From the New York Labor & Law Report-Bond, Schoeneck & King (an excellent free resource for NYS labor law-public and private)
Although public employers may be aware of their obligation to provide certain types of employees with an opportunity for a hearing prior to imposing discipline (such as a written reprimand), the line between a non-disciplinary counseling memorandum and a disciplinary reprimand is not always clear. The New York State Court of Appeals’ recent decision in Matter of Michael D’Angelo v Nicholas Scoppetta serves as an important reminder that the term “reprimand” may be interpreted more broadly than public employers anticipate.
Read full text of decision below:
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