D'Angelo v. Scoppetta

Smith, J. (dissenting).

I dissent because I do not think the Assistant Commissioner’s letter to petitioner is a “reprimand” as we interpreted that term in Holt v Board of Educ. of Webutuck Cent. School Dist. (52 NY2d 625 [1981]).

Laws governing the discipline of civil servants, including Administrative Code of the City of New York § 15-113, often require a trial or hearing, with due process protections, before an employee can be given a “reprimand.” If that term were given a broad interpretation, it could make the lives of public employers almost impossible: They would have to go through a…