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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Scazafavo v. Erie County Water Authority

Petitioner, a meter service worker, challenged the termination of his employment following three acts of insubordination, stemming from his refusal to undergo a random drug test. He argued that as an employee with a noncommercial driver's license, company policy exempted him from such testing. Despite his union representative advising compliance with the "work now, grieve later" rule, the petitioner maintained his refusal. The court found substantial evidence to support the insubordination charges, noting the petitioner's concession of refusal. It also concluded that the termination penalty was not disproportionate, considering his 11-year tenure, past absenteeism, and a prior drug possession conviction. The court confirmed the determination and dismissed the petition.

insubordinationemployment terminationdrug testingCPLR article 78public sector employmentdisciplinary actionsubstantial evidencepenalty reviewworkplace policyunion advice
References
2
Case No. MISSING
Regular Panel Decision
May 02, 1973

Reeves v. Golar

A probationary patrolman's employment with the New York City Housing Authority was terminated following suspicions of narcotic use, despite his claims of medication-related quinine traces and denial of unlawful drug use. His requests for medical test reports and a thorough medical examination were denied, leading to an informal hearing and subsequent termination. The court questioned the arbitrary and capricious nature of the dismissal, highlighting that the termination was based on unproven drug use rather than work performance. Citing due process concerns under the Fourteenth Amendment regarding the petitioner's liberty interest and reputation, the court found he deserved a proper hearing to refute the charges. Consequently, the Supreme Court's judgment to reinstate the petitioner was partially reversed, and the case was remanded to the Housing Authority for a further hearing and medical investigation.

Due processArticle 78probationary employmentterminationnarcotic suspicionurine testarbitrary and capriciousliberty interestFourteenth Amendmenthearing rights
References
10
Case No. MISSING
Regular Panel Decision
Jun 01, 2009

People v. Nunn

This case addresses whether a court's discretion to deem a misdemeanor complaint charging a drug offense as an information, without a field test or laboratory analysis, violates a defendant's due process rights. The court distinguishes People v Kalin and Matter of Jahron S., applying the three-factor test from Mathews v Eldridge. It concludes that the substantial private interest in physical liberty and the risk of erroneous deprivation necessitate a laboratory report or field test in most drug-related cases, imposing minimal burden on the prosecution. Specifically, for defendant Mr. Nunn, the misdemeanor complaint was deemed an information on June 1, 2009, after the certified laboratory analysis was filed.

Due ProcessCriminal ProcedureMisdemeanorControlled SubstanceDrug PossessionMisdemeanor InformationMisdemeanor ComplaintPrima Facie CaseLaboratory AnalysisField Test
References
21
Case No. MISSING
Regular Panel Decision

Gordon v. Brown

A New York City police officer, referred to as 'Petitioner,' underwent a random drug screening in June 1991, testing positive for cocaine. Subsequently, he was charged with violating department rules and faced an administrative hearing. During the hearing, Dr. William Closson, the Director of Forensic Toxicology at Brunswick Hospital Center, testified regarding the EMIT and GC/MS tests performed on the petitioner's urine specimen. However, the laboratory technicians who conducted the tests were not produced for cross-examination. Petitioner was terminated based on the hearing officer's findings. He challenged his termination through a CPLR article 78 proceeding, alleging a denial of due process due to the inability to cross-examine the technicians. The Appellate Division confirmed the Commissioner's determination, and the Court of Appeals affirmed, holding that due process did not require the production of the laboratory personnel where the general reliability of the procedures was not disputed, the supervisor was subject to cross-examination, and no specific testing defect was claimed. The court also found the termination penalty was not unduly harsh.

due processadministrative lawpolice disciplinedrug screeningurinalysis testcocaine ingestionevidence rulescross-examination rightslaboratory proceduresforensic evidence
References
11
Case No. MISSING
Regular Panel Decision

Ryan v. Carroll

Susan Ryan, a probationary police officer, was terminated from the City of New Rochelle Police Department after failing a random drug test for THC. She disputed the results, undergoing independent tests that came back negative, and sought reconsideration. Commissioner Carroll upheld the termination after an internal investigation. Ryan then filed a federal lawsuit alleging violations of her constitutional due process rights due to stigmatizing disclosure and wrongful termination, including a prior Article 78 proceeding challenging the denial of worker's compensation benefits. The District Court granted the defendants' motion for summary judgment, dismissing Ryan's claims for lack of evidence of wrongful disclosure by defendants and the availability of an adequate state post-deprivation procedure for her procedural due process claim. The court declined to exercise supplemental jurisdiction over the remaining Article 78 claim.

Due Process ViolationLiberty Interest DeprivationSummary Judgment GrantedPolice Officer TerminationDrug Test ChallengeProbationary Employment RightsPublic Disclosure of InformationDefamation ClaimSection 1983 ActionArticle 78 Review
References
18
Case No. ADJ799845
Regular
Sep 06, 2012

BOBBY RIVERA vs. STURGEON & SONS, INC., ZURICH NORTH AMERICA

This Workers' Compensation Appeals Board case denied a defendant's petition for reconsideration. The WCJ had awarded temporary total disability and further medical treatment for a knee injury. The defendant argued disability payments should cease after the applicant's termination for cause (positive drug test). However, the Board found no evidence the applicant could have returned to modified work within his restrictions, even if he had passed the drug test, thus upholding the temporary disability award.

Workers' Compensation Appeals BoardFindings and AwardReconsideration DeniedTemporary DisabilityFurther Medical TreatmentTermination for CauseDrug ScreenQualified Medical EvaluatorWork RestrictionsModified Work
References
3
Case No. MISSING
Regular Panel Decision

Hall v. New York City Transit Authority

Robert Canty, a 15-year bus operator, was terminated by the New York City Transit Authority following two positive drug tests for marihuana. Despite a hearing examiner's recommendation, the vice-president for labor relations sustained the charge. The court found that the determination was not supported by substantial evidence, noting the toxicology expert's testimony on residual drug traces. Consequently, the court annulled the termination, dismissed the charge, and ordered Canty's reinstatement with back pay, as he was not afforded proper opportunity under the Transit Authority's own regulations.

drug testingmarihuana useemployee terminationadministrative reviewlack of substantial evidencereinstatementback paybus operatordrug counseling programdisciplinary action
References
0
Case No. MISSING
Regular Panel Decision

In re the Claim of Ramirez

Claimant's employment was terminated after a random drug test returned positive for cocaine, leading to an initial disqualification from unemployment insurance benefits due to misconduct. The Unemployment Insurance Appeal Board later ruled the positive drug test was not competent proof of misconduct, citing an unestablished chain of custody, and granted benefits. The employer appealed, arguing that the chain of custody was not disputed by claimant's counsel during the Administrative Law Judge hearings. The appellate court agreed with the employer, finding the Board's decision was not based on the record and lacked substantial evidence. Consequently, the court reversed the Board's decision and remitted the matter for further proceedings.

Unemployment InsuranceDrug TestingEmployment MisconductChain of CustodyAppellate ReviewAdministrative LawSubstantial EvidenceRemittalUnemployment Insurance Appeal BoardLabor Law
References
2
Case No. MISSING
Regular Panel Decision

Buckley v. Consolidated Edison Company of New York, Inc.

Dan Buckley, a former management employee, sued Consolidated Edison Company of New York, Inc. for violations of the Americans with Disabilities Act (ADA) and New York State Executive Law § 296, alleging discrimination based on his disability as a rehabilitated alcohol/substance abuser and termination due to his inability to provide a urine sample for drug testing. The court had previously dismissed his complaint but allowed him to replead, finding he adequately alleged disability but not discrimination based on it. In his amended complaint, Buckley conceded his bladder condition, which prevented him from urinating on command, was not an ADA disability but argued Con Edison's drug testing procedures were unreasonable. The court granted Con Edison's motion to dismiss, concluding that failure to accommodate a non-disability does not constitute an ADA violation, and Buckley failed to allege that his actual disability (alcohol/substance abuse) was not reasonably accommodated.

Americans with Disabilities ActDisability DiscriminationDrug TestingReasonable AccommodationAlcohol AbuseSubstance AbuseTermination of EmploymentMotion to DismissFederal Rules of Civil Procedure Rule 12New York State Executive Law
References
3
Case No. MISSING
Regular Panel Decision

In re Weir v. State of New York Thruway Authority

Petitioner, a probationary laborer for the New York State Thruway Authority and New York State Canal Corporation, was terminated from his position after co-workers reported him for marihuana use during working hours. Despite a negative urine test and prior satisfactory performance reviews, the Albany Division Director recommended termination based on the credibility of the co-workers' statements and deteriorating relations. Petitioner challenged his termination through a CPLR article 78 proceeding, which was dismissed by the Supreme Court. The appellate court affirmed this dismissal, ruling that as a probationary employee, petitioner could be dismissed without a hearing or stated reasons, and he failed to demonstrate bad faith, arbitrary, capricious, or otherwise illegal reasons for his termination.

Probationary EmploymentTerminationDrug UseMarihuanaCPLR Article 78Judicial ReviewPublic EmploymentWorkplace ConductBad FaithArbitrary and Capricious
References
4
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