Howell v. County of Albany
A correction officer's General Municipal Law § 207-c benefits were suspended by the Albany County Sheriff after he refused a light duty assignment following a workplace injury in September 2009. The officer initiated a CPLR article 78 proceeding, alleging due process violations because the Hearing Officer supposedly refused to consider proof of post-traumatic stress disorder and relied on evidence outside the record. The Court determined that the petitioner was afforded due process, noting that a predetermination hearing was held where he presented witnesses and cross-examined the respondents'. The Court found no violation of procedural due process as the petitioner did not raise a genuine dispute regarding his PTSD diagnosis before the hearing. Ultimately, the Court confirmed the determination to suspend benefits and dismissed the petition.