Steen v. Governor's Office of Employee Relations
Petitioners, employed as Recreation Workers and Therapists at Pilgrim Psychiatric Center, were assigned new duties as "Treatment Plan Coordinators" under the "Buffalo Model" program. These new responsibilities included transcribing patient information, conducting patient interviews, entering data into worksheets, and performing 90-day progress reviews. Believing these tasks constituted out-of-title work typically performed by higher-grade Treatment Team Leaders, petitioners filed administrative grievances, which were consistently denied by the Governor's Office of Employee Relations. Subsequently, petitioners commenced a CPLR article 78 proceeding, but the Supreme Court dismissed their application, upholding the administrative determination. On appeal, the higher court found no rational basis for the administrative conclusion that the duties were a logical extension of petitioners' original roles, determining that the work was indeed out-of-title. Consequently, the judgment of the Supreme Court was reversed, the administrative determination annulled, and the petition granted.