In re the Arbitration between Bukowski
Petitioner Michael Bukowski, a correction officer, was dismissed from service after he kicked an inmate, causing serious injuries, and subsequently lied about the incident. An arbitrator sustained the charges but reduced the penalty to a 120-day suspension, which respondent Department of Corrections and Community Supervision (DOCCS) refused to comply with. The Supreme Court confirmed the misconduct findings but vacated the reduced penalty, remitting the matter for a new penalty. On appeal, the higher court affirmed, ruling that the arbitrator's reduced penalty violated strong public policy against inmate abuse and officer dishonesty, as Bukowski not only used excessive force but also repeatedly lied to conceal his actions. The case was remitted for the imposition of an appropriate penalty, taking into account the public policy implications of the officer's misconduct and deceit.