Matter of Clarke v. Board of Educ. of the City Sch.
The Appellate Division, First Department, affirmed the Supreme Court's dismissal of petitions challenging the New York City Department of Education's (DOE) COVID-19 vaccine mandate. Petitioners, employees placed on leave without pay for non-compliance, had sought to annul the DOE's determinations and vacate an arbitration award. The court found that the vaccine mandate was a valid qualification of employment, unrelated to job performance or misconduct, and therefore did not constitute disciplinary action. Furthermore, it ruled that the arbitrator's authority stemmed from the Civil Service Law, not the collective bargaining agreement or Education Law, and petitioners lacked standing to challenge the arbitration award. The court also determined that petitioners' due process rights were not violated, as they were offered opportunities for exemptions and accommodations.