Cleary v. Board of Education
The petitioner, a substitute school teacher, sought retroactive membership in the New York State Teachers’ Retirement System after the enactment of Retirement and Social Security Law § 803. Respondent, her employer, denied her application. Petitioner then initiated a CPLR article 78 proceeding, which the Supreme Court granted, annulling the Hearing Officer's determination due to lack of a rational basis. The respondent appealed this decision. The Appellate Court affirmed the Supreme Court's judgment, concluding that the Hearing Officer's finding that the petitioner participated in a procedure requiring a formal decision to join the retirement system lacked a rational basis, as the evidence presented by the respondent, including W-4 forms, personnel notations, and general office practice testimony, was insufficient to meet the burden.