Beame v. DeLeon

163 Misc. 2d 885
CourtNew York Supreme Court
DecidedSeptember 9, 1993
StatusPublished
Cited by1 cases

This text of 163 Misc. 2d 885 (Beame v. DeLeon) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beame v. DeLeon, 163 Misc. 2d 885 (N.Y. Super. Ct. 1993).

Opinion

OPINION OF THE COURT

Alice Schlesinger, J.

Before the court are three petitions brought pursuant to the City Human Rights Law (Administrative Code of City of NY § 8-101 et seq.) and CPLR article 78 to annul orders issued by the New York City Commission on Human Rights (the Commission) adopting the recommendations of Chief Administra[890]*890tive Law Judge (CALJ) Maldonado in the sex discrimination proceeding entitled Powers v Beame.

The New York City Police Department (Police Department) seeks to annul CALJ Maldonado’s decision in the proceedings brought by the complainants Helene Rinaldi and Regina McKay. Mary Ann Larsen and Regina McKay have also moved against CALJ Maldonado’s order as it relates to them (hereinafter Beame III).

In stage one of the proceedings, CALJ Kirchgaessner found that the complainants had established a prima facie case of gender-based discrimination. He identified the following practices to be violations of the Administrative Code:

(1) respondents’ hiring practices including the use of quotas limiting women to between 1 and 2% of the force;

(2) respondents’ layoff practices during the 1975 fiscal crisis;

(3) respondents’ reinstatement practices;

(4) respondents’ practice in requiring women to serve involuntary matron duty;

(5) respondents’ practice of assigning policewomen to only 7 out of 73 precincts while patrolmen were assigned to all precincts;

(6) respondents’ practice of restricting policewomen from certain types of duties and assignments such as anticrime, crime prevention, community relations, roll call and Captain’s clerical duty while patrolmen had opportunities to participate in all such duties and assignments;

(7) respondents’ practice of requiring policewomen to "fly” regularly from one precinct to another in order to provide matron duty while patrolmen would fly only in emergency situations;

(8) respondents’ practice of restricting policewomen from assignment to duties on a steady basis while patrolmen remain in steady posts within one precinct;

(9) respondents’ practice of restricting policewomen from regular participation in radio motor-patrol activities and/or assignment to steady partners and steady foot posts;

(10) respondents’ practice of denying policewomen certain schedules which were granted to patrolmen such as selection of annual vacation time with squads, emergency days off and "excusáis” on major holidays, and tour changes in order to go to school;

(11) respondents’ practice of denying transfers between patrolwomen and patrolmen;

[891]*891(12) respondents’ practice of requiring policewomen to be responsible to both the precinct and area commands and, therefore, responsible for coverage throughout a borough while patrolmen were responsible only to the precinct; and

(13) respondents’ practice of refusing to permit policewomen returning from maternity leave to be assigned to their former command while patrolmen assigned to the "military extended leave desk” were permitted to return to their former command upon expiration of such leave.

On November 8, 1991, the Commission adopted CALJ Kirchgaessner findings and directed hearings on each individual complainant’s damages.

The Police Department commenced a proceeding in the Supreme Court challenging the Commission’s November 8, 1991 decision and order. I dismissed the petition (hereinafter Beame I).

Thereafter, the parties commenced the stage two proceedings. On October 1, 1992 as amended on December 23, 1992, CALJ Maldonado issued a recommended decision in which she held that 45 complainants had established timely claims. She recommended that the successful complainants were entitled to retroactive seniority to the position they would have achieved but for the discrimination. Additionally, she recommended retroactive adjustments to the women’s pension benefit levels to reflect their earlier appointment dates.

The Commission adopted CALJ Maldonado’s recommendations. The Police Department also appealed this order. On June 22, 1993,1 dismissed the petition (hereinafter Beame II).

Two arguments raised in Beame II and again raised in the instant proceedings merit a brief discussion.

The Police Department, through these proceedings, has maintained that the award of retroactive seniority may not be granted because it is not reasonably related to the alleged wrong that was established during the limitations period. Essentially, they assert that mandatory matron duty is unrelated to any injury a complainant may have sustained.

I rejected this argument in Beame II. The Administrative Code grants the Commission broad power to fashion the appropriate remedy.

This remedy is reasonably related to the discriminatory conduct. As the Commission found in Beame I, excessive matron duty affected promotional opportunities of women [892]*892police officers. They received lower evaluations, fewer awards, lower examination scores. Furthermore, the complainants’ precinct assignments were restricted and as a result they failed to receive the patrol experience necessary for advancement.

Thus, it is clear that retroactive seniority is the appropriate remedy to make the complainants whole.

Second, the Police Department has consistently maintained that the Commission lacks authority to adjust the successful complainants’ pension levels and benefits because the pension fund is not a party to these proceedings.

I found this argument to lack merit in Beame II because the changes to the pension levels is an incidental result based on the adjustment of seniority dates. The pension fund need not be a party for this purpose.

Before discussing CALJ Maldonado’s findings in Beame III two legal points merit discussion. First, the judiciary has a limited role in reviewing the Commission’s factual determinations. "Unlawful discrimination in the present day is generally practiced in subtle ways * * * That others would require stronger evidence to reach the ultimate factual inferences is not relevant. The inference-making function, as it is exercised at the evidentiary or fact-finding level, is exclusively that of the administrative agency” (State Div. of Human Rights v Wagner, 39 NY2d 865, 866 [1976] [citations omitted]).

Second, section 8-120 of the Administrative Code grants the Commission broad power to fashion the appropriate relief to remedy discriminatory conduct. "[T]he relief imposed by the Commissioner need only be reasonably related to the discriminatory conduct. 'Unless the award is so arbitrary and capricious as to constitute an abuse of discretion, it is not erroneous as a matter of law. (Matter of Imperial Diner v State Human Rights Appeal Bd., 52 NY2d 72, 79’ ”) (Matter of New York City Tr. Auth. v State Div. of Human Rights, 78 NY2d 207, 217 [1991] [other citations omitted].)

I. Beam v DeLeon, New York City Commission on Human Rights, and Helene Rinaldi.

CALJ Maldonado recommended that Rinaldi’s seniority be adjusted to reflect her retroactive appointment as a police trainee on November 7, 1966 and that her appointment date as a police officer be changed to December 14, 1969.

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Related

Beame v. DeLeon
209 A.D.2d 252 (Appellate Division of the Supreme Court of New York, 1994)

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163 Misc. 2d 885, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beame-v-deleon-nysupct-1993.