.

Walsh pleaded guilty to petit larceny before Judge Van H. White in Rochester City Court.

###

Since taking office in 2007, DiNapoli has committed to fighting public corruption and encourages the public to help fight fraud and abuse. New Yorkers can report allegations of fraud involving taxpayer money by calling the toll-free Fraud Hotline at 1-888-672-4555, by emailing a complaint to investigations@osc.ny.gov or by mailing a complaint to: Office of the State Comptroller, Division of Investigations, 8th Floor, 110 State St., Albany, NY 12236.



Dec 1, 2025

New York State Comptroller Thomas P. DiNapoli posts local government audits on the Internet

On November 26, 2025, New York State Comptroller Thomas P. DiNapoli announced the following local government audits were issued.

Click the text highlighted in COLOR to access the audit posted on the Internet

City of Dunkirk – Budget Review (Chautauqua County)
The lack of complete, accurate and current accounting and financial records significantly limited this review and precluded auditors from determining the reasonableness of all of the city’s significant revenue and expenditure projections. The city’s most recent Annual Financial Report (AFR) was submitted to the Office of the State Comptroller (OSC) for the 2023 fiscal year; the 2024 AFR was due April 30, 2025. 

The most recent available independent audited financial statements were finalized for 2024 in October 2025. The external auditor’s findings reported in the 2022, 2023 and 2024 financial statements further support OSC’s position that the city’s accounting records are not reliable or up to date. These findings also acknowledge the rapid deterioration of the city’s finances and report that officials do not have the ability to effectively monitor the city’s cash position or results of operations, making financial planning and budgeting incredibly difficult. 

The city’s most recently completed audited financial statements reported that as of Dec. 31, 2024, the general, water, wastewater, refuse and boardwalk funds had deficit fund balances totaling $15.3 million. 

The city’s financial condition continued to decline during the current year because the 2025 adopted budget was not structurally balanced and due to a large unbudgeted $1.8 million payment for the purchase of two pumper trucks. With fund balance depleted, the city has limited options available to fund any increases in operating costs. 

City officials were not planning to increase water or wastewater rates to address the deficits in the water and wastewater funds. The 2026 budget includes a proposed tax levy increase of $198,675 (2%) which will exhaust 86.37% of the city’s constitutional tax limit. As a result, the city’s ability to raise taxes going forward will be severely limited.


Seaford Union Free School District – Capital Assets (Nassau County)
District officials did not maintain complete and accurate capital asset records. Auditors determined that, while assets totaling $1.7 million were inventoried, the district’s inventory records lacked sufficient detail to account for and safeguard the assets. Assets totaling $196,089 were not inventoried, and assets totaling $42,314 were missing and could not be located. The inventory list did not include all necessary information to locate and identify assets. For example, 358 IT assets on the inventory list totaling $1.7 million did not have a serial number. Additionally, 280 assets totaling $630,009 (including 186 IT assets totaling $200,705) did not have the current location recorded on the inventory list. 

Town of Kingsbury – Multiyear Planning for Fund Balance and Reserves (Washington County)
The board and officials did not develop and adopt a multiyear financial plan, a fund balance policy or a reserve policy. As a result, officials continued to accumulate unrestricted fund balance without defining the amounts the board deemed necessary and without documenting future goals or expectations for the accumulation of funds. Had the board and officials developed and adopted a multiyear financial plan and fund balance and reserve policies, the goals of maintaining an adequate level of fund balance and improving the town’s capital assets over time would have been more transparent to the town’s taxpayers. Without such plans or policies, the board cannot assess revenue trends, expenditure commitments, financial risks and the affordability of new services and capital investments over time.


Town of Hornellsville – Financial Management (Steuben County)
The board did not effectively manage the town’s fund balance. Despite maintaining significant unrestricted fund balances, the board overrode the tax levy limit each year and adopted budgets that increased real property taxes by a total of 18% in calendar years 2022 through 2025. As a result, the board maintained unrestricted fund balances that, as of Dec. 31, 2024, were sufficient to fund more than five years of water, three years of sewer and half of the combined town-wide (TW) funds’ 2025 budgeted appropriations. In addition, the board did not treat taxpayers equitably because it inappropriately allocated sales tax revenues totaling $1.1 million to the TW funds instead of the town-outside-village funds in calendar years 2022 through 2024. The board also did not adopt a written fund balance policy until Feb. 11, 2025, after the State Comptroller’s audit notification, or adopt comprehensive written multiyear financial or capital plans. Although auditors provided recommendations in their prior audit, the board did not implement adequate corrective action to address the deficiencies.


  
City of Little Falls – Budget Review (Herkimer County)
The tentative budget includes revenues of $966,599 for revenue sharing state aid, $480,000 for garbage collection user fees, $177,000 for the sale of real property, $350,000 for ambulance charges, $60,000 for the sale of timber, $1.4 million for metered water sales, $1.6 million for sewer rents and $138,500 for golf revenues. These revenues may not be reasonable. The budget also does not include a contingency appropriation in any fund. In addition, the budget includes approximately $1.16 million in debt payments, which are likely overestimated by $37,327. The budget also includes retirement appropriations totaling approximately $1.3 million for members of the state retirement system and appropriations totaling $161,398 for workers’ compensation costs. These appropriations were not properly allocated to each of the operating funds.


Wyoming County Industrial Development Agency (WCIDA) – Payments in Lieu of Taxes (PILOT)
WCIDA officials ensured PILOTs they calculated were accurate and in compliance with the PILOT agreements. During the audit period, WCIDA officials calculated PILOT billings for nine wind and solar energy projects, totaling $971,547. Auditors reviewed the PILOT billings for five of these agreements totaling $280,693 and determined they were accurate and in compliance with the PILOT agreements.


Town of Danby – Audit Follow-Up (Tompkins County)
A previous audit, Town of Danby – Board Oversight (2022M-127), determined that the board did not seek competition when procuring goods and services and audit claims prior to payment. The audit included 14 recommendations to help officials monitor and improve the town’s purchasing and claims auditing procedures. The board and town officials failed to implement any of the 14 audit recommendations and were unable to provide reasonable explanations for their lack of action. The board also persisted in procuring goods and services that may not have been made in a cost-effective manner and the board’s ability to effectively monitor the town’s financial operations continued to be diminished.

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Nov 29, 2025

Selected items posted on blogs on the Internet during the week ending November 28, 2025

Five Ways Government Leaders Boost Transparency and Trust Learn how public-sector agencies strengthen community confidence through improved transparency and accountability. READ NOW 

Elevating Constituent Services with Connected Experiences This leadership paper explains what your agency needs to create connected experiences and provides several real-world examples of how connected experiences have transformed government services. Read more to find out how your organization can start building connected experiences! DOWNLOAD 

Resilience Blueprint for Local Governments In this comprehensive guide designed for local government leaders, learn actionable strategies to bolster your community's extreme weather resilience, future-proof your energy systems, and ensure continuity of critical servicesDOWNLOAD

New Series Premiere: Public Officials of the Year Webcast The first episode of The Common Thread, Governing’s new series hosted by CEO Cathilea Robinett, spotlights L.A. CIO Ted Ross and his bold approach to modernizing one of America’s largest cities. Watch the Premiere Episode



 

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