ARTIFICIAL INTELLIGENCE IS NOT USED, IN WHOLE OR IN PART, IN THE SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS PREPARED BY NYPPL

November 12, 2013

A candidate improperly disqualified for appointment from the eligible list does not have a right to be appointed to the title in the event he or she successfully challenges the disqualification


A candidate improperly disqualified for appointment from the eligible list does not have a right to be appointed to the title in the event he or she successfully challenges the disqualification
2013 NY Slip Op 07250, Appellate Division, First Department
 
An individual seeking an appointment as a New York City Correction Officer [Candidate] filed an administrative appeal challenging the removal of his name from the eligible list. He successfully argued that he had been improperly disqualified for the appointment and his name was again placed on the eligible list for appointment.

However, Candidate’s claim that his winning the administrative appeal “entitled him to an appointment as a correction officer” was rejected by Supreme Court.

The Appellate Division agreed.

Restoring the name of a candidate to an eligible list, even one improperly earlier removed from the list, does not obviate the application of the so-called Rule of Three, Civil Service Law §61(1). The Rule of Three authorizes the appointing authority to select of any one of three persons with the highest rankings on an eligible list willing to accept the appointment or promotion.

In the event there are more that three eligibles certified for appointment because of “tied-scores,” the appointing authority may select any one of the eligibles certified to it.

For example, in the event one candidate had a score of 95, a second candidate had a score of 90 and 20 candidates had a score of 85, the names of all 22 eligibles would be certified for appointment and the appointing authority could select any one of the 22 individuals so certified for the appointment.

In contrast, had there been 20 eligibles with a score of 95, one eligible with a score of 90 and one eligible with a score of 85, the appointing authority could select any on of the 20 candidates certified have a score of 95 but could not “reach” either the candidate with a score of 90 or with a score of 85 unless there were 18 or 19 "declinations" of the offer of appointment, as the case may be, among those eligibles attaining a score of 95..

In some instances, a collective bargaining agreement negotiated pursuant to the Taylor Law [Civil Service Law Article 14] may require the appointing authority to observe the “Rule of the List” or “The Rule of One,”* and appoint the person whose name is listed first on the certification.

As the Court of Appeals held in Cassidy v Municipal Civil Service Commission of City of New Rochelle, 37 N.Y.2d 526, Civil Service Law §61(1) grants the appointing authority broad discretion in the selection of candidates, including that of appointing a lower-scoring candidate over a higher-scoring one.

However, should the appointing authority be faced with a mandatory eligible list, it must either select one of those certified to it as standing highest on the eligible list within the meaning of the Rule of Three or elect to keep the position vacant.

Another issue considered by the Appellate Division in Candidate’s appeal focused on the refusal of DOC to have the circumstances underlying Candidate’s not being appointed to the position expunged from the record before DOC as well as expunging that portion of  DOC’s  record that indicated that that it did not to appoint him notwithstanding his name being restored to the eligible list and considering him, along with other eligibles, for appointment on three occasions.

The Appellate Division ruled that DOC’s rejection of Candidate’s request to expunge the material to which he objected from his record was neither arbitrary nor capricious and dismissed his appeal.

* Preferred and special military lists are subject to the “Rule of One” by operation of law. In this instance the appointing authority must either appoint the persons whose name is certified as "first" on the preferred or special military list or elect to keep the position vacant.

The DOC decision is posted on the Internet at:
http://www.nycourts.gov/reporter/3dseries/2013/2013_07250.htm

November 11, 2013

Employee's request for a laptop computer to use at home after surgery ruled not an accommodation request within the meaning of the ADA


Employee's request for a laptop computer to use at home after surgery ruled not an accommodation request within the meaning of the ADA
Source: Employment Law Daily - a Wolters Kluwer publication
Decision summarized by Kathleen Kapusta, J.D.

"An employee’s request for a laptop so he could work from home while recovering from surgery was a “far cry from a ‘sufficiently direct and specific’ request for an accommodation” that would put his employer on notice that he wanted assistance for his disability, the Tenth Circuit ruled in an unpublished decision.

"Accordingly, the appeals court affirmed summary judgment in favor of the employer on his ADA failure to accommodate claim.(Dinse v Carlisle Foodservice Products, Inc, November 6, 2013, Holmes, J)."

The full text of Ms. Kapusta’s article is posted on the Internet at:
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November 09, 2013

Selected reports and information published by New York State's Comptroller Thomas P. DiNapoli during the week ending November 9, 2013


Selected reports and information published by New York State's Comptroller Thomas P. DiNapoli during the week ending November 9, 2013
Click on text highlighted in color  to access the full report

Comptroller DiNapoli noted that onMonday, November 11, we will celebrate Veterans Day across the country, remembering and honoring the individuals of all ages and backgrounds who have served in the United States armed forces since our nation was born. November 11th marks the end of World War I, then known as the Great War, in 1918, a conflict intended to make the world safe for democracy in which some 4 million Americans served, 200,000 were wounded and 100,000 gave their lives. After World War II, Armistice Day was renamed Veterans Day and reconceived as a day to celebrate the dedication, patriotism and fighting spirit of all U.S. military veterans.

At local parades and other gatherings, and in our homes, Veterans Day is an opportunity for us to come together to thank the men and women who have served for their sacrifice and bravery, and to reflect upon the principles they upheld in defending the United States of America.

Comptroller DiNapoli & A.G. Schneiderman Announce Arrests of Former Monroe County Public Officials and Business Executives in Elaborate Bid–Rigging Scheme

On November 6, 2013 Comptroller Thomas P. DiNapoli and Attorney General Eric T. Schneiderman announced the indictment of four individuals for an elaborate scheme to rig the bidding process for several multimillion–dollar contracts. Nelson Rivera and Robert Wiesner, both former Monroe County public officials, along with John Maggio and Daniel Lynch, two local business executives, have been charged with a total of 43 felony counts, including Money Laundering, Conspiracy, Falsifying Business Records, Offering a False Instrument for Filing, and Combination in Restraint of Trade and Competition.


DiNapoli: Immigrants Continue to Play Key Role in New York City Economy

Immigrants in New York City accounted for $210 billion in economic activity in 2011, or about 31 percent of New York City’s gross city product, according to a reportreleased Thursday by New York State Comptroller Thomas P. DiNapoli. While immigrants were hit hard by the recession, their wages rebounded strongly and exceeded pre–recession levels two years later.


DiNapoli: Former Clerk Admits to Stealing Village Funds

The former clerk–treasurer in the Steuben County village of Riverside was arrested Friday and charged with stealing more than $40,000 in village funds, State Comptroller Thomas P. DiNapoli announced.


DiNapoli: $4 Million Availabile for Veterans to Expand Their Businesses

With Veterans Day coming, New York State Comptroller Thomas P. DiNapoli Wednesday spotlighted the availability of $4 million in competitive fixed–rate small business loans for military veterans through the New York Business Development Corp.


DiNapoli Announces $500 Million Investment in Opportunistic Portfolio Asset Class

New York State Comptroller Thomas P. DiNapoli announced on November  8, 2013 that the $160.7 billion New York State Common Retirement Fund has made the first investment in its opportunistic asset class with a $500 million separate account commitment to Blackstone Tactical Opportunities Fund.


DiNapoli Releases Quick Start State Budget Analysis for 2014–15

State Comptroller Thomas P. DiNapoli projects the state’s tax revenues will grow by 2.5 percent to $90.1 billion in state fiscal year 2014–15, according to the Comptroller's annual Quick Start reportreleased Tuesday in accordance with the Budget Reform Act of 2007.


DiNapoli’s Office to Audit SUNY Upstate Medical University’s Contracts with MedBest

New York State Comptroller Thomas P. DiNapoli announced Friday that his office has scheduled an audit of the State University of New York Upstate Medical University’s contracts with MedBest Medical Management Inc.


Comptroller DiNapoli Releases Municipal Audits

New York State Comptroller Thomas P. DiNapoli Wednesday announced his office completed audits of::




the Ethelbert B. Crawford Public Library.
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November 08, 2013

What's in a name? that which we call a rose



What's in a name? that which we call a rose*
Source: Professor Michael Froomkin, Laurie Silvers & Mitchell Rubenstein Distinguished Professor of Law, University of Miami School of Law

Professor Michael Froomkin, Laurie Silvers & Mitchell Rubenstein Distinguished Professor of Law, University of Miami School of Law, referring to a response to a motion submitted to the court by an assistant attorney general for the State of Tennessee, states “I’ve seen half-a-dozen links to this unique and amazing pleading but the world will be a better place with one more.”

Here is yet another link to the pleading. 

Professor Froomkin summaries the situation as follows:

“The setup is that the prosecutor wanted the Judge to order the defense ‘not to refer to the Assistant District Attorney General as “the Government” during trial.'" Seems they thought being called “the government” was prejudicial or derogatory or hurt their feelings or something. Defense hits it out of the park. The really good stuff starts at the bottom of page two.” 

* William Shakespeare, Romeo and Juliet

The defendant’s attorney’s Response To Government's Motion In Limine II is posted on the Internet at:
http://www.scribd.com/doc/180035586/Response-to-Government-Moving-to-Ban-the-Word-Government
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State sued for alleged defamation after publishing information depicting the plaintiff as a “sexual offender/predator”


State sued for defamation after publication of information depicting the plaintiff as a “sexual offender/predator”
2013 NY Slip Op 51814(U), Court of Claims, Judge Judith A. Hard [Not selected for publication in the Official Reports.]

In this action filed in the Court of Claims, the plaintiff [Anonymous] sought damages for alleged defamation arising out of “the State’s implementation, organization, publication, portrayal and dissemination of photographs and materials” which depicted Anonymous to third persons as a sexual offender/predator even though Anonymous was never charged with a sexual offense or convicted as a sexual offender/predator.

In her decision Judge Hard found that Anonymous proved liability by a preponderance of the credible evidence and explained the relevant law with respect to the issue before her, i.e.,  Did the publication of those statements constituted defamation? 

Defamation, said the court, "is defined as the making of a false statement which tends to ‘expose the plaintiff to public contempt, ridicule, aversion or disgrace, or induce an evil opinion of him in the minds of right-thinking persons, and to deprive him of their friendly intercourse in society.' [while] [d]efamation is the injury to one's reputation, either by written expression (libel) or oral expression (slander)."

In the words of Judge Hard “The elements of defamation are: (1) a false statement; (2) the publication of said statement without privilege or authorization to a third party; (3) fault amounting at least to negligence on the part of the publisher; and (4) the statement causes special harm or constitutes defamation per se. Publication of a photograph constitutes dissemination of information.”

In this case, the Court concluded that a State law enforcement agency's employee’s speech to the press, a press release, a media advisory and “the display of the [Anonymous’] mug shot on the wall of shame,” all of which wrongly imply that Anonymous was a sexual predator, constitute false statements. In addition, the court concluded that “the publication of said statements was not authorized.”

The issue for the court to determine: “Whether the statements were privileged, whether the fault amounts at least to negligence on the part of defendant, and whether the statements caused special harm or constitute defamation per se.”

As to “privilege,” a public official being sued for alleged slander or liable may claim an “absolute privilege” or a “qualified privilege.”

Absolute privilege protects "communications made by individuals participating in a public function, such as executive, legislative, judicial or quasi-judicial proceedings" but only extends to comments "made in the context of official communications by a principal executive of State or local government [or] those entrusted by law with considerable administrative or executive policy making responsibilities.” 

Further, Judge Hard said that “Absolute privilege attaches to actions performed by delegation on behalf of a department head of an agency, but not to those actions undertaken by an employee on their own behalf in the discharge of their own official duties.”

As to “qualified privilege,” Judge Hard said that “Press statements made by governmental representatives concerning governmental affairs are covered by such a qualified privilege. To establish such a [qualified] privilege, defendant needs to submit proof establishing that it was objectively reasonable for the defendant to believe that its conduct was appropriate under the circumstances. A [qualified] privilege will attach to statements in which the communicating party possesses a legal duty to communicate information about another, if the communicator has a good-faith belief that the information is true.”

In this action, the State did not claim an absolute privilege.

As to any “qualified privilege,” Judge Hard indicated that although a qualified privilege may apply to press statements made by governmental representatives concerning governmental affairs, the State defendant cannot avail itself of the qualified privilege defense here  because the State defendant did not submit any proof that its behavior was even remotely reasonable under the circumstances or that it had a good-faith belief that Anonymous was an online sexual predator. To the contrary, Judge Hard said that it was clear that State, through the actions of it employees, was aware that Anonymous was charged with a crime - criminal possession of a controlled substance. However, noted the court, Anonymous had not been charged with any of the internet crimes that was the subject of the press conference or press release.

Judge Hard found that “no privilege attaches to any of the alleged defamatory statements,” and then commented “… even if a qualified privilege did exist, it would be overcome by malice as [the State] recklessly disregarded the truth (i.e. that [Anonymous] was charged with criminal possession of a controlled substance) when affixing [Anonymous’] photo to the wall of shame designed to highlight online predators.”

The Court’s conclusion:

1. The State’s “fault rises at least to negligence, and further that the defamatory statements constitute defamation per sebecause they would naturally import a criminal or disgraceful charge to the mind of an intelligent person.”

2. Anonymous has proved [the] case by a preponderance of the credible evidence.

Holding that the State “is 100% liable for the defamation,” Judge Hard said that a trial on damages “shall be scheduled as soon as practicable.”

The decision is posted on the Internet at:
http://www.nycourts.gov/reporter/3dseries/2013/2013_51814.htm
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November 07, 2013

An employee’s Constitutional right against self-incrimination does not give the individual the right to answer questions untruthfully


An employee’s Constitutional right against self-incrimination does not give the individual the right to answer questions untruthfully
2013 NY Slip Op 07104, Appellate Division, Third Department

An individual [Claimant]employed by Ulster County was arrested and charged with felony and misdemeanor counts of criminal possession of a controlled substance after heroin was found in the car she was driving. The County suspended Claimant without pay from her employment pending the resolution of the criminal charges.

Claimant then applied for unemployment insurance benefits and told the Department of Labor investigator that she was on disciplinary suspension because of her arrest and that she was "not guilty of any wrongdoing in connection with the arrest." Claimant was approved to receive unemployment insurance benefits based on this information.

Subsequently Claimant was convicted of two misdemeanor counts of criminal possession of a controlled substance in the seventh degree arising out of the arrest and Ulster County terminated her employment.

Following Claimant's termination by the County, a Labor Department Administrative Law Judge (ALJ) disqualified her from receiving unemployment insurance benefits on the ground that she had been separated from employment due to her misconduct. The Unemployment Insurance Appeal Board affirmed the ALJ’s decision and ultimately Claimant was held subject to a recoverable overpayment of unemployment insurance benefits in the amount of $31,935 and a reduced right to receive future benefits by 16 effective days on the Board’s finding that she had made willful misrepresentations to obtain benefits.

Complainant appealed contending that her statement to the investigator constituted “an exercise of her constitutional right against self-incrimination for which she could not be penalized by the Board.” The Appellate Division rejected this argument, explaining that although Claimant had the right to refuse to respond to any inquiries related to her possible guilt in connection with her arrest and the criminal charges then pending against her, "neither the text nor the spirit of the Fifth Amendment confers a privilege to lie."*

In the words of the Appellate Division, “By her response to the investigator's inquiry as to whether she was, in fact, guilty of the crimes she was charged with, [Claimant] “took a course that the Fifth Amendment gave [her] no privilege to take’ and the jury's verdict convicting her of knowingly possessing heroin at the time of her arrest conclusively established the falsity of her statement denying any wrongdoing.”

The Appellate Division sustained the Board’s determination, ruling that substantial evidence supported its finding that Claimant's affirmative statement to the Labor Department's investigator that she was "not guilty of any wrongdoing in connection with [her] arrest" was a willful misrepresentation made in order to obtain benefits.

* In Bryson v. United States, 396 US 64, the Court said “Our legal system provides methods for challenging the Government’s right to ask questions – lying is not one of them. A citizen may decline to answer the question, or answer it honestly, but he [or she] cannot with impunity knowingly and willfully answer with a falsehood.”

The decision is posted on the Internet at:
http://www.nycourts.gov/reporter/3dseries/2013/2013_07104.htm
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November 06, 2013

Town adopts a local law replacing a contract disciplinary procedure applicable to town police officers pursuant to Town Law §155


Town adopting a local law replacing a contract disciplinary procedure applicable to town police officers pursuant to Town Law §155
Town of Goshen v Town of Goshen Police Benevolent Assn., 2013 NY Slip Op 23365, Supreme Court, Orange County

In Matter of Town of Wallkill v Civil Serv. Employees Assn., Inc., 19 NY3d 1066 [2012] and Matter of Patrolmen's Benevolent Assn. of City of NY, Inc. v. New York State Pub. Empl. Relations Bd., 6 NY3d 563 [2006]. the Court of Appeals considered two companion appeals involving the effect of the Rockland County Police Act in one action and the New York City Charter and Administrative Code in the other case on the relevant municipality's authority over police discipline.

The Court of Appeals held that discipline of police officers "may not be a subject of collective bargaining under the Taylor Law when the Legislature has expressly committed disciplinary authority over a police department to local officials." The Court of Appeals applied that holding in Town of Wallkill, and upheld the Town of Wallkill's local law making police discipline the subject of local authority rather than collective bargaining.

In response to disciplinary charges filed against a police officer pursuant the Town’s Local Law No. 1 of 2013, the Police Benevolent Association [PBA] demanded that the matter be submitted to arbitration.

The Town, cited the Town of Wallkill ruling in support of its initiating disciplinary action against a town police officer pursuant to the Town’s local law, asked Supreme Court to grant its petition to stay submitting the matter to arbitration based on the Town’s representation that it had, pursuant to the authority provided under Town Law §155, supplanted ”the disciplinary procedure laid out in Article 13 of the CBA [Collective Bargaining Agreement] with the disciplinary procedure set forth in Local Law No. 1 of 2013.”*

The court agreed, holding that Article 13 of the CBA is null and void and the procedures set forth in the Town's Local Law, not those of the CBA, govern police discipline in the Town and the Town's Local Law controls with respect to the disciplinary charges brought against police officers following enactment of the Local Law, provided those charges were timely brought.

The PBA then move to have the disciplinary charges filed against the police officer dismiss, contending that they were untimely, pointing out that Town Law §155 provides that disciplinary charges "shall not be brought more than sixty days after the time when the facts upon which such charges are based are known to the town board."

The PBA contend that the Town had knowledge of the facts underlying the charges more than 60 days prior to the charges being served on the police officer.**
 
In rebuttal the Town argued that the issue of timeliness of the disciplinary charges was not properly before the court. The Town also contended that, in any event, Local Law No.1 of 2013 "did not supplant the eighteen-month limitation period in the CBA agreement; it merely altered the process of noticing and hearing discipline, i.e., substituted a hearing officer for arbitrators and provided that the Town Board make the final determination."

The court agreed with the PBA, noting the statute of limitations set out in the Town Law §155 whereby disciplinary charges "shall not be brought more than sixty days after the time when the facts upon which such charges are based are known to the town board."

Here, said the court, “having successfully eliminated the arbitration provisions from the CBA, the Town cannot extend the principles that derive from arbitration agreements to its local law and decree that the question of timeliness is to be determined by the Town Board or a hearing officer selected by the Town Board. Thus, in the absence of an arbitration agreement on the issue, the timeliness of the Town's disciplinary charges is an issue for the Court to determine.

Accordingly, Supreme Court ruled that the Town’s action in bringing disciplinary action against the police officer was untimely.

* Supreme Court noted that “The Town used the Town of Wallkill's local law as a model for [its] Local Law No. 1 of 2013 and the two [local] laws are virtually identical.”

** According to the decision, the police officer had been served with the Notice of Discipline more than 120 days after the Town Board had knowledge of the facts underlying its bringing the disciplinary action.

The decision is posted on the Internet at:http://www.nycourts.gov/reporter/3dseries/2013/2013_23365.htm
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November 05, 2013

Seniority for the purposes of layoff of a Unified Court System employee is determined solely on the basis of his or her permanent service with the System


Seniority for the purposes of layoff of a Unified Court System employee is determined solely on the basis of his or her permanent service with the System
2013 NY Slip Op 07135, Appellate Division First Department

A Senior Law Librarian[Librarian] was laid off as part of a workforce reduction by the Unified Court System [UCS]. USC had determined that Librarian did not qualify for the "legal and secretarial employees providing services directly to judges" exception to the reduction. 

In response to Librarian’s petition challenging USC’s determination, the Appellate Division ruled that USC’s decision was based its interpretation of its own guidelines and “was not arbitrary and capricious, or irrational." The court explained that Librarian’s title, Senior Law Librarian, did not place him in the category of personnel directly assigned to, and serving at the pleasure of, the judges.

USC had determined Librarian’s seniority “based solely upon his years of service for the UCS” in accordance with rules promulgated by the Chief Judge and set out in 22 NYCRR 25.30[a].

22 NYCRR 25.30[a] provides that personnel are to be laid off "in inverse order of original appointment on a permanent basis in the classified service of the [UCS]." The decision notes that the Judiciary Law § 211(1)(d)'s directive that the administrative standards imposed by the Chief Judge "be consistent with the civil service law," requires only that they be guided, not governed, by it.”

The Appellate Division concluded that  22 NYCRR 25.30's provision that personnel be reduced "in inverse order of original appointment on a permanent basis in the classified service of the [UCS]" is consistent with Civil Service Law §80(1)'s requirement that employees be given a preference based upon the length of their service and that its enactment was within the judiciary's authority of self-governance in administrative matters.

Civil Service Law §80.1 provide, in pertinent part, that “Where, because of economy, consolidation or abolition of functions, curtailment of activities or otherwise, positions in the competitive class are abolished or reduced in rank or salary grade, suspension or demotion, as the case may be, among incumbents holding the same or similar positions shall be made in the inverse order of original appointment on a permanent basis in the classified service in the service of the governmental jurisdiction in which such abolition or reduction of positions occurs, subject to the provisions of subdivision seven of section eighty-five of this chapter; provided, however, that the date of original appointment of any such incumbent who was transferred to such governmental jurisdiction from another governmental jurisdiction upon the transfer of functions shall be the date of original appointment on a permanent basis in the classified service in the service of the governmental jurisdiction from which such transfer was made.”

The decision is posted on the Internet at:
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November 04, 2013

Part II of a confidential report concerning allegations of discrimination, harassment and intimidation of Schoharie County employees posted on the Internet by the County


Part II of a confidential report concerning allegations of discrimination, harassment and intimidation of Schoharie County employees posted on the Internet by the County


Part II of the Confidential Report*dated October 24, 2013 concerning allegations of discrimination, harassment and intimidation of Schoharie County employees submitted by Mark J. Fitzmaurice, Esq., of the law firm of Fitzmaurice and Welsh, White Plains, New York, to the Schoharie County Board of Supervisors has been posted on the County's web site at: http://www.schohariecounty-ny.gov/CountyWebSite/DocumentIndexing/430100000000/3661.pdf

Part I of the report prepared by Mr. Fitmaurice entitled “Confidential Final Report Concerning Discrimination, Harassment and Intimidation in the County Workplace" submitted to the Schoharie County Board of Supervisors was earlier posted by the County on the County's Internet site at 

* Parts of Part II of the report have been redacted.

November 02, 2013

Selected reports and information published by New York State's Comptroller Thomas P. DiNapoli during the week ending November 2, 2013


Selected reports and information published by New York State's Comptroller Thomas P. DiNapoli during the week ending November 2, 2013
Click on text highlighted in color  to access the full report


DiNapoli: Fire Company President Stole $34,000S

The former president of C. H. Evans Hook and Ladder Fire Company No. 3, located in the city of Hudson, misused the company’s debit card to make personal purchases totaling approximately $34,000, according to an audit released November 1, 2013 by State Comptroller Thomas P. DiNapoli. The former president, Joseph Morrison Jr., pleaded guilty on October 29, 2013 in Columbia County Court to the charge of Grand Larceny in the third degree, a class D felony.


DiNapoli Reaches Agreement with TD Ameritrade to Expand Protections Against Discrimination

TD Ameritrade Holding Corporation, one of America’s largest online brokerage firms, has agreed to amend its equal employment opportunity policy to explicitly prohibit discrimination based on sexual orientation or gender identity nationwide, New York State Comptroller Thomas P. DiNapoli announced November 1, 2013..


DiNapoli: State Fiscal Picture Stable

State spending was nearly $860 million lower than expected through the first half of the fiscal year while tax collections were just shy of projections, according to the Mid-Year Update and September cash reportreleased Wednesday by New York State Comptroller Thomas P. DiNapoli. Still, threats of another federal government shutdown and battle over the federal debt ceiling, as well as the continued slow pace of economic growth, could make it harder for the state to remain in line with its financial plan.


Comptroller DiNapoli Releases School Audits

On Wednesday, October 26, 2013 New York State Comptroller Thomas P. DiNapoli announced his office completed audits of:





the Oyster Bay–East Norwich Central School District.
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