Jurisdiction of the Commissioner of Education to consider Taylor Law and Open Meetings Law issues
Matter of Goldin and the Wappingers Falls CSD, Decisions of the Commissioner of Education, 14043
This decision by the Commissioner of Education points out he does not have jurisdiction to resolve a dispute merely because the issue involves a school district. In this Education Law Section 310 appeal filed with the Commissioner, the issues raised concerned the terms of a collective bargaining agreement and the State’s Open Meetings Law.
After noting that Goldin’s appeal had to be dismissed for a number of procedural reasons including her failure to include all necessary parties -- the Board of Education and the Congress -- the Commissioner dismissed the appeal on the grounds that he did not have the authority to resolve these issues.
Since 1988 collective bargaining agreements between the Wappingers Central School District and the Wappingers Congress of Teachers provided that the Congress’ president, in order to conduct union business, “will teach three periods per day if he/she is a secondary teacher and will act as a substitute three days per week if he/she is an elementary teacher.”
A 1995 “side letter” signed by school superintendent John G. Marmillo and Congress president Ronald L. Warman relieved Warman of all of his teaching duties in order to allow him to conduct Congress business. The Congress was to reimburse the district in accordance with an agreed upon formula based on “60 percent of the substitute pay rate.”
Contending that the “side letter is an illegal document,” Dione Goldin filed an appeal with the Commissioner pursuant to Section 310 of the Education Law naming school superintendent John G. Marmillo and Congress president Ronald L. Warman as the respondents. She asked the Commissioner of Education to annul the side letter and order the Congress to reimburse the district the “salary for the period covered under the letter” paid to its president.
This decision demonstrates that including all the “necessary parties” is critical in prosecuting a Section 310 appeal before the Commissioner. As an example, in an appeal in which parents sought to have a school bus driver dismissed because of alleged “abusive conduct” towards students after the district declined to do so, the Commissioner said that “the parents’ failure to name the driver as a respondent required that he dismiss their appeal” [Appeal of Lippman (Holland Central School District), Decision 14041]. The decision points out that “a party whose rights would be adversely affected by a determination of an appeal in favor of the petitioner is a necessary party and must be joined as such.”
The Commissioner pointed out that “to the extent that [Goldin] seeks an order directing the Wappingers Congress of Teachers to reimburse the school district, union organizations are not subject to the jurisdiction of the Commissioner of Education under Education Law Section 310.”
Goldin also complained that the Board of Education violated the Open Meetings Law. The Commissioner said that alleged violations of the Open Meetings Law must be pursued in State Supreme Court pursuant to Article 78 of the Civil Practice Law and Rules, rather than a Section 310 appeal.
NYPPL
Summaries of, and commentaries on, selected court and administrative decisions and related matters affecting public employers and employees in New York State in particular and possibly in other jurisdictions in general.
ARTIFICIAL INTELLIGENCE [AI] IS NOT USED, IN WHOLE OR IN PART, IN PREPARING NYPPL SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS
November 24, 2010
Claim of mistake does not permit a party to rescind provisions set out in collective bargaining agreement
Claim of mistake does not permit a party to rescind provisions set out in collective bargaining agreement
Plattsburgh v Plattsburgh Police Officers Union, 250 AD2d 327, motion to appeal denied, 93 NY2d 807
Disabled firefighters and disabled police officers are entitled to significantly different benefits under New York’s General Municipal Law, Sections 207-a (firefighters) and 207-c (police officers).
If a police collective bargaining agreement dealing with disability benefits cites General Municipal Law Section 207-a as the basis for providing such benefits, does this give police officers the right to disability benefits ordinarily reserved for firefighters? And if the municipality claims the citation of GML 207-a rather than GML 207-c was an error on the part of both parties, does this mean the parties must be required to re-negotiate the contract?
The Appellate Division considered these questions in the Plattsburgh case. The City of Plattsburgh and its police officers union agreed while negotiating their 1995-1998 Taylor Law contract to include a provision -- referred to as the “207-c benefits” -- in the agreement. The contract’s “207-c benefits” clause provided that permanently disabled police officers would receive the same benefits provided permanently disabled firefighters pursuant to GML Sect. 207-a.
The benefits under 207-a and 207-c are nearly identical except for retirement salary supplements. If a firefighter is receiving an accidental or line-of-duty disability retirement allowance, the municipality must pay him or her a supplement to bring his or income up to the level of compensation that the firefighter would have earned had he or she not been disabled. This supplement is paid until the firefighter attains the mandatory age of retirement or he or she completes the period of service required before he or she could be terminated or retired. However, Section 207-c does not require municipalities to pay such salary supplements upon a disabled police officer’s retirement.
How Section 207-a became cited in the Plattsburgh police agreement is a bit of a mystery. According to court documents, city officials drafted the agreement after looking at several models provided by the union. These included police contracts that cited 207-c as well as the city’s own agreement with its firefighters, which cited 207-a. It is common practice to borrow language from reference agreements, which might explain how the 207-a benefit may have been negotiated for the police.
Plattsburgh city officials claimed they discovered the “mistaken inclusion of this [207-a] benefit” in 1966. However, nothing much happened until February 4, 1997 when a permanently disabled police officer applied for a disability benefit under the terms of the agreement.
When Plattsburgh refused to pay the benefit, the union demanded arbitration. The city asked a state Supreme Court judge, and later the Appellate Division, for a stay of arbitration. It further requested “reformation of the 207-c agreement on the ground of mutual mistake.”
The Appellate Division said that in an application for a stay of arbitration of a public sector labor dispute, two tests are applied: (1) does a statute, court decision or public policy bar arbitration of the matter in accordance with the Taylor Law? and (2) do the terms of the contract’s arbitration clause include the subject matter of the dispute?
The Appellate Division found that the parties should submit the matter to arbitration.
Plattsburgh contended that the 207-c agreement “runs afoul” of statutes prohibiting public employers and employees from negotiating with respect to any benefit provided by a public retirement system [Section 470, Retirement and Social Security Law].
The Appellate Division brushed aside that objection, holding that the contract provided 207-c benefits were not statutorily prohibited since they do not affect the benefit the individual would receive from the retirement system.
In addition, the Appellate Division pointed out that the Public Employment Relations Board had previously decided that GML Section 207-c “establishes a floor below which an employee’s benefits may not fall and, thus, a public employer may, pursuant to collective bargaining negotiations, provide benefits to their employees in excess of those provided by GML 207-c [Matter of CSEA Local 830, 23 PERB 4595].
As to Plattsburgh’s motion to stay the arbitration and hold a judicial hearing on the issue of reformation of its 207-c agreement, the Appellate Division pointed out that “the scope of the substantive provisions of the collective bargaining agreement, including the failure to reflect a meeting of the minds, is for the arbitrator to decide.”
Ultimately, the arbitrator, Howard A. Rubenstein, Esq., ruled that the language used in the collective bargaining agreement controlled and thus the City was required to provide its police officers disabled in the performance of their law enforcement duties the benefits provided firefighters mandated by General Municipal Law Section 207-a.
NYPPL
Plattsburgh v Plattsburgh Police Officers Union, 250 AD2d 327, motion to appeal denied, 93 NY2d 807
Disabled firefighters and disabled police officers are entitled to significantly different benefits under New York’s General Municipal Law, Sections 207-a (firefighters) and 207-c (police officers).
If a police collective bargaining agreement dealing with disability benefits cites General Municipal Law Section 207-a as the basis for providing such benefits, does this give police officers the right to disability benefits ordinarily reserved for firefighters? And if the municipality claims the citation of GML 207-a rather than GML 207-c was an error on the part of both parties, does this mean the parties must be required to re-negotiate the contract?
The Appellate Division considered these questions in the Plattsburgh case. The City of Plattsburgh and its police officers union agreed while negotiating their 1995-1998 Taylor Law contract to include a provision -- referred to as the “207-c benefits” -- in the agreement. The contract’s “207-c benefits” clause provided that permanently disabled police officers would receive the same benefits provided permanently disabled firefighters pursuant to GML Sect. 207-a.
The benefits under 207-a and 207-c are nearly identical except for retirement salary supplements. If a firefighter is receiving an accidental or line-of-duty disability retirement allowance, the municipality must pay him or her a supplement to bring his or income up to the level of compensation that the firefighter would have earned had he or she not been disabled. This supplement is paid until the firefighter attains the mandatory age of retirement or he or she completes the period of service required before he or she could be terminated or retired. However, Section 207-c does not require municipalities to pay such salary supplements upon a disabled police officer’s retirement.
How Section 207-a became cited in the Plattsburgh police agreement is a bit of a mystery. According to court documents, city officials drafted the agreement after looking at several models provided by the union. These included police contracts that cited 207-c as well as the city’s own agreement with its firefighters, which cited 207-a. It is common practice to borrow language from reference agreements, which might explain how the 207-a benefit may have been negotiated for the police.
Plattsburgh city officials claimed they discovered the “mistaken inclusion of this [207-a] benefit” in 1966. However, nothing much happened until February 4, 1997 when a permanently disabled police officer applied for a disability benefit under the terms of the agreement.
When Plattsburgh refused to pay the benefit, the union demanded arbitration. The city asked a state Supreme Court judge, and later the Appellate Division, for a stay of arbitration. It further requested “reformation of the 207-c agreement on the ground of mutual mistake.”
The Appellate Division said that in an application for a stay of arbitration of a public sector labor dispute, two tests are applied: (1) does a statute, court decision or public policy bar arbitration of the matter in accordance with the Taylor Law? and (2) do the terms of the contract’s arbitration clause include the subject matter of the dispute?
The Appellate Division found that the parties should submit the matter to arbitration.
Plattsburgh contended that the 207-c agreement “runs afoul” of statutes prohibiting public employers and employees from negotiating with respect to any benefit provided by a public retirement system [Section 470, Retirement and Social Security Law].
The Appellate Division brushed aside that objection, holding that the contract provided 207-c benefits were not statutorily prohibited since they do not affect the benefit the individual would receive from the retirement system.
In addition, the Appellate Division pointed out that the Public Employment Relations Board had previously decided that GML Section 207-c “establishes a floor below which an employee’s benefits may not fall and, thus, a public employer may, pursuant to collective bargaining negotiations, provide benefits to their employees in excess of those provided by GML 207-c [Matter of CSEA Local 830, 23 PERB 4595].
As to Plattsburgh’s motion to stay the arbitration and hold a judicial hearing on the issue of reformation of its 207-c agreement, the Appellate Division pointed out that “the scope of the substantive provisions of the collective bargaining agreement, including the failure to reflect a meeting of the minds, is for the arbitrator to decide.”
Ultimately, the arbitrator, Howard A. Rubenstein, Esq., ruled that the language used in the collective bargaining agreement controlled and thus the City was required to provide its police officers disabled in the performance of their law enforcement duties the benefits provided firefighters mandated by General Municipal Law Section 207-a.
NYPPL
Claim of mistake does not permit a party to rescind provisions set out in collective bargaining agreement
Claim of mistake does not permit a party to rescind provisions set out in collective bargaining agreement
Plattsburgh v Plattsburgh Police Officers Union, 250 AD2d 327, motion to appeal denied, 93 NY2d 807
Disabled firefighters and disabled police officers are entitled to significantly different benefits under New York’s General Municipal Law, Sections 207-a (firefighters) and 207-c (police officers).
If a police collective bargaining agreement dealing with disability benefits cites General Municipal Law Section 207-a as the basis for providing such benefits, does this give police officers the right to disability benefits ordinarily reserved for firefighters? And if the municipality claims the citation of GML 207-a rather than GML 207-c was an error on the part of both parties, does this mean the parties must be required to re-negotiate the contract?
The Appellate Division considered these questions in the Plattsburgh case. The City of Plattsburgh and its police officers union agreed while negotiating their 1995-1998 Taylor Law contract to include a provision -- referred to as the “207-c benefits” -- in the agreement. The contract’s “207-c benefits” clause provided that permanently disabled police officers would receive the same benefits provided permanently disabled firefighters pursuant to GML Sect. 207-a.
The benefits under 207-a and 207-c are nearly identical except for retirement salary supplements. If a firefighter is receiving an accidental or line-of-duty disability retirement allowance, the municipality must pay him or her a supplement to bring his or her income up to the level of compensation that the firefighter would have earned had he or she not been disabled. This supplement is paid until the firefighter attains the mandatory age of retirement or he or she completes the period of service required before he or she could be terminated or retired. However, Section 207-c does not require municipalities to pay such salary supplements upon a disabled police officer’s retirement.
How Section 207-a became cited in the Plattsburgh police agreement is a bit of a mystery. According to court documents, city officials drafted the agreement after looking at several models provided by the union. These included police contracts that cited 207-c as well as the city’s own agreement with its firefighters, which cited 207-a. It is common practice to borrow language from reference agreements, which might explain how the 207-a benefit may have been negotiated for the police.
Plattsburgh city officials claimed they discovered the “mistaken inclusion of this [207-a] benefit” in 1966. However, nothing much happened until February 4, 1997 when a permanently disabled police officer applied for a disability benefit under the terms of the agreement.
When Plattsburgh refused to pay the benefit, the union demanded arbitration. The city asked a state Supreme Court judge, and later the Appellate Division, for a stay of arbitration. It further requested “reformation of the 207-c agreement on the ground of mutual mistake.”
The Appellate Division said that in an application for a stay of arbitration of a public sector labor dispute, two tests are applied: (1) does a statute, court decision or public policy bar arbitration of the matter in accordance with the Taylor Law? and (2) do the terms of the contract’s arbitration clause include the subject matter of the dispute?
The Appellate Division found that the parties should submit the matter to arbitration.
Plattsburgh contended that the 207-c agreement “runs afoul” of statutes prohibiting public employers and employees from negotiating with respect to any benefit provided by a public retirement system [Section 470, Retirement and Social Security Law].
The Appellate Division brushed aside that objection, holding that the contract provided 207-c benefits were not statutorily prohibited since they do not affect the benefit the individual would receive from the retirement system.
In addition, the Appellate Division pointed out that the Public Employment Relations Board had previously decided that GML Section 207-c “establishes a floor below which an employee’s benefits may not fall and, thus, a public employer may, pursuant to collective bargaining negotiations, provide benefits to their employees in excess of those provided by GML 207-c [Matter of CSEA Local 830, 23 PERB 4595].
As to Plattsburgh’s motion to stay the arbitration and hold a judicial hearing on the issue of reformation of its 207-c agreement, the Appellate Division pointed out that “the scope of the substantive provisions of the collective bargaining agreement, including the failure to reflect a meeting of the minds, is for the arbitrator to decide.”
Ultimately, the arbitrator, Howard A. Rubenstein, Esq., ruled that the language used in the collective bargaining agreement controlled and thus the City was required to provide its police officers disabled in the performance of their law enforcement duties the benefits provided firefighters mandated by General Municipal Law Section 207-a.
NYPPL
Plattsburgh v Plattsburgh Police Officers Union, 250 AD2d 327, motion to appeal denied, 93 NY2d 807
Disabled firefighters and disabled police officers are entitled to significantly different benefits under New York’s General Municipal Law, Sections 207-a (firefighters) and 207-c (police officers).
If a police collective bargaining agreement dealing with disability benefits cites General Municipal Law Section 207-a as the basis for providing such benefits, does this give police officers the right to disability benefits ordinarily reserved for firefighters? And if the municipality claims the citation of GML 207-a rather than GML 207-c was an error on the part of both parties, does this mean the parties must be required to re-negotiate the contract?
The Appellate Division considered these questions in the Plattsburgh case. The City of Plattsburgh and its police officers union agreed while negotiating their 1995-1998 Taylor Law contract to include a provision -- referred to as the “207-c benefits” -- in the agreement. The contract’s “207-c benefits” clause provided that permanently disabled police officers would receive the same benefits provided permanently disabled firefighters pursuant to GML Sect. 207-a.
The benefits under 207-a and 207-c are nearly identical except for retirement salary supplements. If a firefighter is receiving an accidental or line-of-duty disability retirement allowance, the municipality must pay him or her a supplement to bring his or her income up to the level of compensation that the firefighter would have earned had he or she not been disabled. This supplement is paid until the firefighter attains the mandatory age of retirement or he or she completes the period of service required before he or she could be terminated or retired. However, Section 207-c does not require municipalities to pay such salary supplements upon a disabled police officer’s retirement.
How Section 207-a became cited in the Plattsburgh police agreement is a bit of a mystery. According to court documents, city officials drafted the agreement after looking at several models provided by the union. These included police contracts that cited 207-c as well as the city’s own agreement with its firefighters, which cited 207-a. It is common practice to borrow language from reference agreements, which might explain how the 207-a benefit may have been negotiated for the police.
Plattsburgh city officials claimed they discovered the “mistaken inclusion of this [207-a] benefit” in 1966. However, nothing much happened until February 4, 1997 when a permanently disabled police officer applied for a disability benefit under the terms of the agreement.
When Plattsburgh refused to pay the benefit, the union demanded arbitration. The city asked a state Supreme Court judge, and later the Appellate Division, for a stay of arbitration. It further requested “reformation of the 207-c agreement on the ground of mutual mistake.”
The Appellate Division said that in an application for a stay of arbitration of a public sector labor dispute, two tests are applied: (1) does a statute, court decision or public policy bar arbitration of the matter in accordance with the Taylor Law? and (2) do the terms of the contract’s arbitration clause include the subject matter of the dispute?
The Appellate Division found that the parties should submit the matter to arbitration.
Plattsburgh contended that the 207-c agreement “runs afoul” of statutes prohibiting public employers and employees from negotiating with respect to any benefit provided by a public retirement system [Section 470, Retirement and Social Security Law].
The Appellate Division brushed aside that objection, holding that the contract provided 207-c benefits were not statutorily prohibited since they do not affect the benefit the individual would receive from the retirement system.
In addition, the Appellate Division pointed out that the Public Employment Relations Board had previously decided that GML Section 207-c “establishes a floor below which an employee’s benefits may not fall and, thus, a public employer may, pursuant to collective bargaining negotiations, provide benefits to their employees in excess of those provided by GML 207-c [Matter of CSEA Local 830, 23 PERB 4595].
As to Plattsburgh’s motion to stay the arbitration and hold a judicial hearing on the issue of reformation of its 207-c agreement, the Appellate Division pointed out that “the scope of the substantive provisions of the collective bargaining agreement, including the failure to reflect a meeting of the minds, is for the arbitrator to decide.”
Ultimately, the arbitrator, Howard A. Rubenstein, Esq., ruled that the language used in the collective bargaining agreement controlled and thus the City was required to provide its police officers disabled in the performance of their law enforcement duties the benefits provided firefighters mandated by General Municipal Law Section 207-a.
NYPPL
November 23, 2010
Facing the Legal Dangers of Social Media – a Complimentary Webinar
Facing the Legal Dangers of Social Media – a Complimentary Webinar
Source: The Virtual LegalTech Team
The Virtual LegalTech Team has announced that a one-hour webinar entitled, "Facing the Legal Dangers of Social Media," will take place in the Virtual Auditorium at Virtual LegalTech on December 14, 2010 from 10:00 – 11:00 AM EST." The webinar session is eligible for CLE credit in certain states.*
According to the Team, "This Webinar will take a close look at the most challenging social media issues arising in the legal industry today, including:
1. The good and the bad of employees and social media;
2. Monitoring online content and combating the negatives; and
3. Preserving privilege and avoiding inadvertent contact with adversaries online."
The Team also notes that those participating in the December 14 session will be able to "chat with vendors, see product demonstrations, collect information, network with colleagues and get the latest news from the ever-evolving legal industry."
Register at http://www.virtuallegaltechshow.com/.
Registration is complimentary and use Priority Code SOCIAL1 when registering.
For additional information please go to http://alm-promotions-us.msgfocus.com/c/1fH13YdyA5u8FZO5Tc or telephone 212-457-7905
* According to the Team, Complimentary CLE will only be offered for credits in NY, CA and IL by attending the Virtual LegalTech show on December 14, 2010. CLE credit is pending in FL. Not all sessions are CLE eligible. Other terms and conditions apply. All potential participants will be contacted with further details prior to the show.
NYPPL
Source: The Virtual LegalTech Team
The Virtual LegalTech Team has announced that a one-hour webinar entitled, "Facing the Legal Dangers of Social Media," will take place in the Virtual Auditorium at Virtual LegalTech on December 14, 2010 from 10:00 – 11:00 AM EST." The webinar session is eligible for CLE credit in certain states.*
According to the Team, "This Webinar will take a close look at the most challenging social media issues arising in the legal industry today, including:
1. The good and the bad of employees and social media;
2. Monitoring online content and combating the negatives; and
3. Preserving privilege and avoiding inadvertent contact with adversaries online."
The Team also notes that those participating in the December 14 session will be able to "chat with vendors, see product demonstrations, collect information, network with colleagues and get the latest news from the ever-evolving legal industry."
Register at http://www.virtuallegaltechshow.com/.
Registration is complimentary and use Priority Code SOCIAL1 when registering.
For additional information please go to http://alm-promotions-us.msgfocus.com/c/1fH13YdyA5u8FZO5Tc or telephone 212-457-7905
* According to the Team, Complimentary CLE will only be offered for credits in NY, CA and IL by attending the Virtual LegalTech show on December 14, 2010. CLE credit is pending in FL. Not all sessions are CLE eligible. Other terms and conditions apply. All potential participants will be contacted with further details prior to the show.
NYPPL
Employee fined for using employer’s equipment for personal business
Employee fined for using employer’s equipment for personal business
Conflicts of Interest Board v Raymond McNeil, OATH Index #09-307
OATH Administrative Law Judge Faye Lewis found that former New York City procurement analyst Raymond McNeil had used his City computer and his City e-mail account for a non-City purpose – engaging in his personal business -- during normal working hours.
Judge Lewis found that McNeil had violated the New York City Conflict of Interest Board’s Rules by using his City computer to send e-mails concerning his notary public services. Further, the decision notes that “[p]roviding one’s City government e-mail address and phone number as contact information for outside employment is in conflict with the proper discharge of [the employee’s] official duties.”
Although Judge Lewis recommended that a $600 fine be imposed on McNeil, the Conflicts of Interest Board decided to impose a $2,000 fine as the penalty for violated its Rules.
The decision is posted on the Internet at:
http://archive.citylaw.org/oath/10_Cases/10-1790.pdf
NYPPL
Conflicts of Interest Board v Raymond McNeil, OATH Index #09-307
OATH Administrative Law Judge Faye Lewis found that former New York City procurement analyst Raymond McNeil had used his City computer and his City e-mail account for a non-City purpose – engaging in his personal business -- during normal working hours.
Judge Lewis found that McNeil had violated the New York City Conflict of Interest Board’s Rules by using his City computer to send e-mails concerning his notary public services. Further, the decision notes that “[p]roviding one’s City government e-mail address and phone number as contact information for outside employment is in conflict with the proper discharge of [the employee’s] official duties.”
Although Judge Lewis recommended that a $600 fine be imposed on McNeil, the Conflicts of Interest Board decided to impose a $2,000 fine as the penalty for violated its Rules.
The decision is posted on the Internet at:
http://archive.citylaw.org/oath/10_Cases/10-1790.pdf
NYPPL
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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.
NYPPL Blogger Harvey Randall served as Principal Attorney, New York State Department of Civil Service; Director of Personnel, SUNY Central Administration; Director of Research, Governor’s Office of Employee Relations; Staff Judge Advocate General, New York Guard [See also https://www.linkedin.com/in/harvey-randall-9130a5178/].
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.
New York Public Personnel Law.
Email: publications@nycap.rr.com