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

Nov 29, 2024

Paid Family Leave updates for 2025 issued by the New York State Workers Compensation Boar Chair Clarissa Rodriguez

NYS Workers' Compensation Board Chair Clarissa M. Rodriguez announced that starting January 1, 2025, New Yorkers taking Paid Family Leave may receive up to $14,127.84 in total benefits – an increase of over $300 from 2024. The annual maximum cost they will pay will increase by about $20.

NYS Paid Family Leave provides eligible employees with up to 12 weeks of job protected, paid time off to bond with a new child, care for a family member with a serious health condition, or to assist loved ones when a family member is deployed abroad on active military service.

“Strong Paid Family Leave benefits means New Yorkers don’t have to sacrifice financial security to be there for family in times of need,” said Workers' Compensation Board Chair Clarissa M. Rodriguez. “No one should have to choose between caring for a loved one and a paycheck.”

Employees taking Paid Family Leave receive 67% of their average weekly wage, up to a cap of 67% of the current New York State Average Weekly Wage (NYSAWW), which is $1,757.19 for 2025. This means the maximum weekly benefit will be $1,177.32, and the total possible benefit to an employee is $14,127.84.

Beginning January 1, 2025, employees will contribute 0.388% of their gross wages per pay period to pay for Paid Family Leave, with a maximum annual contribution of $354.53 (0.388% of the NYSAWW). Employees earning less than the NYSAWW will contribute less than the annual cap of $354.53, consistent with their actual wages.


 Year 

 Maximum Total Benefit 

 Maximum Total Cost 

 2025

 $14,127.84

 $354.53

 2024

 $13,813.92

 $333.25

 

Free resources for employers and HR professionals

To help employers understand the NYS Paid Family Leave updates and share information with their employees, the Board has created a number of employer resources, including a deduction notice template, language for employee handbooks, and fact sheets, which are available in the Employer Resources section of paidfamilyleave.ny.gov/2025.

Additionally, the Board will be hosting a webinar for employers and HR professionals to provide an overview of the benefit, review the 2025 updates, and answer any participant questions. The one-hour webinar is offered on three dates:

About NYS Paid Family Leave

NYS Paid Family Leave is insurance, fully paid for by employees, that provides job-protected, paid time off care for family in times of need. Most employees of private employers in New York State are covered for NYS Paid Family Leave, while public employers can voluntarily opt in to provide the benefit.

Since NYS Paid Family Leave was first implemented in 2018, benefits have been significantly enhanced to further improve the lives of working New Yorkers and their families, including higher benefits, more time off, and more eligible events and family members.

More information

Complete details on NYS Paid Family Leave are available at PaidFamilyLeave.ny.gov. There is also a special page with updates for 2025 that includes benefit and deduction calculators, answers to frequently asked questions, and other resources.

Help is also available via a toll-free Paid Family Leave Helpline at (844) 337-6303, Monday through Friday, 8:30 a.m. - 4:30 p.m.


Nov 27, 2024

Administrative Law Judge recommends the termination of an administrative director found guilty of knowingly approved a subordinate’s fraudulent timesheets

New York City Office of Administrative Trials and Hearings Administrative Law Judge [ALJ] Jonathan Fogel recommended termination of employment for an administrative director [Respondent] who knowingly approved a subordinate’s fraudulent timesheets, made false timesheet entries on his behalf, and failed to verify the accuracy of his timesheets. 

The ALJ found that on numerous occasions from 2017 to 2022, Respondent submitted and approved a subordinate’s timesheets even though she knew that the subordinate was not at work. 

The ALJ did not credit Respondent’s explanation that her CityTime account may have been “compromised,” and rejected Respondent’s argument that she had approved the timesheets in good faith, finding that Respondent failed to address why she took affirmative steps to record and approve specific work hours for her subordinate, including overtime, when he was not working and was instead traveling out of state. 

Although Respondent has been employed by the agency since 2008, received favorable performance reviews in recent years, and has no disciplinary history, the ALJ concluded that termination is an appropriate penalty because Respondent's  repeated and deliberate dishonesty over several years demonstrated a lack of integrity. 

Click HERE to access Judge Fogel's findings and recommendation posted on the Internet.


Nov 26, 2024

New York State's Commissioner of Education dismissed a petitioner's application seeking to have a superintendent of schools removed from his position for alleged misconduct

In this appeal to the Commissioner of Education the Commissioner held that the Petitioner had not demonstrated that the Superintendent of the School District [Respondent] had "willfully violate the Education Law or neglected his duties as a school officer" and dismissed Petitioner's application.

Concluding that the record reflected that Respondent investigated the incident alleged by Petitioner and concluded that there was nothing to support a finding of child abuse, which finding the Commissioner's decision notes was "a determination with which Petitioner agrees", dismissed Petitioner's application seeking to have the Commissioner remove the Respondent from his position.

The Commissioner's decision is set out below: 

Decisions of the Commissioner of Education

Application of JOHN DOE for the removal of Dan Wilson as superintendent of the Catskill Central School District.

Decision No. 18,521

(November 12, 2024) 

Ferrara Fiorenza PC, attorneys for respondent, Cameron B. Daniels, Esq., of counsel 

ROSA., Commissioner.--Petitioner seeks the removal of Dan Wilson as superintendent (“respondent”) of the Catskill Central School District pursuant to Education Law § 306.  The application must be denied. 

Petitioner is the parent of a child who attends respondent’s high school (the “student”).  On or about February 15, 2024, the student participated in a rehearsal for the school musical “Cinderella.”

According to petitioner, a school district employee offered tape to the students in a joking manner, and the student proceeded to place a piece of tape on her own mouth.  By contrast, respondent indicates that he “received a report that a school staff member had placed tape over [the] student’s mouth.”  Upon receipt thereof, respondent informed law enforcement and initiated an internal investigation.  As part of its investigation, the district’s director of human resources interviewed several students, including petitioner’s child.  According to an affidavit submitted by the human resources director, petitioner’s child twice reported that the school employee had placed tape on her mouth.  

Following this investigation, respondent determined that the incident did not involve child abuse as defined by Article 23-B of the Education Law.  This application ensued. 

Petitioner argues that he and his spouse should have been contacted prior to the student’s interview and that respondent’s “concern in this situation was not for [his] child as an alleged victim, but rather to seek punishment for two staff members.”  Petitioner seeks respondent’s removal based on his alleged mishandling of the tape incident. 

Respondent contends that the application must be denied for, among other procedural deficiencies, failure to include the required notice.  Respondent also seeks certification that he acted in good faith in accordance with Education Law § 3811. 

The application must be denied for insufficient notice.  Section 277.1 (b) of the Commissioner’s regulations dictates the specific notice required for removal applications pursuant to Education Law § 306, which is distinct from the notice required under section 275.11 (a) for appeals pursuant to Education Law § 310.  The notice of petition secures jurisdiction over the intended respondent and alerts the respondent that he or she must appear in the removal proceeding and answer the allegations contained in the application (Application of Johnson, et al., 56 Ed Dept Rep, Decision No. 17,055; Appeal of Hertel, 49 id. 267, Decision No. 16,021; Application of Barton, 48 id. 189, Decision No. 15,832).  Thus, a removal application that does not include the specific notice required by 8 NYCRR 277.1 (b) is fatally defective and must be denied (Application of Johnson, et al., 56 Ed Dept Rep, Decision No. 17,055; Appeal of White and Carmand, 56 id., Decision No. 16,994; Appeal of Kelly, 45 id. 38, Decision No. 15,253).  Petitioner’s application lacks the required notice and, thus, must be denied (Appeal of Melton, 63 Ed Dept Rep, Decision No. 18,359; Appeal of M.B., 56 id., Decision No. 17,044).[1] 

Even if the application contained the required notice, it would be denied on the merits.  The Commissioner of Education may remove a school officer or member of a board of education from office when it is proven to the satisfaction of the Commissioner that the officer or board member has engaged in a willful violation or neglect of duty under the Education Law or has willfully disobeyed a decision, order, rule, or regulation of the Board of Regents or the Commissioner (Education Law § 306 [1]; see Application of Kolbmann, 48 Ed Dept Rep 370, Decision No. 15,888; Application of Schenk, 47 id. 375, Decision No. 15,729). 

Here, petitioner has not demonstrated that respondent willfully violated the Education Law or neglected his duties as a school officer.  The record reflects that respondent reasonably investigated an allegation that a staff member placed tape over a student’s mouth.  Moreover, respondent reasonably concluded that the incident did not constitute child abuse—a conclusion with which petitioner agrees.[2] 

Petitioner argues that he and his spouse should have been contacted prior to the student’s interview and that respondent’s “concern in this situation was not for [his] child as an alleged victim, but rather to seek punishment for two staff members.”* Petitioner seeks respondent’s removal based on his alleged mishandling of the tape incident.

[* N.BSee Decisions of the Commissioner of Education, Decision 18,522, set out below this decision.]

Finally, respondent requests a certificate of good faith pursuant to Education Law § 3811 (1).  Such certification is solely for the purpose of authorizing a board of education to indemnify a respondent for costs incurred in defending against a proceeding arising out of the exercise of the respondent’s powers or the performance of the respondent’s duties as a board member or other official listed in section 3811 (1).  The Commissioner will issue such certification unless the record establishes that the requesting respondent acted in bad faith (Application of McCray, 57 Ed Dept Rep, Decision No. 17,240; Application of Valentin, 56 id., Decision No. 17,014; Application of Paladino, 53 id., Decision No. 16,594).  Since the application has been dismissed on procedural grounds without any findings on the merits, I hereby certify that respondent is entitled to the requested certification (e.g., Application of Karimi, 63 Ed Dept Rep, Decision No. 18,345; Appeal and Application of Petrocelli, 62 id., Decision No. 18,223).

In light of this determination, I need not address the parties’ remaining contentions. 

THE APPLICATION IS DENIED. 


[1] While petitioner correctly notes that an appeal “shall not be dismissed for failure to include the language” contained in 8 NYCRR 275.11 (a), that section is inapplicable to applications for removal, which are governed by Part 277 of the Commissioner’s regulations. 

[2] Specifically, petitioner indicates:  “I am not suggesting in any way that my daughter was actually harmed.” 

END OF FILE 

Decisions of the Commissioner of Education

Appeal of MARCUS McGREGOR from action of the Board of Education of the Catskill Central School District regarding a personnel matter and application for the removal of Dan Wilson as superintendent and Jeremy Engelin and Ryan Osswald, as members of the Board of Education of the Catskill Central School District.

Decision No. 18,522

(November 12, 2024)

Ferrara Fiorenza PC, attorneys for respondent, Cameron B. Daniels, Esq., of counsel

ROSA., Commissioner.--Petitioner appeals his termination by the Board of Education of the Catskill Central School District (“respondent”) and seeks the removal of Dan Wilson as superintendent, and Jeremy Engelin and Ryan Osswald, as members of the board (“individual respondents”) (collectively, “respondents”).[1]  The appeal must be dismissed, and the application must be denied.

This appeal stems from the same factual background as Appeal of John Doe, 64 Ed Dept Rep, Decision No. 18,521, issued herewith.  Petitioner was employed by respondent as an independent contractor to assist in a musical production.  On March 15, 2024, respondent terminated petitioner’s contract for allegedly disclosing confidential information. This appeal and application ensued.

Petitioner[2] argues that the district improperly handled an investigation and seeks the removal of the superintendent and two board members for their alleged misconduct in connection therewith.  Petitioner also seeks reinstatement to his contractor position, arguing that he did not receive training on how to ensure the confidentiality of student information.

Respondents argue that the appeal must be dismissed for lack of standing, as untimely, and for improper service.  On the merits, they assert that petitioner has not established any willful violation of law or neglect of duty that would warrant removal of the individual respondents.  Respondents further argue that they acted within their authority and followed appropriate procedures in investigating an incident involving alleged harm to a student.  Finally, respondents maintain that petitioner was permissibly terminated for violating its confidentiality policy.

First, I must address a procedural issue.  The purpose of a reply is to respond to new material or affirmative defenses set forth in an answer (8 NYCRR 275.3, 275.14).  A reply is not meant to buttress allegations in the petition or belatedly add assertions that should have been raised in the petition (Appeal of Nappi, 57 Ed Dept Rep, Decision No. 17,300; Appeal of Caswell, 48 id. 472, Decision No. 15,920; Appeal of Hinson, 48 id. 437, Decision No. 15,908).  Therefore, while I have reviewed the reply, I have not considered those portions containing new allegations or exhibits that are not responsive to new material or affirmative defenses set forth in the answer.

Petitioner’s application for removal must be denied for lack of the required notice.  Section 277.1 (b) of the Commissioner’s regulations dictates the specific notice required for removal applications pursuant to Education Law § 306, which is distinct from the notice required under section 275.11 (a) for appeals pursuant to Education Law § 310.  The notice of petition secures jurisdiction over the intended respondent and alerts the respondent that he or she must appear in the removal proceeding and answer the allegations contained in the application (Application of Johnson, et al., 56 Ed Dept Rep, Decision No. 17,055; Appeal of Hertel, 49 id. 267, Decision No. 16,021; Application of Barton, 48 id. 189, Decision No. 15,832).  Thus, a removal application that does not include the specific notice required by 8 NYCRR 277.1 (b) is fatally defective and must be denied (Application of Johnson, et al., 56 Ed Dept Rep, Decision No. 17,055; Appeal of White and Carmand, 56 id., Decision No. 16,994; Appeal of Kelly, 45 id. 38, Decision No. 15,253).  Petitioner’s application lacks the required notice and, thus, must be denied (Appeal of Melton, 63 Ed Dept Rep, Decision No. 18,359; Appeal of M.B., 56 id., Decision No. 17,044).

The remaining relief sought by petitioner, reinstatement to his contractual position, is untimely.  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 for good cause shown (8 NYCRR 275.16; Appeal of Saxena, 57 Ed Dept Rep, Decision No. 17,239; Appeal of Lippolt, 48 id. 457, Decision No. 15,914).  Petitioner did not commence the instant action until over 30 days past his termination and he offers no excuse for the delay.  Accordingly, the appeal must be dismissed as untimely (Appeal of Zwanka, 56 Ed Dept Rep, Decision No. 17,051; Appeal of M.B., 56 id., Decision No. 17,044).[3]

Finally, respondents request certification of good faith pursuant to Education Law § 3811 (1).  Such certification is solely for the purpose of authorizing a board of education to indemnify a respondent for costs incurred in defending against a proceeding arising out of the exercise of the respondent’s powers or the performance of the respondent’s duties as a board member or other official listed in section 3811 (1).  The Commissioner will issue such certification unless the record establishes that the requesting respondent acted in bad faith (Application of McCray, 57 Ed Dept Rep, Decision No. 17,240; Application of Valentin, 56 id., Decision No. 17,014; Application of Paladino, 53 id., Decision No. 16,594).  Since the appeal has been dismissed on procedural grounds without any findings on the merits, I hereby certify that the individual respondents are entitled to the requested certification (e.g., Application of Karimi, 63 Ed Dept Rep, Decision No. 18,345; Appeal and Application of Petrocelli, 62 id., Decision No. 18,223).

In light of this determination, I need not address petitioner’s remaining contentions.

THE APPEAL IS DISMISSED.

THE APPLICATION IS DENIED.

[1] Petitioner also seeks the removal of respondent’s human resources director.  However, a human resources director is not a school officer subject to removal pursuant to Education Law § 306.

[2] To the extent that petitioner seeks relief on behalf of others, he lacks standing to do so and has not met the criteria to bring a class appeal (8 NYCRR 275.2).

[3] Since, petitioner was employed on a contractual, non-instructional basis, any right to reinstatement would arise from the terms of his contract.  Petitioner has not submitted a copy of this contract or identified any relevant provisions therein (see Appeal of Brosseau, 39 Ed Dept Rep 132, Decision No. 14,193).

END OF FILE

 


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.
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