From Casetext: Smarter Legal Research

Adams v. City of New York

Appellate Division of the Supreme Court of New York, First Department
Apr 25, 2000
271 A.D.2d 341 (N.Y. App. Div. 2000)

Summary

holding that where "the relief actually being sought is to compel [the agency] to discharge a duty in conformity with its personnel policies and procedures, . . . plaintiffs must invoke the procedural requirements of [A]rticle 78"

Summary of this case from Santangelo v. City of N.Y.

Opinion

April 25, 2000.

Orders, Supreme Court, New York County (Phyllis Gangel-Jacob, J.), both entered on or about September 30, 1998, dismissing the complaints, unanimously reversed, on the law, without costs, the plenary action converted to a CPLR article 78 proceeding, and the matter remanded for further proceedings.

Joseph J. Ranni, for plaintiff-appellant.

Linda H. Young, for defendant-respondent.

SULLIVAN, P.J., NARDELLI, MAZZARELLI, TOM, FRIEDMAN, JJ.


Although pleaded as an action sounding in breach of contract to require the municipal respondent to adjust plaintiffs' salaries, the relief actually being sought is to compel respondent to discharge a duty in conformity with its personnel policies and procedures. As such, plaintiffs must invoke the procedural requirements of article 78. When the administrative determination is deemed final for purposes of commencement of the four-month Statute of Limitations turns on whether the action sounds in mandamus or certiorari (see, Matter of Hamptons Hospital Center v. Moore, 52 N.Y.2d 88, 96). In a proceeding for mandamus relief, it is necessary to make a demand and await a refusal, and the limitations period does not commence until the refusal (Matter of Bernstein v. Industrial Commissioner of the State of New York, 57 A.D.2d 767). As an affirmative defense, the Statute of Limitations must be pleaded and proved (CPLR 3018 [b]; 3211[a][5]; see, Siegel, New York Practice, § 34, at 40 [3d ed.]). Plaintiffs' demands were not formally rejected (see, Matter of Bates v. County of Steuben, 113 Misc.2d 68). Rather, at various times, administrative personnel even tried to achieve the results sought by plaintiffs, well after the January 1993 date identified by the motion court as the time when the limitations period commenced. Moreover, respondent itself failed to prove the date when agency action was final. As such, the finality necessary to commence the limitations period has not been established, and the controversy remains viable. Accordingly, we convert this matter into an article 78 proceeding and remand for determination thereof.

THIS CONSTITUTES THE DECISION AND ORDER OF SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT.


Summaries of

Adams v. City of New York

Appellate Division of the Supreme Court of New York, First Department
Apr 25, 2000
271 A.D.2d 341 (N.Y. App. Div. 2000)

holding that where "the relief actually being sought is to compel [the agency] to discharge a duty in conformity with its personnel policies and procedures, . . . plaintiffs must invoke the procedural requirements of [A]rticle 78"

Summary of this case from Santangelo v. City of N.Y.
Case details for

Adams v. City of New York

Case Details

Full title:STEVEN B. ADAMS, Plaintiff-Appellant, v. CITY OF NEW YORK…

Court:Appellate Division of the Supreme Court of New York, First Department

Date published: Apr 25, 2000

Citations

271 A.D.2d 341 (N.Y. App. Div. 2000)
707 N.Y.S.2d 73

Citing Cases

Abdur-Rauf v. City of New York

Consequently, an administrative agency's decision to terminate a plaintiff's employment is properly…

Santangelo v. City of N.Y.

As such, this claim amounts to an alleged violation of the DOC's own procedural rules and regulations, which…