Matsa v. Wallach
The petitioner, a former Psychiatric Social Worker at Creedmoor State Hospital, was dismissed from her probationary role as Psychiatric Social Work Supervisor II at Brooklyn State Hospital after 26 weeks for unsatisfactory performance. She initiated a CPLR article 78 proceeding, arguing her position became permanent after a 12-week probationary period and her dismissal was in bad faith. While Special Term agreed, the appellate court reversed, clarifying that her appointment was an original one subject to a 26-week probation. The court found proper notice for the extended probation and no evidence of bad faith in her dismissal.