Hyland v. New York City Fire Dept.

2024 NY Slip Op 33395(U)
CourtNew York Supreme Court, New York County
DecidedSeptember 27, 2024
DocketIndex No. 151942/2024
StatusUnpublished

This text of 2024 NY Slip Op 33395(U) (Hyland v. New York City Fire Dept.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hyland v. New York City Fire Dept., 2024 NY Slip Op 33395(U) (N.Y. Super. Ct. 2024).

Opinion

Hyland v New York City Fire Dept. 2024 NY Slip Op 33395(U) September 27, 2024 Supreme Court, New York County Docket Number: Index No. 151942/2024 Judge: Lyle E. Frank Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 151942/2024 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 09/27/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. LYLE E. FRANK PART 11M Justice ----------------------------------------------------------------- ----------------X INDEX NO. 151942/2024 DANIEL HYLAND, MOTION DATE 03/04/2024 Plaintiff, MOTION SEQ. NO. 001 - V -

NEW YORK CITY FIRE DEPARTMENT, CITY OF NEW DECISION + ORDER ON YORK MOTION Defendant. ------------------------------------------------------------------- --------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 2, 8, 11, 12, 13, 14, 15, 16, 17, 18, 19,20,21,22,23,24 were read on this motion to/for ARTICLE 78 (BODY OR OFFICER)

Upon the foregoing documents, petitioner's motion is denied and respondents' cross-

motion to dismiss the petition is granted.

Background

This dispute arises out of a claim of unlawful retaliation under the New York State

Human Rights Law and the New York City Human Rights Law relating to the transfer of a

firefighter. Prior to November 20, 2019, Petitioner Daniel Hyland ("Petitioner") was assigned to

and working in Rescue I in Manhattan. Petitioner claims that he wrote a letter in favor of a

Captain Morris during an Equal Employment Opportunity ("EEO") investigation and that as a

result of that letter he was subjected to a hostile work environment. Petitioner filed an EEO

complaint about his workplace environment with the Respondent New York City Fire

Department ("FDNY", together with the City of New York "Respondents"). After this, Petitioner

was transferred to Rescue 5 on Staten Island. Although the parties disagree about the nature of

this transfer, and the dates and number of subsequent requests, both agree that multiple times

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thereafter Petitioner unsuccessfully requested to be transferred back to Rescue 1, starting with a

request made on December 11, 2019.

Petitioner filed a petition pursuant to Article 78 on March 04, 2024, seeking an order

directing Respondents to transfer Petitioner back to Rescue 1 and directing Respondents to pay

Petitioner the sum of money he was allegedly unlawfully prevented from earning in overtime as

well as damages for pain and suffering and other emotional distress.

Respondents filed a cross-motion seeking under CPLR § 321 l(a)(5) and (7) to dismiss

the petition as untimely and for failure to state a claim. Petitioner then filed for leave to amend

the petition and opposed the cross-motion to dismiss.

Standard of Review

CPLR § 7803(1) allows for the question to be raised of whether the subject body failed to

perform a duty enjoined upon it by law. CPLR § 7803(3) allows for the question to be raised of

whether a determination was made in violation of lawful procedure, was arbitrary and capricious,

or was an abuse of discretion. Pursuant to CPLR § 217(1), the statute oflimitations to commence

an Article 78 proceeding is four months from the issuance of a final determination. See also

Matter ofBanos v. Rhea, 25 N.Y.3d 266,276 (2015).

Discussion

Petitioner and Respondents dispute several issues such as whether or not there was an

adverse employment action taken against Petitioner or if the amended petition states a valid

claim. Ultimately, the Court does not need to reach these issues, as the petition is barred as

untimely.

When, as is the case here, multiple administrative requests are made, the determination of

when the CPLR § 217 four-month statute of limitations clock begins relies largely on the nature

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of the requests. Generally, "[d]iscrete acts such as ... denial of transfer ... constitutes a separate

actionable 'unlawful employment practice'." AMTRAK v. Morgan, 536 U.S. 101, 114 (2002).

But when, for instance, a plaintiff has "alleged one tortious act, and the continuing consequences

of that act did not amount to distinct wrongs", the continuing wrong doctrine does not apply to

toll the limitations period. Jorge v. City of New York, 220 A.D.3d 593, 593 (1st Dept. 2023).

Additionally, a request for reconsideration of a prior request without any change in

circumstances does not toll the four months. Corbin v. Ward, 160 A.D.2d 596 (1st Dept. 1990).

When a final and binding determination is made, subsequent requests that are "duplicative of

[the] prior request" likewise do not toll the statute oflimitations. Kelly v. New York City Police

Dep 't, 286 A.D.2d 581 (1st Dept. 2001).

A challenged administrative decision becomes final and binding under CPLR § 217

"when it 'has its impact' upon the petitioner who is thereby aggrieved. Edmead v. McGuire, 67

N.Y.2d 714, 716 (1986). If, however, "the agency has created the impression that the

determination, albeit issued, was intended to be nonconclusive", then the statute of limitations

does not begin to run. Id. The issue therefore becomes when a final and binding determination

was made by Respondents concerning the Petitioner's transfer to Rescue 5, thus making any

subsequent requests to transfer back to Rescue 1 in the nature of a duplicative request for

reconsideration without any change in circumstances. At that point, Petitioner would have had

four months to file an Article 78 proceeding.

A final and binding determination made by Respondents in this matter can be found

simply by reading through Petitioner's own moving papers. Petitioner states in the Statement of

Facts for his Memorandum of Law opposing the motion to dismiss that the detail transferring

him to Rescue 5 was originally "suggested to Petitioner as temporary" and later in the same

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Memorandum cites the allegedly temporary nature of the transfer to Rescue 5 as grounds for the

claim being timely under CPLR § 217 and case law. But this argument contradicts Petitioner's

own statements in his Amended Petition.

Paragraph 18 of the Factual Background section of the Amended Petition states in its

entirety "On December 11, 2019, Petitioner tried to return to Rescue 1 and was informed on

January 2, 2020 that his detail was now non-voluntary and that he could not return to Rescue 1"

(emphasis added). Paragraph 19 states that "[t]his came as a shock to Petitioner, as he had not

engaged in any wrongdoing and yet was sent on an involuntary detail immediately after filing an

EEO charge of harassment" (emphasis added).

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Related

National Railroad Passenger Corporation v. Morgan
536 U.S. 101 (Supreme Court, 2002)
Edmead v. McGuire
490 N.E.2d 853 (New York Court of Appeals, 1986)
Corbin v. Ward
160 A.D.2d 596 (Appellate Division of the Supreme Court of New York, 1990)
Kelly v. New York City Police Department
286 A.D.2d 581 (Appellate Division of the Supreme Court of New York, 2001)

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2024 NY Slip Op 33395(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/hyland-v-new-york-city-fire-dept-nysupctnewyork-2024.