ADMINISTRATIVE LAW

01-2-6463 In the Matter of Del Valle, Union County, App. Div. (per curiam) (9 pp.) Del Valle, who worked for the Union County Department of Human Services from 1994 until 2012, appealed the final decision of the Civil Service Commission that determined that she did not have displacement rights to a former job title after being laid off from her current position. The panel affirmed, finding that, based on its independent review of the record, there was no arbitrary, capricious or unreasonable action by the agency in denying her appeal where the record showed that she never held the title of HSS2 but held only the separate title of HSS2-Bilingual. It found her reliance on a personnel form she signed in 1999 listing her title as HSS2 was misplaced since that form contained the job code for her actual position of HSS2-Bilingual. Moreover, the form was not part of her official employment record and the agency’s practice of resolving title dispute appeals through reference to official employment records was plainly reasonable. The panel rejected her claim that she was entitled to displacement rights over the HSS2 title because the IMW title was consolidated into the HSS title, finding that the agency rationally found that the IM job title series was not the same as the HHS series.