Graves v. City of New York
Gary Graves, a former licensed clinical social worker at Rikers Island for Corizon Health Inc., initiated a CPLR article 78 proceeding against the City of New York and the New York City Department of Correction (DOC) after his security clearance was revoked. This revocation stemmed from a 2015 investigation into Corizon, which revealed systemic failures and security breaches at Rikers Island. Despite Graves's extensive rehabilitation efforts and a successful 14-year tenure at Rikers Island with no disciplinary issues, his security license was revoked based on criminal convictions from 1972-1987. Graves argued that the respondents failed to consider all eight factors mandated by Correction Law, article 23-A, §§ 752 and 753. The court, however, dismissed the petition, ruling that the Correction Law provisions do not apply to DOC's revocation of security clearance for individuals working at its facilities, interpreting such access as 'membership' in a law enforcement agency, which is exempt from the statute.