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Hon. Joan R. Salzman retires from OATH. On December 10, 2025, the OATH Trials Division honored retiring Supervising Law Judge and Deputy Commissioner Joan R. Salzman, with a festive luncheon attended by over 50 people, including former Trials Division administrative law judges and law clerks, and employees from across the many divisions within OATH. Chief Judge Asim Rehman presented Judge Salzman with a Mayoral proclamation honoring her service and declaring December 10, 2025, “Judge Salzman Day,” and many colleagues spoke to share their memories of working with Judge Salzman.

Born in Brooklyn, Judge Salzman is a graduate of Yale College and Harvard Law School. Judge Salzman joined OATH in 2005 as an administrative law judge, before leaving in 2015 to become Executive Director of the Federal Bar Council, a nonprofit professional association of judges and attorneys from courts within the Second Circuit. She became a New York State administrative law judge in 2018, before rejoining OATH in 2020 as a judge in the Trials Division. In December 2022, she became Supervising Administrative Law Judge and Deputy Commissioner of the Trials Division. In that capacity, Judge Salzman led a team of fifteen administrative law judges, in addition to the calendar, administrative, and law clerk units. Judge Salzman has also served as an adjunct professor at Baruch College/Marxe School of Public and International Affairs, where she taught government ethics in the graduate Executive MPA Program. She serves as Vice President of the New York State Association of Administrative Law Judges.

Judge Salzman is widely known for her intellectual rigor, for the in-depth, comprehensive analysis contained in her written decisions, and for the preparedness and empathy that she shows in case conferences. She is equally known and respected for her deep commitment to fairness, to providing access to justice to unrepresented New Yorkers, and to maintaining the integrity and independence of the tribunal.

Judge Salzman’s last day at OATH was December 31, 2025. Judge Faye Lewis, who has served as an administrative law judge at OATH since 1991, has assumed the role of Acting Supervising Law Judge and Deputy Commissioner for the Trials Division.

Johanna C. Segal promoted to Supervising Law Clerk. Ms. Segal will oversee the Trials Division legal research unit that supports the Administrative Law Judges in all matters that come before the OATH Trials Division. Ms. Segal joined OATH as a Law Clerk in 2023, and prior to that she was an agency attorney with the New York City Commission on Human Rights. Ms. Segal holds a B.A. from Bryn Mawr, a J.D. from CUNY School of Law, and an MSW from the NYU Silver School of Social Work.

Job opportunities at OATH: OATH Trials Division is seeking recent law school graduates for the position of Law Clerk. Working directly with OATH’s Administrative Law Judges, Law Clerks engage in legal research and writing on cases involving civil servant discipline, consumer and worker protection matters, taxi and rideshare licensing, contract disputes involving the city, as well as cases falling under the Campaign Finance Law, Human Rights Law, Conflict of Interest Law, and more.

This position promotes access to justice in New York City. For more details visit https://cityjobs.nyc.gov/ and search for Job ID 758404 (Law Clerk).

CityAdmin Notice: The OATH decision database has moved. The CityAdmin Document Repository is now hosted by the City of New York and can be found here: https://nyc.mindbreeze.com/search/apps/cityadmin/.

Contract Dispute Resolution Board Panelists: OATH is accepting applications from qualified persons to serve on Contract Dispute Resolution Board (CDRB) panels. CDRB panels hear the final appeal in a three-step dispute resolution process contained in City contracts for construction, goods and services. Each CDRB panel consists of an OATH Administrative Law Judge, as chair, a representative of the Mayor’s Office of Contract Services, and a third member selected from a pre-qualified roster of individuals, established and administered by OATH, who has appropriate expertise and is unaffiliated and not employed by the City.

Those interested in being added to the roster of pre-qualified individuals are encouraged to apply. Applicants should have a background and experience in government contracting, construction, engineering or related law. The application form, as well as more information on the panelist role, can be found here. Completed applications should be sent via e-mail to the OATH Trials Division Law Clerks, LawClerks@oath.nyc.gov.

Trials Division

Real Property

Closure of Premises Recommended.

ALJ Christine Stecura recommended closure of a premises being used for dead storage of motor vehicles, junk salvage storage, and as a contractor’s yard in an area zoned for residential use in violation of the New York City Zoning Resolution. Dep’t of Buildings v. 120 Sapphire Street & 122 Sapphire Street, Brooklyn, New York, OATH Index No. 328/26 (Nov. 24, 2025), adopted, Comm’r Dec. (Dec. 8, 2025).

Read more about Dep’t of Buildings v. 120 Sapphire Street & 122 Sapphire Street, Brooklyn, New York.

Licensing

Civil penalty recommended.

ALJ Charlotte E. Davidson recommended a $20,000 civil penalty for a company licensed by the Business Integrity Commission that failed to keep in its vehicle a six-month inspection form and a daily vehicle inspection report. Business Integrity Comm’n v. Queens County Carting Inc, OATH Index No. 2448/25 (Nov. 20, 2025).

ALJ Jonathan Fogel recommended license revocation, a civil penalty and restitution to 29 consumers, where a company engaged in booting motor vehicles in violation of applicable law and rules. Dep’t of Consumer & Worker Protection v. B&M Electronic Diagnostic Repair Service Inc., OATH Index No. 1869/23 (Oct. 20, 2025).

Read more about Business Integrity Comm’n v. Queens County Carting Inc. and other Licensing cases.

Appeals from the Hearings Division

An appellate decision affirmed a hearing decision dismissing a violation § 80-12(e) of the Taxi and Limousine Commission rules for threats, harassment, or abuse committed while performing a licensee’s duties. In the unsworn summons, petitioner alleged respondent parked his for-hire vehicle in front of the complaining witness’s house, threatened to kill her dog, who was in the yard, and called her and her family “dogs.” The appellate division agreed with the hearing officer’s decision dismissing the charge, noting that the proper focus in determining whether a respondent was performing the duties and responsibilities of a licensee is on whether a licensed vehicle is involved and the public nature of the conduct, and finding that the respondent’s vehicle was not involved in the dispute. TLC v. Liu, Miao, Appeal No. 10277692C (November 12, 2025).

An appellate decision affirmed two hearing decisions sustaining two violations of § 151.02(a) of the Health Code, one issued for failure to eliminate conditions conducive to pests and the other for failure to keep premises free from pests. At the hearing, respondent denied both charges and submitted invoices for monthly professional extermination services. The appellate decision deferred to the hearing officer’s credibility finding regarding respondent’s denial of harborage conditions and active rat signs and agreed that a respondent cannot claim as a defense to the active rat signs violation that adequate measures were taken to prevent pests if at the same time harborage conditions were present. DOHMH v. My 12 Gods LLC, Appeal No. 2500905 (November 20, 2025).

An appellate decision reversed a hearing decision dismissing charges issued against the premises owner relating to transient use. At the hearing, respondent moved to dismiss on the ground of improper party, submitting a deed showing that it had sold the property on the date of occurrence. The hearing officer found that respondent was an improper party. The appellate decision concluded that respondent was properly named as a party because respondent failed to show that the sale was completed before the time of inspection and cited to no authority showing that ownership would be considered transferred before the transaction was completed. DOB v. 699 Rutland LLC, Appeal No. 2501155 (November 20, 2025).