Conley v. Ambach
New York Court of Appeals
472 N.Y.S.2d 598, 460 N.E.2d 1083, 16 Educ. L. Rep. 576 (1984)
- Written by Emily Laird, JD
Facts
In evaluating allegations against a tenured teacher, a hearing panel determined that the teacher was at fault and recommended a fine. In an appeal following the agency’s quasi-judicial hearings process, the commissioner of education annulled the panel’s action, citing the chairman’s bias and noting the chairman had failed to disclose a relationship with the counsel for the teacher. In addition to annulling the panel’s action, the commissioner directed the parties to select a replacement chairman, a process unsupported by the state statute, which required that the remaining panel members replace a chairman. After the replacement of the chairman, the commissioner declared that the new panel had to confine its decision to the administrative record established by the previous hearing panel. The state trial court overturned the commissioner’s action. The case was ultimately appealed to the New York Court of Appeals.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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