Tipaldo v. Lynn
The plaintiff, a former Acting Assistant Commissioner for Planning with the New York City Department of Transportation (DOT), was demoted in retaliation for reporting a superior's violation of bidding rules. Following a nonjury trial, the Supreme Court awarded the plaintiff $175,000 in back pay but denied interest and reinstatement. This appellate court modified the lower court's order, finding that the back pay award should be recalculated based on the plaintiff's expert testimony, which estimated lost earnings at $388,243 plus 9% statutory interest. The court also ruled that prejudgment interest should have been awarded, citing Civil Service Law § 75-b and its link to Labor Law § 740, which aims to make whistleblowers "whole." Furthermore, the appellate court ordered the defendants to reinstate the plaintiff to his former or an equivalent position, affirming the order otherwise.