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

December 15, 2017

Paid Family Leave

Paid Family Leave
Source: New York State Department of Labor

 
Effective January 1, 2018, most employees who work in New York State for private employers are eligible to take Paid Family Leave, [see Workers' Compensation Law §200 et. seq., The Disability Benefits Law and the Paid Family Leave Benefits Law]. In addition, many public employers provide Paid Family Leave.

New York’s paid family leave law provides job-protected, paid time off so employees can bond with a newly born, adopted or fostered child; care for a close relative with a serious health condition; or assist loved ones when a family member is deployed abroad on active military service.

The employee is able to continue his or her health insurance while on leave and is guaranteed the same or a comparable job after the leave ends. If the employee contribute to the cost of health insurance, he or she must continue to pay the premium cost while on Paid Family Leave. 

Information for employers is posted on the Internet at: https://paidfamilyleave.ny.gov/paid-family-leave-information-employers
 
Information for employees is posted on the Internet at: https://paidfamilyleave.ny.gov/paid-family-leave-information-employees

Information for health care providers is posted on the Internet at: https://paidfamilyleave.ny.gov/paid-family-leave-information-health-care-providers
 
Additional New York Paid Family Leave Law information is available on the Internet at: https://paidfamilyleave.ny.gov/


December 14, 2017

FMLA Law News Update December 2017


FMLA Law News Update December 2017
Source: | December 13, 2017

Click on text highlighted in color to access the full report

Timing Is Everything: FMLA Claim Survives Summary Judgment …
The National Law Review-Nov 21, 2017
Employees requesting, currently taking, or just returning from leave under the Family and Medical Leave Act (“FMLA”) can be terminated for legitimate reasons that are unrelated to their FMLA leave. This point is exemplified by
Jennings v. Univ. of N.C., N.C. Ct. App., Case No. COA16-1031 (July 5, 2017), …

Reassignment can be post-FMLA accommodation
Business Management Daily-Dec 11, 2017
When a disabled employee wants to return to work, limitations may make it impossible for him to do his old job. If so, it may be reasonable to either grant more leave or reassign the employee—or both. The worker may prefer another accommodation, but it’s the employer’s choice. Recent case:
Gary

FMLA FAQ: If an Employee Racks Up Both FMLA and Unexcused …
Lexology-Dec 8, 2017
Mary Beth is a nurse for a local hospital and has been diagnosed with cancer and asthma. Over the course of about one year: 1. She is certified for FMLA leave for her cancer and asthma;. 2. She incurs a total of 13 intermittent absences in a 12-month period;. 3. A handful of these absences relate to her …

Terminated employee's civil rights violation claim dismissed pursuant to the doctrine of res judicata


Terminated employee's civil rights violation claim dismissed pursuant to the doctrine of res judicata
Russo v. City of New York, USCA, 2nd Circuit,  17-233-CV*

United States District Court for the Eastern District of New York  dismissed Anthony J. Russo's claim brought under 42 U.S.C. §1983. The district court sua sponte** dismissed Russo’s complaint pursuant to 28 U.S.C. §1915(e)(2)(B) and the doctrine of res judicata.***

Russo had been terminated by the New York City Board of Education as the result of an arbitration conducted pursuant to §3020-a of the New York State Education Law. Although Russo brought a CPLR Article 75 action challenging the arbitration award in New York State Supreme Court, the award was ultimately affirmed by the New York State Court of Appeals.

The Second Circuit affirmed the district court dismissal Russo’s complaint and the denial of his motion for reconsideration on the ground that Russo’s claims are barred by the doctrine of claim preclusion. We note at the outset that “the failure of a defendant to raise res judicata does not deprive a court of the power to dismiss a claim on that ground” in large part because of “the strong public policy in economizing the use of judicial resources by avoiding relitigation.

The Circuit Court then found that the dismissal Russo's petition on the basis of res judicata was appropriate in this case because Russo raises claims that are premised entirely on the same set of facts and alleged misconduct as the facts and misconduct alleged in his state court action, and because the initial state forum had the power to award the full measure of relief sought in this §1983 action.

Further, said the court, "even though Russo’s federal claims were not raised and litigated in his state action, there was no error in the district court’s decision to dismiss these claims on the grounds that they were barred by the state court judgment."

*N.B. Summary order - rulings by summary order do not have precedential effect. Citation to a summary order filed on or after January 1, 2007, is permitted and is governed by federal rule of appellate procedure 32.1 and the 2nd Circuit's local rule 32.1.1.

** An action taken by the court without a formal motion by a party.

*** A matter that has been adjudicated by a court of competent jurisdiction and as a result not be relitigated further by the same parties.

The decision is posted on the Internet at:


December 13, 2017

Selected reports posted in Employment Law News by WK Workday


Selected reports posted in Employment Law News by WK Workday
Source: Wolters Kulwer

Selected reports posted by WK Workday December 13, 2017
Click on text highlighted in color to access the full report 





Possessing “over-the-counter and, or, prescription drugs or harmful substances” on school property


Possessing “over-the-counter and, or, prescription drugs or harmful substances” on school property
Decisions of the Commissioner of Education, Decision No. 17,269

The lunch bag belonging to a student [W.H.] who is the subject of this appeal was found to have in it "over the counter medication.”  The principal advised W.H.'s parents [Petitioners ] that W.H. would be suspended for three days based upon his possession of “over the counter medication.” Petitioners told the principal that the pills were “vitamin C, Olive Leaf extract and Echinacea supplements.” 

The principal advised Petitioners that, in accordance with school policy, over the counter medications must be authorized by parents and physicians and may only be administered by the school nurse.  The principal requested that the student be immediately picked up from school. The school principal then advised Petitioners that W.H.'s possession of the supplements violated the portion of Marathon Central School District's code of conduct prohibiting “conduct that endangers the safety, morals, health, or welfare of others.”  A second letter described the supplements as “unknown substances” and noted that the student “admitted to having them in his possession.”

Petitioners subsequently met with the superintendent and the principal and explained that [1] they were aware of the district's policy concerning the administration of over-the-counter medications and [2] the pills which the student possessed were nutritional supplements, which the Food and Drug Administration considers food, not drugs. 

The superintendent declined to modify the student’s three-day suspension, and Petitioners thereafter appealed to school board. The president of the school board told Petitioners that the board had considered their appeal and upheld the three-day suspension and Petitioners appealed to the Commissioner seeking to have the student’s suspension be expunged from his record.

After considering a number of procedural issues, the Commissioner considered the merits of Petitioners' appeal and said that "in an appeal to the Commissioner, a petitioner has the burden of demonstrating a clear legal right to the relief requested and the burden of establishing the facts upon which petitioner seeks relief."

In this instance the Commissioner found that Petitioners had "met their burden of proof to show that [the school board's] decision was arbitrary and capricious. The Commissioner explained that Petitioners asserted, and the school board has not refuted, that the student possessed vitamins and herbal supplements which the Food and Drug Administration classifies as foods, not drugs.  Further, Petitioners admitted that they were and are aware of the school district's policy which prohibits the possession of “over-the-counter and, or, prescription drugs or harmful substances,” but contended that the “food” possessed by the student did not fall into any of these categories. 

In contrast the Commissioner found that the school board had not submitted any proof to refute Petitioners’ allegations or establish that the vitamins and herbal supplements at issue were over-the-counter drugs or harmful substances within the meaning of its policy that would support a finding that the student engaged in “conduct that endanger[ed] the safety, morals, health or welfare of others.”

Accordingly, the Commissioner ruled that "on this record" Petitioners have met their burden of proving that the student’s conduct was not prohibited by any portion of school board's code of conduct and ordered that W.H.'s suspension "be expunged from his record."

In addition, the Commissioner observed that:

1. Although the school district had argued that the supplements were subject to prohibition as “look-alike” drugs, this rationale is not supported by the evidence in the record as the school board had not established on this record that its code of conduct prohibits the possession of “look-alike” drugs or that the principal, superintendent or the school board relied upon such reasoning in imposing or upholding W.H.'s disciplinary penalty. 

2. Although the school board failed to demonstrate on this record that its code of conduct prohibits possession of vitamins, herbal supplements or “look-alike” drugs, nothing in this decision should be construed as prohibiting the school district from adopting a code of conduct which clearly apprises students and parents that students may be subject to discipline for the unauthorized possession of nutritional supplements, herbal remedies or look-alike drugs.

The decision is posted on the Internet at:


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; and Staff Judge Advocate General, 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.
New York Public Personnel Law. Email: publications@nycap.rr.com