Matter of Awe v. D'Alessandro
Margaret Awe, a dual employee of both New York State and New York City, sought to have her combined salaries aggregated for pension benefit calculations upon retirement. The New York City Employees' Retirement System (NYCERS) declined, considering only her City salary. Awe initiated a CPLR article 78 proceeding, which the Supreme Court granted, annulling NYCERS's determination. However, the Appellate Division reversed this judgment, confirming NYCERS's original determination. The court ruled that NYCERS's refusal to aggregate salaries from state and city employment was not arbitrary and capricious, citing statutory requirements that aggregated salaries must stem from 'city-service,' which her state employment was not.