The First Department reverses a Supreme Court order annulling a DOC demotion, holding that provisional appointments under Civil Service Law § 65 carry no tenure and no right to a hearing — and that a provisional appointment does not ripen into permanent status through the passage of time, only through civil service examination.
The First Department dismisses an Article 78 challenge to NYCHA’s redevelopment plan for the Elliot and Chelsea Houses, holding that the four-month CPLR 217(1) limitations period began running from NYCHA’s July 28, 2025 record of decision — leaving the December 22, 2025 filing untimely by nearly a month.
The First Department upheld denial of accidental disability retirement to an NYPD officer with PTSD from witnessing a fellow officer stabbed through the eye, holding that confronting on-duty violence falls within the inherent risks of police work and is not an ‘accident’ for pension purposes.