Administrative Law Judges Not 'Second-Tier Players,' NJ Supreme Court Says
"The appellate tests for reviewing an administrative disciplinary sanction and a criminal sentence are virtually the same," and the Appellate Division "erred in suggesting that appellate review of a disciplinary sanction imposed by a judge is de novo and different from traditional appellate review of an agency determination," the court said in "Matter of Hendrickson."
September 18, 2018 at 03:46 PM
4 minute read
The New Jersey Supreme Court ruled Monday that an administrative law judge's ruling on a state employee's discipline must be given deference even if the Civil Service Commission can't muster enough members to review the ruling within the statutory deadline.
In a unanimous ruling, the court upheld a six-month suspension handed down by an ALJ to a state Department of Community Affairs fire inspector who the court said was overheard using a discriminatory slur to describe a female supervisor.
“The appellate tests for reviewing an administrative disciplinary sanction and a criminal sentence are virtually the same,” and the Appellate Division “erred in suggesting that appellate review of a disciplinary sanction imposed by a judge is de novo and different from traditional appellate review of an agency determination,” the court said in Matter of Hendrickson.
“Additionally, merely because the factual findings and rulings made by ALJs are oftentimes contingent on whether an agency accepts, rejects, or modifies an ALJ's decision does not mean that ALJs are second-tier players or hold an inferior status as factfinders,” the court added.
The decision upheld the six-month suspension of Inspector William Hendrickson over the objections of the DCA, which argued that Hendrickson should have been fired for his remarks.
“Was the discipline imposed by the ALJ so disproportionate that it shocks the conscience or one's sense of fairness?” wrote Justice Barry Albin for the court. “So long as reasonable minds might differ about the appropriateness of the disciplinary sanction, we have no call to second-guess the call made by the ALJ.”
According to the decision, Hendrickson was hired as a fire inspector by the DCA in August 2012.
On Dec. 1, 2013, Hendrickson was one of a number of fire inspectors assigned to work a New York Jets football game at MetLife Stadium. Before the game, he and two other co-workers were talking in the stadium parking lot when they received their assignments from their supervisor, Margaret Knight.
Knight assigned Hendrickson to inspect a pyrotechnics display on the roof of the stadium.
Hendrickson was displeased with the assignment. Others present recounted that Hendrickson muttered, “cunt,” though he said he had no recollection of using that term, but acknowledged saying, “I hope she gets a disease,” according to the decision.
Although it's disputed how loudly Hendrickson was talking, his co-workers in any event overheard him and reported the incident to superiors.
The DCA charged Hendrickson with violating public policy regarding gender discrimination and conduct unbecoming a public employee.
The DCA recommended that Hendrickson be fired, and the matter was referred to an ALJ. The ALJ, noting that Hendrickson had no prior disciplinary history, ruled that a six-month suspension was more appropriate.
Both Hendrickson and the DCA objected, with Hendrickson saying the ALJ's punishment was too harsh and the DCA saying Hendrickson should be fired.
The matter then should have been handled by the state Civil Service Commission, which has 45 days to issue a ruling per N.J.S.A. 52:14B-10(c). However, it lacked a quorum to act since there was only one active member. The commission was supposed to have five members, of which three would constitute a quorum.
Because of the CSC's lack of a quorum, the ALJ's decision was deemed adopted, and both sides appealed to the Appellate Division.
An Appellate Division panel sided with the DCA, rejected the doctrine of “progressive discipline,” and said Hendrickson should be fired. The court held that because the CSC lacked a quorum and could not review, the ALJ's decision was not “deemed adopted” per the statutory language and thus were not entitled to deference.
Hendrickson sought review from the Supreme court, which said: “The panel evidently classified the ALJ's disciplinary sanction as a legal conclusion and therefore erroneously engaged in a de novo review. An abuse of discretion standard, however, applies to the judicial imposition of a sentence … or a disciplinary sanction.”
Albin said, ”Based on our deferential standard of review, we cannot conclude that the ALJ's decision is shocking to one's sense of fairness.”
Hendrickson's attorney, Arnold Cohen, said Hendrickson has been out of work since the appeals court ruling and will now move to return to work.
“The court corrected a bad decision,” said Cohen, of Newark's Oxfeld Cohen.
The DCA was represented by the Attorney General's Office, which didn't respond to a request for comment.
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