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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Jun 01, 2009

People v. Nunn

This case addresses whether a court's discretion to deem a misdemeanor complaint charging a drug offense as an information, without a field test or laboratory analysis, violates a defendant's due process rights. The court distinguishes People v Kalin and Matter of Jahron S., applying the three-factor test from Mathews v Eldridge. It concludes that the substantial private interest in physical liberty and the risk of erroneous deprivation necessitate a laboratory report or field test in most drug-related cases, imposing minimal burden on the prosecution. Specifically, for defendant Mr. Nunn, the misdemeanor complaint was deemed an information on June 1, 2009, after the certified laboratory analysis was filed.

Due ProcessCriminal ProcedureMisdemeanorControlled SubstanceDrug PossessionMisdemeanor InformationMisdemeanor ComplaintPrima Facie CaseLaboratory AnalysisField Test
References
21
Case No. MISSING
Regular Panel Decision

American Train Dispatchers Ass'n v. Metro-North Commuter Railroad

Plaintiff American Train Dispatchers Association (ATDA) accused defendant Metro-North Commuter Railroad Company of violating the Railway Labor Act (RLA) by unilaterally implementing changes to work rules and conditions without prior union consultation. The changes concerned sick leave, vacation days, training time, work attire, and drug/alcohol testing. The court classified these disputes as either 'major' or 'minor' under the RLA. It found that the automatic requirement for doctor's certificates for sick days not contiguous to rest days, holidays, or vacation, and the new work attire policy constituted 'major disputes', and thus granted a permanent injunction to restore the status quo. However, the court deemed disputes over training time, single vacation days, and sick days contiguous to rest days/holidays/vacation as 'minor disputes', denying injunctive relief for these. The court also denied injunctive relief for random drug testing due to insufficient evidence, noting that the issue of drug testing as part of regular medical examinations was being addressed in a separate ruling.

Railway Labor ActMajor DisputeMinor DisputeInjunctive ReliefWork RulesSick Leave PolicyVacation PolicyTraining TimeDress CodeDrug Testing
References
14
Case No. MISSING
Regular Panel Decision

Buckley v. Consolidated Edison Company of New York, Inc.

Dan Buckley, a former management employee, sued Consolidated Edison Company of New York, Inc. for violations of the Americans with Disabilities Act (ADA) and New York State Executive Law § 296, alleging discrimination based on his disability as a rehabilitated alcohol/substance abuser and termination due to his inability to provide a urine sample for drug testing. The court had previously dismissed his complaint but allowed him to replead, finding he adequately alleged disability but not discrimination based on it. In his amended complaint, Buckley conceded his bladder condition, which prevented him from urinating on command, was not an ADA disability but argued Con Edison's drug testing procedures were unreasonable. The court granted Con Edison's motion to dismiss, concluding that failure to accommodate a non-disability does not constitute an ADA violation, and Buckley failed to allege that his actual disability (alcohol/substance abuse) was not reasonably accommodated.

Americans with Disabilities ActDisability DiscriminationDrug TestingReasonable AccommodationAlcohol AbuseSubstance AbuseTermination of EmploymentMotion to DismissFederal Rules of Civil Procedure Rule 12New York State Executive Law
References
3
Case No. MISSING
Regular Panel Decision

Jackman v. Schembri

The petitioner's dismissal from his correction officer position by the Correction Commissioner, based on a drug test, was unanimously confirmed. The court found substantial evidence to support the reasonable suspicion justifying the drug test, citing the Health Management Division physician's observations of alcohol on petitioner's breath, nasal congestion, swollen glands, throat soreness, and nystagmus, indicative of substance abuse. Additionally, the petitioner's agitated and hostile behavior in the waiting room contributed to the suspicion. The court also determined that the petitioner's due process rights were not violated by the refusal to grant an adjournment, as he had failed to appear for two previous hearings, his attorney could not explain his absence, and there was no indication he would appear at a later date. Consequently, the petition was denied, and the CPLR Article 78 proceeding was dismissed.

correction officer dismissaldrug testingreasonable suspiciondue processadjournment denialsubstance abusenystagmusadministrative reviewemployment terminationmedical examination findings
References
2
Case No. MISSING
Regular Panel Decision

Coleman v. Town of Hempstead

Plaintiff Paul Coleman, an employee of the Town of Hempstead Department of Sanitation, was suspended for 24 days after failing a random drug test he alleges was flawed. He filed claims under 42 U.S.C. § 1983 for procedural and substantive due process violations, along with state law claims for negligence and malpractice, against the Town, its officials, and various private entities involved in the drug testing, including Medical Review Officers (MROs) and a laboratory. Defendants University Services (an MRO) and LabCorp Laboratories (the testing lab) moved to dismiss the amended complaint, arguing they are private entities not acting under color of state law for the § 1983 claims, and that LabCorp owed no duty to the plaintiff for the negligence claim. The Court denied both motions, finding that the plaintiff adequately alleged that LabCorp and University Services acted under color of state law, either through a close-nexus or symbiotic relationship with the Town. Regarding the negligence claim against LabCorp, the Court determined that New York law would recognize a common law duty of care owed by a drug testing laboratory to an employee in such circumstances, due to the significant and potentially devastating consequences of a false-positive drug test.

Drug TestingWorkplace Drug TestingDue Process ViolationSection 1983 ClaimNegligence ClaimMedical MalpracticeState Action DoctrinePrivate Entity LiabilityMotion to DismissUrine Sample
References
33
Case No. MISSING
Regular Panel Decision

Catlin v. Orleans County Highway Department

Petitioner was discharged from his employment as a maintenance equipment operator for the Orleans County Highway Department after testing positive for marihuana during a random drug test. He initiated a CPLR article 78 proceeding, contending that the penalty was arbitrary and capricious, an abuse of discretion, and that he was denied due process due to inadequate notice of the consequences of a positive drug test. The court rejected these contentions, finding that he had received mandatory training and notice regarding the drug policy. The court upheld the dismissal, concluding that the severe penalty was not disproportionate to the offense, especially given his duties operating heavy equipment near others and the public.

Drug TestingPublic EmploymentCivil Service LawCPLR Article 78Employment TerminationArbitrary and CapriciousDue ProcessPenalty ProportionalityOrleans CountyHeavy Equipment Operator
References
6
Case No. MISSING
Regular Panel Decision

Seelig v. Koehler

This is a dissenting opinion regarding the random drug testing of correction officers. Justice Milonas argues that the majority decision to allow such testing without reasonable suspicion oversteps the boundaries set by the Court of Appeals and the United States Supreme Court. The dissent emphasizes that New York State law requires more stringent conditions for random searches, particularly concerning privacy interests and government justification. Milonas distinguishes correction officers from other law enforcement personnel, highlighting their reduced exposure to drugs within a controlled environment, which lessens the justification for random testing. The opinion concludes that there is no legal precedent in New York for the proposed blanket random drug-screening program for all correction officers.

Drug TestingUrinalysisFourth AmendmentPrivacy RightsPublic EmployeesCorrectional OfficersPolice PowersConstitutional ScrutinyReasonable SuspicionNew York Court of Appeals Precedent
References
16
Case No. 2016 NY Slip Op 01770 [137 AD3d 542]
Regular Panel Decision
Mar 15, 2016

Matter of Niang v. New York City Dept. of Educ.

Babacar Niang, a school bus driver, challenged the New York City Department of Education's (DOE) decision to permanently revoke his certification for failing to submit to a drug test on the day of an accident. The Appellate Division, First Department, found the DOE's determination arbitrary and capricious and contrary to its own regulations. The court noted that the DOE's policy (Chancellor's Regulation C-102) only requires post-accident drug tests under specific circumstances, none of which applied to Niang's first accident where no injuries occurred and no vehicle was disabled. Furthermore, Niang underwent a drug test within 24 hours, which returned negative results. Consequently, the court annulled the DOE's determination, reinstated Niang's certification, and remanded the case for a hearing to determine any incidental damages.

School bus driverCertification revocationDrug test policyArbitrary and capriciousAgency regulationPost-accident testingChancellor's Regulation C-102Incidental damagesCPLR article 78Employment dispute
References
3
Case No. MISSING
Regular Panel Decision

Landon v. Kroll Laboratory Specialists, Inc.

This case addresses whether a drug testing laboratory can be held liable in tort to a non-contracting subject for negligent testing. The plaintiff, while on probation in Orange County, submitted an oral fluid sample that Kroll Laboratory Specialists, Inc., falsely reported as positive for marijuana. The lab allegedly used a lower cutoff level than recommended and failed to perform a confirmatory GC/MS test, leading to an extension of the plaintiff's probation. The Supreme Court initially dismissed the complaint, but the appellate court reversed, asserting that a duty of reasonable care exists due to the severe consequences of inaccurate drug test results on individuals' lives and the lack of market incentives for testing accuracy. The court concluded that the plaintiff's complaint adequately stated a cause of action for negligence.

Drug TestingNegligenceTort LiabilityForensic ToxicologyPrivity of ContractDuty of CareProbation ViolationFalse PositiveLaboratory StandardsCPLR 3211(a)(7)
References
101
Case No. MISSING
Regular Panel Decision

Otero v. Town of Southampton

The plaintiff, Otero, a school bus driver, sued the Town of Southampton, its Police Department, and Officer Andrew Mazzio under federal civil rights laws (42 U.S.C. §§ 1981, 1983) and state laws for false arrest, false imprisonment, malicious prosecution, and excessive force. The claims arose from Otero's January 1999 arrest for Driving While Intoxicated (DWI) and Endangering the Welfare of a Child, following reports of erratic driving and his failure of sobriety tests after consuming Robitussin for a cold. Although Otero's blood tests later showed no alcohol or drugs, and the initial charges were dismissed, he eventually pled guilty to Failure to Maintain Lane. The District Court granted summary judgment to the defendants, concluding that probable cause existed for the arrest and initial charges, no excessive force was used, and an alleged 'perp walk' did not violate the Fourth Amendment. The court declined jurisdiction over the remaining state law claims.

Civil Rights ActFalse ArrestFalse ImprisonmentMalicious ProsecutionExcessive ForceQualified ImmunityProbable CauseSummary JudgmentDriving While Intoxicated (DWI)Endangering Welfare of a Child
References
21
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