In a recent ruling, the Appellate Division of the Supreme Court of New York decided on a case involving the salary increases for police chiefs in Cohoes. The court upheld a lower court's decision that denied a request from the police chiefs for a 7.01% salary increase, instead affirming that they are entitled to a 4% increase. This ruling affects Todd Waldin, the chief of police, and his assistant chief, and highlights the complexities of salary negotiations within public service.

The case, titled Matter of Waldin v. City of Cohoes (Docket No. CV-25-1006), was decided on November 5, 2026. It underscores the legal intricacies surrounding employment contracts and salary negotiations for public employees, particularly those in law enforcement. The outcome is significant for public sector employees who may find their salary increases governed by collective bargaining agreements.

Background

The dispute arose between Todd Waldin and the City of Cohoes regarding salary increases for the police chiefs. Waldin and his assistant chief sought to challenge the city's decision to grant them only a 4% salary increase, which was the same increase given to an animal control officer in the same bargaining unit. They argued that they should instead receive a higher increase of 7.01%, which was the percentage increase given to certain police officers who were restructured into a new salary category.

The police officers in Cohoes are represented by a union, and their salaries are determined by a memorandum of agreement (MOA) that outlines the terms and conditions of employment. The MOA had been modified to include a restructuring of the salary chart for police officers, which allowed some officers to receive significant raises due to their reclassification. However, the chiefs, not being part of the union, were subject to different terms under the city code, which stated that their salary increases could not be less than the highest percentage negotiated for any category of employee in the bargaining unit.

The police chiefs filed a proceeding under CPLR article 78, which allows individuals to challenge the actions of government agencies. They sought to compel the city to grant them the higher salary increase based on their interpretation of the city code. The case eventually made its way to the Appellate Division after the Supreme Court dismissed their petition.

The Ruling

The Appellate Division ruled against the police chiefs, affirming the lower court's decision. The judges concluded that the language of the city code clearly indicated that the chiefs were entitled to annual salary increases that matched the highest percentage negotiated for any employee in the bargaining unit. The court noted, "The plain meaning of that language requires that petitioners' raises match the highest negotiated 'annual' percentage increase in salary."

The judges emphasized that the only increase that qualified as an annual raise in 2025 was the 4% increase awarded to the animal control officer. The court further clarified that the increases received by police officers due to the restructuring were not considered annual increases, as they were one-time adjustments to their salaries. The court's decision highlighted the importance of statutory interpretation in determining the rights of public employees.

Judges Reynolds Fitzgerald, Fisher, McShan, Mackey, and Corcoran all concurred with the ruling, which effectively upheld the lower court's dismissal of the police chiefs' petition. They noted that the chiefs failed to demonstrate a clear legal right to a higher salary increase and did not provide sufficient evidence that the 4% raise was unlawful or irrational.

Impact

This ruling has broader implications for public sector employees, particularly those in law enforcement. It reinforces the idea that salary increases for public employees can be tightly regulated by collective bargaining agreements and local laws. The decision indicates that even if certain employees may feel entitled to higher wages based on restructuring or other factors, they must rely on the specific language of the governing agreements and statutes.

The outcome also highlights the challenges faced by public employees who are not part of a union. In this case, the police chiefs found themselves at a disadvantage because their salary negotiations were not aligned with the terms negotiated for unionized officers. This could serve as a precedent for similar cases in the future, where non-union public employees may seek to challenge salary decisions based on union agreements.

What's Next

While the court's ruling is final in this case, it is possible that the police chiefs may consider further legal options or appeals. However, details were not available in the court filing regarding any plans for an appeal or related cases. The ruling stands as a significant legal interpretation of salary negotiations for public employees in New York.