Grogan v. Holland Patent Central School District
Petitioner, a food service worker, resigned from Holland Patent Central School District and later sought to withdraw her resignation. The Board of Education refused, leading the petitioner to commence a CPLR article 78 proceeding challenging this refusal. The Supreme Court denied the relief sought, and the judgment was unanimously affirmed on appeal. The court found that delivery of the resignation to the Board's Clerk constituted valid delivery to the Board, and subsequently, the resignation could not be withdrawn without the Board's consent. The decision not to consent by the Board was deemed to have a reasonable basis. Claims of harassment and constructive discharge, preceding the resignation, were properly referred to the Public Employment Relations Board.