New York Public Personnel Law

Nov 4, 2025

Pandemic unemployment fraud conspiracy

On October 22, 2025, New York State Inspector General Lucy Lang announced the sentencing of Jodi Drygula, of Amsterdam, NY, and Anthony Camou, of Las Vegas, NV, for their roles in a conspiracy to fraudulently obtain more than $250,000 in unemployment insurance benefits intended to support New Yorkers during the COVID-19 pandemic.

Click HERE to access the press release issued by the Office of the Inspector General concerning this matter.

Appellate Division finds termination of educator from employment to be reasonable under the circumstances

Supreme Court rejected Plaintiff's petition seeking to vacate an arbitration award which resulted in the termination of Plaintiff's employment by Department of Education of the City of New York [Respondent] and granted Respondent's cross-motion to dismiss the Plaintiff's petition. Plaintiff appealed.

The Appellate Division unanimously affirmed the arbitrator's determination that Plaintiff's teaching performance was deficient during the relevant three-year period, that it was supported by adequate evidence, which included the testimony of school administrators and documentation.

Finding that the determination was rational, and not arbitrary and capricious the Appellate Divisions' decision noted that the record included written observational reports and testimony from school administrators and an independent peer evaluator demonstrating Plaintiff's inadequate teaching, Respondent's efforts at remediation, and Plaintiff's lack of improvement over the three-year period.

The Court opined that the evidence "showed that [Plaintiff] was "unwilling or unable to implement suggestions" despite substantial professional development opportunities.

Citing Matter of Pell v Board of Educ. of Union Free School Dist. No. 1 of Towns of Scarsdale & Mamaroneck, Westchester County, 34 NY2d 222, the Appellate Division concluded that under the circumstances, termination was "not shocking to one's sense of fairness".

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

Nov 3, 2025

New York State Civil Service Department Policy Bulletin updates posted on the Internet

The New York State Department of Civil Service has published Policy Bulletins 25-01 and 25-02, updating the Governor's Programs to Hire Individuals and Veterans with Disabilities (See Civil Service Law Sections 55-b/c).

Text of Policy Bulletins 25-01 and 25-02 will be found at:
Updates to the Governor's Programs to Hire Individuals and Veterans with Disabilities (Civil Service Law Sections 55-b/c).

Policy Bulletins 25-01 and 25-02, in pdf format will be found at:
Updates to the Governor's Programs to Hire Individuals and Veterans with Disabilities (Civil Service Law Sections 55-b/c) - PDF.

To view previous Policy Bulletins issued by the Department of Civil Service, visit: https://www.cs.ny.gov/ssd/Manuals/SPMM/

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.