Petitioner appealed a Federal District Court’s dismissal of his complaint as frivolous "sua sponte"

In this pro se action, Petitioner's [Plaintiff] voluminous allegations referenced numerous presidents of the United States, public officials, and celebrities, and described violent and sexually explicit events. The Federal District Court, sua sponte, dismissed Plaintiff's complaint, concluding that the allegations reflected delusion or fantasy, and then denied Plaintiff's motion for leave to amend his complaint as futile. Plaintiff appealed the lower court's action.

The Second Circuit Court of Appeal sustained the lower court's ruling, opining that a complaint is frivolous when either: 

(1) "the factual contentions are clearly baseless, such as when allegations are the product of delusion or fantasy; or 

(2) "the claim is based on an indisputably meritless legal theory."

The Circuit Court, noting that Plaintiff's allegations recited Plaintiff's implausible associations with "numerous former presidents, public officials, and celebrities", affirmed the Federal District Court's ruling.

In addition, the Circuit Court said that the "district court also properly denied [Plaintiff's] request to amend the complaint", explaining that "Repleading would be futile because there is no indication that 'a chance to reframe' would cure the complaint’s substantive deficiencies". 

Click HERE to access the Circuit Court of Appeals' decision posted on the Internet.

Selected Internet posting made during the week ending January 24, 2026

At the beginning of each year, Governing writers and editors compile a list of the biggest issues to watch in state and local government in the coming 12 months. Here are some of the biggest issues to watch in the states in 2026. Click to Read 

Modernize Government Payouts for Better Service Discover how agencies can deliver fast, secure and equitable payments. READ MORE

Navigating Dash Cams: A Guide for Union Engagement Navigating union concerns around dash cams? This guide shows public sector leaders how to build trust, address privacy head-on, and create fair policies that support both safety and morale. DOWNLOAD

Stopping Next-Gen Identity Fraud How AI-enabled identity tools and concerns around dash cams? This guide shows public sector leaders how to build trust, address privacy head-on, and create fair policies that support both safety and morale. DOWNLOAD 

CIO Essentials: Vital Priorities for a Transforming Landscape State and local government CIOs are leading through rapid change. Their remit is expanding as AI, data and cybersecurity reshape government. This paper discusses the four core priorities CIOs must focus on to meet this moment: modernizing legacy systems, advancing data and AI maturity, leading enterprise security and driving operational efficiency. DOWNLOAD

The Top 6 Cybersecurity Threats to the Public Sector
Cybercriminals tactics are evolving, and public sector agencies remain squarely in the crosshairs. This report breaks down the six most urgent cybersecurity threats government teams face and how to strengthen digital resilience in response. DOWNLOAD

Five Ways Government Leaders Boost Transparency and Trust Learn how public-sector agencies strengthen community confidence through improved transparency and accountability. READ NOW

From the Trenches: Why Every Government City Manager Needs Better Meeting Documentation Poor documentation erodes trust and slows government action; modern tools help preserve institutional memory. READ NOW

How Smart Police Stations Are Redefining Public Service Self-service kiosks are helping law enforcement agencies deliver faster, clearer service by digitizing high-impact workflows and reducing front-desk demands. READ NOW

Future Forward Government A space created for state and local IT leaders and decision-makers who are charting the course of tomorrow's public sector. EXPLORE

How data analytics and AI in government can drive public value Governments understand the potential of data and AI, but the cost of inaction grows daily. Learn from government “pioneers.”

Use AI to simplify grant application efforts. Improve funding while freeing your grant team to pursue additional funding avenues. Request a demo

2026 Public Safety Trends Report The 2026 Public Safety Trends Report delivers five critical insights from frontline voices across the U.S. and U.K. Learn how leading agencies are using AI, cybersecurity, data, and unified systems to strengthen response, improve morale, and operate with more clarity and confidence. DOWNLOAD

Simplifying Service Delivery for All: How to Implement Self-Service Tools in Government This publication explores how self-service solutions can transform interactions with government, making services more accessible while reducing administrative burden behind the scenes. DOWNLOAD

The 2026 State of Online Payments This sixth annual report delivers essential insights into how, when, and why Americans are paying their bills digitally. DOWNLOAD

New York State's Comptroller reports 31 school districts designated as being in "fiscal stress"

On January 22, 2026, New York State Comptroller Thomas P. DiNapoli’s Fiscal Stress Monitoring System reported that tirty-one school districts were designated in some level of fiscal stress under the New York State Comptroller's Fiscal Stress Monitoring System for the school fiscal year (SY) ending June 30, 2025, up from 22 districts in fiscal stress so designated in the previous school fiscal year.

“In recent years, pandemic-related federal funding as well as increases in state aid have provided districts with significant financial support,” DiNapoli said. “With much of the relief funding having been spent, the number of school districts in fiscal stress has returned to pre-pandemic levels this year. As districts continue to adjust to these conditions, officials should make every effort to ensure budgets are structurally balanced to avoid fiscal problems going forward.”

From SY 2019-20 to 2024-25, school districts spent $4 billion of the nearly $4.6 billion in available federal pandemic relief funding. With this funding dwindling, in SY 2024-25, districts reported spending only $317 million in combined federal pandemic relief funding, a decrease of over 70% from SY 2023-24.

Of the 669 school districts that filed their financial reports in time to be scored in SY 2025, 4.6% have been designated as being in a level of fiscal stress, compared to 3.3% in SY 2024.

DiNapoli’s Fiscal Stress Monitoring System was designed to identify school districts, counties, cities, towns and villages that are having difficulties with budgetary solvency, or the ability to generate enough revenue to meet expenses. School districts receive a fiscal stress score that is based on several factors: year-end fund balance, operating deficits, cash position, and reliance on short-term debt for cashflow. The higher the score, the more severe the level of stress.

This release of scores, which excludes New York City and the “Big Four” City School Districts of Buffalo, Rochester, Syracuse and Yonkers, designated two school districts in “significant fiscal stress,” the highest category – Harrisville Central School District in Lewis County and Mount Vernon School District in Westchester County. Four districts were designated as being in “moderate fiscal stress” and 25 districts were designated as “susceptible to fiscal stress.”

Regionally, the Mohawk Valley had the highest percentage of school districts with a stress designation (10.9%), followed by Central New York (10.4%) and the North County (7%).

In addition, DiNapoli’s report identified 24 chronically stressed school districts which have been designated in a category of stress for five or more years since SY 2012-13, although they may not currently be designated in a level of stress.

DiNapoli urges district officials to take advantage of the resources available to them to monitor factors affecting fiscal stress. These include the Comptroller’s self-assessment tool and financial toolkit, which offer guidance, resources, training and reports, to help officials manage through complex fiscal circumstances.

Lists
School Districts in Stress for Fiscal Year Ending 2025
Complete List of School District Fiscal Stress Scores

Report
Fiscal Stress Monitoring System: School Districts Fiscal Year 2024-25 Results

Judicial review of a determination made by an administrative agency without the agency holding a quasi-judicial hearing is limited

In reviewing a determination of an administrative agency not made after a quasi-judicial hearing, the Appellate Division noted that the reviewing court's inquiry is limited to determining whether the administrative decision:

1. Is arbitrary and capricious; 

2. Without a rational basis in the record; and 

3. Has a reasonable basis in law.

The Appellate Division observed that "An agency's interpretation of the statutes and regulations that it administers is entitled to deference, and must be upheld if reasonable".

Further, the court opined that "The agency's determination need only be supported by a rational basis", noting that "An administrative determination is arbitrary and capricious when it exceeds the agency's statutory authority or is made in violation of the Constitution or laws of this State".

In the words of the Appellate Division: "If the agency's determination is rationally based, a reviewing court may not substitute its judgment for that of the agency even if the court might have decided the matter differently" as it is not "for a reviewing court to weigh the evidence or reject the choice made by the agency where the evidence conflicts and room for choice exists ."

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

2026 Paid Family Leave webinar series for employers and HR professionals

The New York State Workers’ Compensation Board is hosting a Paid Family Leave (PFL) webinar specifically for "employers and HR professionals" to share What’s New for 2026", including:

• the higher maximum weekly benefit amount, and
• the updated employee contribution rate.

Each one-hour, online session, will also provide an overview of New York State’s landmark PFL benefits, including:

• who is eligible,
• how employees take it, and
• employers’ role in the process.

The sessions are free and there will be time at the end for questions. Each session covers the same content, and interested individuals are invited to choose the date that works best for them. 

PFL for employers and HR professionals are schedule to be held on:

 

Thursday, January 29, 2026 12:00 p.m. - 1:00 p.m.

Register here 

Wednesday, March 18, 2026 12:00 p.m. - 1:00 p.m.

Register here