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

August 03, 2023

Exchanging sexually-explicit text messages with individuals while on duty held to constitute misconduct within the meaning of Civil Service Law §75

In accordance with Civil Service Law §75, the Appointing Authority [Respondent] notified an employee [Petitioner] that he was charged with two specifications of misconduct.

Specification 1 alleged that, during a period of time when Petitioner was on duty, "[Petitioner] failed to devote all of [his] time and attention to the performance of [his] duties in violation of [certain provisions set out in the Respondent's] Employees' Manual...."

Specification 2 alleged that during that same time period, "[Petitioner] failed to model appropriate conduct, ethics, and performance ... in violation of [certain provisions set out in the Respondent's] Employees' Manual ...."

Petitioner denied the allegations and a Civil Service Law §75(2) disciplinary hearing was conducted. At the conclusion of the hearing the Hearing Officer issued a determination finding Petitioner guilty of both Specifications and recommended that Petitioner be dismissed from service. Respondent adopted the Hearing Officer's findings and recommendation as to the penalty to be imposed and dismissed Petitioner from service. 

Petitioner then commenced a CPLR Article 78 proceeding in Supreme Court seeking a court order annulling the Respondent's determination on the grounds that [1] the record lacked substantial evidence to support the findings that he engaged in misconduct and [2] that the penalty of termination was disproportionate to the offenses alleged. Supreme Court transferred the matter to the Appellate Division.

Addressing the penalty imposed on Petitioner, the Appellate Division, noted that the Petitioner's record established that Petitioner consistently received "strong evaluations for his work performance" and that Petitioner had "expressed remorse and that he was not proud of his conduct." Citing Matter of Gulotta v New York State Thruway Auth., 174 AD3d 1205, the majority of the court, Lynch, J. dissenting, opined that the penalty of termination "is so disproportionate to the offense and shockingly unfair as to constitute an abuse of discretion as a matter of law" under the circumstances.* 

The Appellate Division, "annulling so much [of the Respondent's decision] as imposed a penalty of termination," remitted the matter to the Respondent for the Respondent "to consider imposing a less severe penalty" on Petitioner.

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

* A Reasonable Disciplinary Penalty Under the Circumstances - a 442-page volume focusing on determining an appropriate disciplinary penalty to be imposed on an officer or employee in the public service in instances where the individual has been found guilty of misconduct or incompetence. Click HERE for more information. 

 

August 02, 2023

Claimant for Workers' Compensation benefits has the burden of establishing a causal connection between his alleged psychological injury and his employment

A train conductor [Claimant] for a self-insured employer filed a claim for workers' compensation benefits. Claimant alleged that notwithstanding his high-risk of exposure to the COVID-19 coronavirus and an unsafe work environment, he was not provided with adequate personal protective equipment by his employer. This, Claimant contended, resulted in anxiety and his preexisting psychiatric conditions were exacerbated. The employer controverted the claim.

A Workers' Compensation Law Judge [WCLJ] disallowed the claim, finding that the stress that Claimant was under was the same as other similarly situated workers during the COVID-19 pandemic. The Workers' Compensation Board affirmed the WCLJ's decision.* Claimant appealed the Board's ruling.

The Appellate Division sustained the Board's determination. Citing  Matter of Novak v St. Luke's Roosevelt Hosp., 148 AD3d 1509, the court, noting "[it] is well settled that a mental injury arising from work-related stress is compensable", pointed out that in order to receive benefits the claimant has the "burden of establishing, by competent medical evidence, that a causal connection exist[s] between [his or] her [psychological injury] and [his or] her employment".** However, opined the court, "[for] a mental injury premised on work-related stress to be compensable, a claimant must demonstrate that the stress that caused the claimed mental injury was greater than that which other similarly situated workers experienced in the normal work environment".

The question of whether the stress experienced by a claimant is more than that normally encountered is a factual question for the Board to resolve, and its finding will not be disturbed by the court when supported by substantial evidence and courts "defer to the Board's credibility assessments".

Finding that substantial evidence supported the Board's factual finding that neither "Claimant's fear of contracting COVID-19," which the Board concluded was "a fear likely experienced by all [t]rain [c]onductors in March of 2020," nor his work environment and duties "resulted in stress greater than that experienced by similarly situated train operators during the pandemic," as "exposure to COVID-19 was a risk being experienced by all train conductors in March 2020 as part of their normal duties".

The Appellate Division also noted that Claimant's reliance on cases involving infectious diseases contracted at work was misplaced "as he did not contract COVID-19 at work."

* The Workers' Compensation Appeals Board rescinded the WCLJ's finding to the extent that it was premised on a determination that claimant was an "essential worker," finding that it had no bearing on his claim for workers' compensation benefits. 

** See Matter of Issayou v Issayuou Inc., 174 AD3d 1277.

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

See, also, Matter of Djanuzakov v Manhattan & Bronx Surface Tr. Operating Auth. posted on the Internet at https://www.nycourts.gov/reporter/3dseries/2023/2023_03893.htm and In the Matter of the Claim of Tracey Brown, Appellant, v New York City Transit Authority, Respondent. Workers' Compensation, posted on the Internet at https://www.nycourts.gov/reporter/3dseries/2023/2023_03888.htm .


August 01, 2023

Inside Higher Education's free comprehensive resource addressing the Supreme Court's landmark affirmative action ruling available for "downloading"

On August 1, 2023, Inside Higher Ed announced it free booklet, "The Ruling Explained: The Future of Affirmative Action in Higher Education, which it  described  as "a comprehensive resource comprised of articles and essays covering and responding to the Supreme Court's landmark ruling against affirmative action."

Click the box below to obtain a copy of this booklet:

Download Today »
Inside Higher Ed  reports the articles contained in this booklet explore:
  • The immediate impact of the decision on college admissions
  • The ongoing debate on whether the decision extends to financial aid, potentially affecting a broader range of colleges
  • The strategies being considered by colleges to attract diverse students without giving preferential treatment to minority applicants
  • The possibility of colleges admitting more transfer students from community colleges as a direct result of the ruling
  • The examination of whether colleges with legacy admissions programs, which predominantly benefit white applicants by favoring the children of alumni, will choose to eliminate such programs

New York State Comptroller DiNapoli releases audits

New York State Comptroller Thomas P. DiNapoli announced the following audits and reports were issued on July 31 2023.

Click on the text highlighted in color to access the entire audit report.

 

State Education Department (Preschool Special Education Audit Initiative) – Step Up Therapy Services, PLLC – Compliance With the Reimbursable Cost Manual (2021-S-31)

Step Up, a New York City-based not-for-profit organization, is approved by the State Education Department to provide preschool special education itinerant teacher services to children with disabilities who are between the ages of three and five years. For the three fiscal years ended June 30, 2015, Step Up reported approximately $7.4 million in reimbursable costs for the SED preschool cost-based program. Auditors identified $810,382 in reported costs that did not comply with requirements.

 

Department of Health – Improper Supplemental Maternity Capitation Payments to Managed Care Organizations (Follow-Up) (2023-F-3)

Many of the State’s Medicaid recipients receive their services through managed care, whereby the Department of Health (DOH) pays managed care organizations (MCOs) a monthly premium for each enrolled recipient and, in turn, the MCOs pay for services their members require. In addition to the monthly premiums, MCOs can receive a one-time Supplemental Maternity Capitation Payment (SMCP) for the prenatal and postpartum physician care and hospital or birthing center delivery costs associated with the maternity care of a recipient. MCOs are not eligible to receive SMCPs for maternity cases that end in termination or a miscarriage, as these are considered reimbursed to the MCO through the monthly premium for the recipient, and must submit encounter claim data as evidence of the delivery and any other inpatient and outpatient maternity services provided.

A prior audit report, issued in November 2021, found about $55 million in improper and questionable SMCPs to MCOs. Auditors also determined DOH’s eMedNY claims processing system did not have access to maternity encounter data to verify that SMCP claims were eligible for reimbursement. Instead, DOH relied on audits by the Office of the Medicaid Inspector General (OMIG) to identify and recoup inappropriate SMCPs. However, auditors found OMIG was not performing these audits in a timely manner and the audits did not capture all improper SMCPs.

The follow-up found that DOH made some progress in addressing the problems identified in the initial audit report, but additional actions are still required. For example, a significant portion of the questionable claims identified have not been reviewed, and DOH has not followed up with the 10 MCOs identified in the initial audit to ensure issues with their claims processing systems were resolved. Of the initial report’s six audit recommendations, three were partially implemented, and three were not implemented.

 

Metropolitan Transportation Authority – Fare Evasion (Follow-Up) (2022-F-23)

For 2018, the Metropolitan Transportation Authority (MTA) reported a total of $225 million in revenue loss due to fare evasion at New York City Transit (Transit) and MTA Bus. Among other actions, the MTA launched the Fare Enforcement and Worker Safety Program (Program) to deter fare evasion. A prior report, issued in April 2021, found that the MTA did not provide assurance that the Program was effective in achieving its goal of reducing annual fare evasion losses below 2017 levels ($150 million). Instead, Transit estimated that it lost more than $300 million to fare evasion in 2019. Since the initial report was issued, the subway and bus fare evasion rates have increased. The first quarter of 2023 (January–March) saw an increase of 11.1% (± 0.9%) for subways and an estimated increase of 37.6% for buses. After the audit’s release, the MTA created a Blue-Ribbon Panel to reduce fare evasion across the MTA system. On May 17, 2023, the panel released its report, which incorporates several of the recommendations of the initial audit report. The follow-up found that the MTA made progress in addressing the issues identified in the initial audit. Of the initial report’s 19 audit recommendations, 13 were implemented, four were partially implemented, one was not implemented, and one is no longer applicable.

 

State Board of Elections – Use of Federal Funding for Election Technology and Security (Follow-Up) (2022-F-35)

The Help America Vote Act of 2002 (HAVA) was enacted to help reform the nation’s voting process. In June 2018, the Board of Elections (BOE) received $19.5 million in HAVA funding to improve and enhance election administration, technology, and security, including $3.3 million that it designated to reimburse County Boards for their remediation activities. A prior audit, issued in September 2021, found the BOE utilized HAVA funding appropriately. However, of the 57 County Boards, only seven had submitted claims for reimbursement, showing that they had moved forward with the needed security measures. The follow-up found that BOE has made significant progress addressing the issues identified, having implemented the one recommendation from the initial report to ensure County Boards take the necessary action to improve security.

 

New York City Department of Buildings – Oversight of Sidewalk Sheds (Follow-Up) (2022-F-36)

The New York City Department of Buildings (DOB) is responsible for regulating the safe and lawful use of more than 1 million buildings and construction sites in the city, including sidewalk sheds (sheds) – temporary structures installed and maintained to protect people and property on city sidewalks during the construction, demolition, and maintenance of buildings. A prior audit report, issued in July 2021, found that DOB was not adequately overseeing and monitoring the timely installation and removal of sheds or ensuring that sheds were properly maintained. For example, the audit found unsafe façades with no installed sheds, sheds with hazardous conditions, and sheds without valid operating permits. The follow-up found that DOB has made limited progress in addressing the problems identified in the initial audit. Of the initial report’s 15 recommendations, four were implemented, two were partially implemented, and nine were not implemented.

 

Division of Homeland Security and Emergency Services – Cyber Incident Response Team (Follow-Up) (2023-F-8)

In 2017, the Cyber Incident Response Team (CIRT) was created within the Division of Homeland Security and Emergency Services (DHSES) to provide cybersecurity support to more than 2,800 non-Executive agencies, local governments, and public authorities in New York. A prior audit report, issued in November 2021, found that CIRT developed lines of service to guide its work – cyber incident response services, technical cyber services, and information sharing and outreach – but did not establish specific and measurable objectives or quantifiable goals that could be measured to evaluate its accomplishments. The follow-up found that DHSES made progress in addressing the issues identified in the initial audit report; however, additional actions are needed. Of the initial report’s two audit recommendations, one was implemented and one was partially implemented.

 

New York State Health Insurance Program – UnitedHealthcare Insurance Company of New York: Improper Payments for Acupuncture and Acupuncture-Related Services (Follow-Up) (2023-F-14)

The Department of Civil Service (Civil Service) contracts with UnitedHealthcare Insurance Company of New York (United) to administer the Empire Plan’s medical/surgical benefits, including acupuncture and acupuncture-related services such as heat and massage therapy. A prior audit report, issued in October 2021, identified $7.3 million in actual and potential overpayments for services that were not supported by provider documentation and for duplicate payments. The follow-up found that United made minimal progress in addressing the issues identified in the initial audit. At the time of the follow-up, United had recovered only $14,281. Further, United was not able to provide evidence of additional control enhancements designed to prevent duplicate payments. Of the initial report’s four recommendations, one was implemented, two were partially implemented, and one was not implemented.

 

Establishing a cause of action based on negligent hiring, negligent retention, or negligent supervision

In this action to recover damages for alleged employment discrimination in violation of the New York State Human Rights Law and the New York City Human Rights Law filed by two teachers [Plaintiffs] employed by the New York City Department of Education [DOE], DOE moved to dismiss Plaintiffs' seeking recover damages from DOE for alleged negligent hiring, training, and supervision of one of its employees. Supreme Court granted DOE's motion and Plaintiffs appealed the court's decision.

The Appellate Division sustained Supreme Court's granting this motion by DOE for Plaintiffs' failure "to state a cause of action." 

Citing S.C. v New York City Dept. of Educ., 97 AD3d 518, 519-520, quoting Shor v Touch-N-Go Farms, Inc., 89 AD3d 830, the Appellate Division explained that in order "[to] establish a cause of action based on negligent hiring, negligent retention, or negligent supervision [of an employee], it must be shown that the employer knew or should have known of the employee's propensity for the conduct which caused the injury."

The Appellate Division opined that Supreme Court properly directed the dismissal of that branch of the Plaintiffs' complaint as Plaintiffs failed to sufficiently allege that DOE knew or should have known of its employee's propensity to commit the wrongful acts "alleged in the second amended complaint." Further, the Appellate Division noted that Plaintiffs' submissions in opposition to DOE's motion failed to remedy this defect.

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

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