The Matter of City of New York v. New York State Nurses Association

The majority believes that the City of New York has conceded that the statutory discovery obliga*555tion contained in Administrative Code of the City of New York § 12-306 (c) (4) (New York City Collective Bargaining Law [NYCCBL]) extends to “grievances” (majority op at 553). The majority then concludes that, because the parties’ collective bargaining agreement defines “grievance” to include “disciplinary action taken against an employee,” the City’s discovery obligation necessarily extends to disciplinary actions (majority op at 553). I disagree with both propositions, and therefore I…