How NYC Pays for Lawsuits: The $2B Tab, Gulino, and Agency Budgets

TL;DR

• New York City resolved 14,170 claims and lawsuits for a record $2.04 billion in Fiscal Year 2025, topping FY 2024’s $1.94 billion and roughly doubling the historic $1.0 billion annual baseline.
• City legal payouts averaged $1.0 billion annually for a decade. They surged starting in FY 2022 due to massive employment class actions, rising special education claims, and multi-million-dollar roadway design verdicts.
• The single costliest case in NYC history is Gulino v. Board of Education, a 1996 federal lawsuit over discriminatory teacher certification tests. The City is paying out $1.35 billion to $1.8 billion across a structured schedule running through FY 2028.
• Street and healthcare liabilities add up quietly. Over the trailing five-year period from FY 2019 through FY 2023, Department of Transportation (DOT) torts cost taxpayers $466.6 million, NYC Health + Hospitals cost $437.7 million, and the NYPD accounted for $1.15 billion.
• Mayoral agencies like the NYPD and DOT do not pay for their own mistakes. Their tort settlement checks are drawn from a central General Fund line item called Agency 098 (Miscellaneous Budget), insulating agency commissioners from the financial consequences of operational failures. The Department of Education pays special-education due-process cases from its own budget, and NYC Health + Hospitals reimburses the City for its malpractice costs.

Every spring, City Hall stages an intense public drama over the municipal budget. Mayors threaten library closures, pool shutterings, and hiring freezes to close projected deficit gaps. City Council members hold marathon hearings to fight for after-school slots and park maintenance crews.

Yet quietly, on a separate line item that receives almost no public debate, the City writes about two billion dollars in checks every year to settle legal claims.

In Fiscal Year 2025, New York City resolved 14,170 claims and lawsuits for $2.04 billion, according to the Comptroller’s Claims Dashboard as of September 2026 [1]. That is the highest annual total on record, topping the $1.94 billion the Comptroller called the most ever for Fiscal Year 2024 [1]. It represents roughly $240 for every man, woman, and child living in the five boroughs. It is about the size of the Department of Sanitation’s entire FY 2025 budget, and it runs more than three times the size of the Parks Department’s [2].

The dashboard updates continuously, so recent-year totals rise as late settlements are recorded. FY 2024 has since grown to $1.99 billion on the same dashboard [1].

Most New Yorkers assume these settlement dollars flow almost entirely to victims of police misconduct. News outlets cover NYPD payouts closely, reporting on the $200 million to $266 million in annual police settlements each year [3]. That reporting is essential, but it captures only a fraction of the city’s balance sheet.

The largest single settlement check City Hall writes today funds a 30-year-old lawsuit over a public school teacher certification exam. Neglected street redesigns, sidewalk hazards, and municipal hospital malpractice claims quietly consume hundreds of millions more.

The money moves through a unique bureaucratic structure that protects agency heads from the costs of their own errors. Here is how New York City’s legal settlement machine actually operates, where the billions go, and why the system resists reform.

The $2 Billion Tab: Inside NYC’s Record Legal Payouts

To understand how rapidly city legal payouts have escalated, look at the historical baseline. Between FY 2014 and FY 2021, total annual settlement spending hovered around $1.0 billion per fiscal year [4]. It was a predictable cost of doing business for a municipal corporation with over 300,000 employees, hundreds of hospitals and clinics, and 6,000 miles of paved streets.

That baseline collapsed in FY 2022. Payouts jumped to $1.56 billion, followed by $1.45 billion in FY 2023, before climbing to $1.94 billion in FY 2024 and $2.04 billion in FY 2025 [1, 4].

The Comptroller’s Office classifies all legal resolutions into two broad categories: tort claims and law claims [4].

Tort claims cover personal injury and property damage. These include motor vehicle collisions involving city vehicles, pedestrian trips on cracked sidewalks, medical malpractice in municipal facilities, and police civil rights violations. In FY 2024, tort settlements surpassed $1.04 billion, driven by rising jury verdicts and inflation in medical care costs [1].

Law claims encompass contract disputes, salary controversies, employment discrimination actions, and special education tuition reimbursements. In FY 2024, law claims accounted for approximately $900 million [1].

This category expanded rapidly over the last three years. The primary driver was the resolution of multi-decade class actions that finally reached their court-ordered payout phases.

For context, FY 2024’s $1.94 billion represents nearly 1.6% of New York City’s entire $127 billion annual budget [5]. Every dollar goes toward past harms, deferred roadway repairs, and decades of contested litigation.

The Budget Shell Game: Why the NYPD and DOT Never Pay for Their Mistakes

When a private corporation faces a surge in legal liabilities, the division responsible absorbs the pain. The division head cuts expenses, lays off staff, or cancels capital projects to balance the books. In New York City municipal government, the opposite occurs.

Under the City Charter, mayoral agencies like the NYPD and DOT are insulated from the direct financial fallout of their own conduct.

Section 93(i) of the New York City Charter gives the City Comptroller the authority to settle and adjust all claims in favor of or against the City [6]. The Comptroller’s internal Bureau of Law and Adjustment (BLA) investigates claims before they become formal lawsuits. If a claim cannot be settled pre-litigation, the City Law Department, led by the Corporation Counsel, defends the agency in state or federal court [7].

The key structural mechanic sits in the city budget. For tort claims against mayoral agencies like the NYPD and DOT, settlements and judgments are not deducted from the budget of the department that caused the injury. They are paid out of a central administrative account: Agency 098 (Miscellaneous Budget), Unit of Appropriation 002 (Other Than Personal Services), object code 719, Judgments and Claims [8]. Two large exceptions carry their own costs. The Department of Education pays special-education due-process cases, also known as Carter cases, from its own Due Process Cases budget, $1.49 billion in Fiscal 2026 [23]. NYC Health + Hospitals files and defends its own malpractice claims and reimburses the City for its malpractice costs (see the H+H section below) [22].

Agency 098 is funded by the City’s General Fund, which relies primarily on real property taxes, personal income taxes, and sales tax revenue [5].

This framework creates a classic moral hazard:

1. No Operational Penalty: If an NYPD precinct generates repeated misconduct settlements, the Police Commissioner’s operational budget does not shrink by a dollar. The money comes out of central tax reserves.
2. No Maintenance Incentive: If the Department of Transportation defers resurfacing a known dangerous corridor, the resulting multi-million-dollar wrongful death verdicts do not cut into DOT paving budgets. Taxpayers absorb the bill through Agency 098.
3. Chronic Underbudgeting: In the two most recent audited years, the Mayor’s Office of Management and Budget (OMB) set the Judgments and Claims line well below what the City spent. In Fiscal 2025 the Adopted Budget set aside $877 million for judgments and claims and the City spent $1.38 billion; in Fiscal 2024 it budgeted $1.16 billion and spent $1.52 billion [24]. OMB relies on mid-year budget modifications to transfer money from the General Reserve to cover the shortfall [5].

Former Comptroller Brad Lander pushed to dismantle this setup. In his office’s reports, including the 2023 investigation Wreckless Spending, Lander advocated for an “Agency Accountability” model [9]. Lander left office December 31, 2025. Mark Levine, the former Manhattan Borough President, was sworn in as the city’s 52nd Comptroller on January 1, 2026, and now runs the Bureau of Law and Adjustment that settles these claims [21].

His proposal would require mayoral agencies to budget for their own historical claims risk. If an agency reduced its crash rates or excessive force claims, it could retain the surplus to spend on operational upgrades. If its liabilities surged, the commissioner would have to find offsets within their departmental budget.

The proposal has faced resistance from mayors and agency commissioners. Department heads argue that shifting liability would lead to operational chaos. If a rogue employee causes a catastrophic crash resulting in a $20 million judgment, an agency could be forced to lay off dozens of frontline workers.

For now, the central General Fund continues to absorb the entire tab.

The 30-Year Lawsuit: How Gulino v. Board of Education Created a $1.8 Billion Obligation

To understand why the city’s non-tort legal payouts exploded after 2021, trace a class action filed in Manhattan federal court when Bill Clinton was president.

In November 1996, Elsa Gulino, a teacher in New York City public schools, joined three colleagues to file a class action in the U.S. District Court for the Southern District of New York: Gulino v. Board of Education of the City School District of the City of New York (Docket No. 96-cv-08414) [10].

The lawsuit challenged two teacher certification tests required by New York: the National Teacher Examination (NTE) and the Liberal Arts and Sciences Test (LAST).

For decades, passing the LAST exam was a statutory requirement to obtain a permanent New York State teaching certificate. Teachers who failed the exam were barred from permanent employment. They were demoted to substitute status, received lower salaries, missed out on health insurance tiers, and lost seniority rights.

The plaintiffs demonstrated stark racial disparities. White test-takers passed the LAST exam at rates exceeding 90%. Black and Latino candidates passed at rates between 50% and 60% [11].

Under Title VII of the Civil Rights Act of 1964, employment tests with an adverse racial impact are unlawful unless the employer can prove the examination is job-related and consistent with business necessity.

In December 2012, after 16 years of litigation, Senior U.S. District Judge Kimba M. Wood issued a 106-page liability ruling [11]. She ruled that the Board of Education failed to demonstrate that the LAST exam measured the essential skills required to teach in a New York City public school. The test relied on broad memorization of art history, literature, and general science, rather than pedagogical competence.

Because the Board of Education used the test to hire, fire, and compensate educators, the City was held strictly liable for employment discrimination.

The scale of the relief phase was unprecedented. Over 5,200 Black and Latino educators qualified as class members [10]. In May 2014, Judge Wood appointed Special Master John S. Siffert, a veteran Manhattan litigator, to oversee the calculation of individual damages under Federal Rule of Civil Procedure 53 [12].

Siffert established a complex adjudicative process. Claimants submitted work histories dating back to 1994. Siffert’s team constructed a “counterfactual career trajectory” for each educator, calculating what they would have earned if they had never failed the exam [10].

The total damages award spans four major components:

1. Back Pay ($800M–$900M): The difference between the lower earnings teachers received as substitutes and the higher union scale salaries of permanent teachers over two decades.
2. Prejudgment Interest ($300M–$400M): Because the injuries occurred in the 1990s and 2000s, statutory interest compounded over decades. For many teachers, accrued interest equals or exceeds their base back pay award.
3. Pension Contributions ($300M–$400M): The court ordered the City to make retroactive employer contributions into the Teachers’ Retirement System of the City of New York (TRSNYC) and the Board of Education Retirement System (BERS). This bought back decades of lost service credits, allowing hundreds of retired teachers to collect Tier 4 pensions rather than Tier 6 benefits [13].
4. Attorneys’ and Special Master Fees ($100M+): Siffert and class counsel, led by the Center for Constitutional Rights and Outten & Golden LLP, receive periodic court-approved fee distributions for thousands of hours of claims adjudication [14].

Recognizing that a single lump-sum payout of nearly $2 billion would drain city reserves, the City Law Department negotiated a structured payout schedule running over seven fiscal years, from FY 2022 through FY 2028 [4].

The City paid $366.8 million in FY 2022 and $218.8 million in FY 2023 for Gulino judgments [4]. Payouts continue today as Special Master Siffert processes the final waves of claims. In Comptroller reports, the projected direct judgment cost is cited at $1.35 billion, with fully loaded pension, interest, and tax liabilities expected to reach $1.8 billion to $2.0 billion by the time the case formally closes in 2028 [1, 4].

For our complete analysis of public school budgeting and administrative mandates, read our guide to how NYC public schools work.

The Street Liability Ledger: How DOT Incurs $100M+ Annually in Torts

While the Board of Education manages historic class actions, the Department of Transportation runs a continuous, high-volume personal injury ledger.

Over the five-year window from FY 2019 through FY 2023, the City paid $466.6 million to settle tort claims filed against the Department of Transportation [4]. That is an average of $93.3 million every year, roughly equivalent to “a half billion dollars every five years.”

The volume of claims is immense. In FY 2023 alone, New Yorkers filed 3,892 new tort claims against DOT [4]. They allege bent bicycle rims from deep potholes, fractured hips on cracked sidewalks, and catastrophic vehicle wrecks on poorly configured arterial roads.

New York City operates under two powerful statutory shields designed to protect taxpayers from street liability. Yet the City still pays out nearly $100 million annually.

1. The 1979 Pothole Law (Prior Written Notice)

Under NYC Administrative Code § 7-201(c)(2), commonly known as the “Pothole Law,” a person injured by a street or sidewalk defect cannot sue the City unless the City had prior written notice of the condition at least 15 days before the incident occurred [15].

For decades, personal injury lawyers bypassed this shield through a unique private operation: the Big Apple Pothole and Sidewalk Protection Corporation. The corporation hired scouts to walk every foot of the city’s sidewalks and roadways, mapping defects onto massive cartographic charts.

They filed these maps with DOT quarterly, establishing legal notice for hundreds of thousands of sidewalk cracks and potholes simultaneously. While digital mapping has modernized the process, proving prior written notice remains the central battle in street litigation.

2. The 2003 Sidewalk Law (Administrative Code § 7-210)

In 2003, Mayor Michael Bloomberg signed Local Law 49, adding Section 7-210 to the Administrative Code [16]. The statute shifted legal liability for sidewalk slips, trips, and falls from the City to private property owners.

If you slip on ice or trip over an uneven sidewalk flag outside an apartment building, office tower, or store, you must sue the property owner directly. The City bears no liability for those sidewalks.

The statute carries a major carve-out: one-, two-, and three-family residential properties that are owner-occupied remain exempt [16]. If you trip outside a single-family rowhouse in Queens, Brooklyn, or Staten Island, the City remains liable.

Where the Big Money Goes: Negligent Roadway Design

While tabloids often focus on minor trip-and-falls, DOT’s claims ledger shows that catastrophic roadway design cases drive the vast majority of settlement dollars [4]. These claims involve traffic crashes resulting in death, paralysis, or traumatic brain injury.

In these lawsuits, plaintiffs argue that DOT knew an intersection or arterial corridor had dangerous sightlines, missing pedestrian signals, or inadequate safety barriers, yet failed to redesign it.

In FY 2023, one of the city’s top tort settlements was a $6.95 million payout to the family of a driver killed on the Harlem River Drive [4]. The victim had pulled over to change a flat tire and was struck by another vehicle. The lawsuit demonstrated that DOT had prior written notice of dangerous conditions on that stretch of highway from numerous prior collisions, but had failed to install adequate shoulders or safety infrastructure.

When DOT delays a street redesign or defers highway guardrail repairs, the financial penalty never touches DOT’s balance sheet. It appears years later as a seven-figure check drawn from Agency 098.

To see how municipal street jurisdiction compares to regional transit operations, review our guide to how the MTA is funded.

NYC Health + Hospitals: The Slow Tail of Medical Malpractice

The second major municipal entity consuming roughly a half billion dollars every five years is NYC Health + Hospitals (H+H).

Between FY 2019 and FY 2023, tort claim payouts for Health + Hospitals totaled $437.7 million, averaging $87.5 million per year [4].

Health + Hospitals is a public benefit corporation operating the country’s largest municipal healthcare system, including 11 acute-care hospitals like Bellevue, Elmhurst, and Kings County. Unlike private hospital networks, H+H serves every patient regardless of ability to pay or immigration status.

Medical malpractice claims against H+H carry unique characteristics:

• The Adjudication Lag: Malpractice claims take between five and ten years to reach a trial verdict or settlement [4]. An obstetric claim filed over a birth injury in 2014 often does not settle until 2023 or 2024. Payouts recorded in recent fiscal years reflect clinical practices from the Bloomberg and early de Blasio administrations.
• Catastrophic Severity: While H+H faces relatively few claims compared to the NYPD or DOT (398 malpractice claims filed in FY 2023, down from 629 in FY 2015), the payouts per case are enormous [4]. Brain damage claims, delayed cancer diagnoses, and surgical errors routinely settle for $5 million to $10 million.
• Downside Turnaround: H+H represents one of the few areas where targeted risk management has successfully lowered costs. Annual settlement payouts dropped from $124.9 million in FY 2014 to $54.5 million in FY 2023, a reduction of over 56% [4]. The system achieved this by implementing standardized labor-and-delivery protocols and early dispute mediation programs.

H+H also runs on a different claims track than the NYPD or DOT. A claim against H+H is filed directly with H+H’s own Office of Legal Affairs instead of the Comptroller’s Bureau of Law and Adjustment, and H+H defends most of its own malpractice cases. H+H has reimbursed the City for a share of its malpractice-related costs since fiscal year 2002; the Independent Budget Office estimated that reimbursement at roughly $285 million in Fiscal Year 2023, covering malpractice insurance, H+H’s share of fringe benefits, and retiree health costs, against a roughly $17 million annual credit the City budgeted back to H+H over Fiscal Years 2023 through 2025 for keeping claims volume down [22].

The Hidden Drivers: Rikers Island and Special Education Claims

Beyond the NYPD, DOT, and Gulino, two other municipal flashpoints generate hundreds of millions in annual payouts: jail conditions and special education placements.

Department of Correction (DOC): The Violence Surcharge

Over the five years from FY 2019 through FY 2023, the City paid $189.7 million to resolve tort claims against the Department of Correction [4].

These settlements stem from conditions inside the Rikers Island jail complex. Claims involve detainee-on-detainee stabbings, assaults by correction officers, and medical neglect inside intake facilities.

The litigation operates in the shadow of Nunez v. City of New York, a 2011 class action that placed the Department of Correction under the oversight of a federal court monitor [17]. Monitor reports repeatedly document unconstitutional levels of violence, excessive use of force by staff, and systemic management failures.

In FY 2023, DOC payouts totaled $38.0 million [4]. City officials expect this figure to climb as federal court dockets resolve dozens of severe injury claims pending from the 2021 to 2023 operational crisis on Rikers Island.

Department of Education: Carter Special Education Tuition Cases

While tort claims capture headlines, the fastest growing category of municipal law claims involves special education tuition reimbursement.

Under the federal Individuals with Disabilities Education Act (IDEA), New York City is legally required to provide every child with a free and appropriate public education (FAPE) suited to their unique needs [18].

When the Department of Education fails to provide an adequate Individualized Education Program (IEP) or cannot offer a seat in a specialized public school classroom, federal law allows parents to enroll their child in a private specialized school and sue the City for tuition reimbursement.

These legal actions are known as Carter cases, named after the 1993 U.S. Supreme Court decision Florence County School District Four v. Carter [19].

Special education claim settlements have expanded rapidly:

In FY 2023, special education settlements reached $397.0 million [4]. They accounted for 56% of all law claim payouts and 89% of all law claim resolutions that year.

The system is inefficient. Wealthy families who can afford upfront private tuition payments hire specialized education attorneys to file due process complaints. The City routinely defaults or settles these cases because public school programs lack the staffing or clinical seats to accommodate the children.

The settlements pay tuition bills and legal fees rather than expanding the city’s internal special education capacity.

The Civic Watchdog Toolkit: How to Track Claims and Fix Neighborhood Hazards

Municipal liability numbers often feel abstract. For residents, however, city claims data offers a practical way to inspect neighborhood infrastructure and advocate for safety repairs.

Here is how to monitor city settlements and use the law to force physical repairs on your block.

1. Inspect the Comptroller’s Claims Dashboard

In April 2025, the Comptroller’s Office retired static annual PDF reports and launched the interactive Claims & Settlements Dashboard [20].

The dashboard allows community boards, civic associations, and investigative reporters to track which intersections and precincts generate the highest payout concentrations across the city.

2. Using 311 to Establish Prior Written Notice

If you notice a dangerous street crater, a broken curb, or a collapsed sewer basin, calling 311 or logging a report via the 311 app does more than request maintenance. It establishes legal accountability.

Under Administrative Code § 7-201, that digital record proves the City had prior written notice. If DOT fails to repair the defect within its statutory window and an injury occurs, the City cannot claim it was unaware of the hazard.

3. Track City Council Budget Oversight Hearings

Every March, the City Council holds preliminary budget oversight hearings under the Finance Committee [5]. Committee chairs question commissioners from the NYPD, DOT, DOC, and DOE regarding agency spending trends.

Residents can attend in person at City Hall or testify remotely via Microsoft Teams. Directing questions about rising agency settlement costs during public comment periods forces agency leaders to address why their operational failures continue to drain taxpayer reserves.

To see how the City Council exercises its oversight powers and controls budget amendments, explore our guide to how the NYC budget process works.

What Happens Next: The Fiscal Outlook Through 2028

New York City’s legal payout tab will remain elevated through at least 2028.

The negotiated payment schedule for Gulino v. Board of Education runs through FY 2028, requiring hundreds of millions more in annual disbursements to resolve retroactive pension and salary claims [4, 10]. Special education due process claims continue to drain roughly $400 million annually from municipal education funds.

Meanwhile, inflation in catastrophic healthcare costs will continue to drive seven-figure verdicts against the Department of Transportation and the Police Department.

Without structural reforms like former Comptroller Lander’s Agency Accountability chargeback proposal or enforceable safety mandates, mayoral agencies like the NYPD and DOT will remain insulated from the financial consequences of their actions.

Settling decades-old lawsuits and paying for deferred roadway maintenance pulls hundreds of millions of dollars away from classroom instruction, transit repair, and neighborhood services every year. Tracking these payouts makes the real financial cost of municipal mismanagement visible.

Sources & Primary Documentation

1. NYC Comptroller’s Office. “Comptroller Lander’s New Dashboard Tracks City Claims & Settlements; City Paid Nearly $2B in Settlements Last Fiscal Year,” Press Release (April 30, 2025; figures as of April 25, 2025). Documenting FY 2024 total payouts ($1.94B) across 13,397 resolved claims. comptroller.nyc.gov/newsroom/comptroller-landers-new-dashboard-tracks-city-claims-city-paid-nearly-2b-in-settlements-last-fiscal-year/. Also: NYC Comptroller Claims Dashboard, Claims Filed & Settled, FY 2025 ($2,039,234,380 across 14,170 claims settled; accessed 2026-09-28), comptroller.nyc.gov/services/for-the-public/claims-dashboard/claims-filed-settled/; and Trends Data, FY 2024 ($1,987,415,252 across 13,676 claims settled; accessed 2026-09-28), comptroller.nyc.gov/services/for-the-public/claims-dashboard/trends-data/.
2. New York City Council Finance Division. Fiscal 2025 Preliminary Plan Finance Division Briefing Papers (March 2024), Table 1 Financial Summary, FY24 Adopted column: Department of Parks and Recreation ($638.2 million), Department of Health and Mental Hygiene ($2,104.8 million), Department of Sanitation ($1,901.4 million). FY 2025 figures: Fiscal 2026 Preliminary Plan briefings (March 2025), FY25 Adopted: Department of Sanitation ($1,947.5 million), Department of Parks and Recreation ($618.1 million); Fiscal 2027 Preliminary Plan briefings (March 2026), FY25 Actual: Department of Sanitation ($2,057.9 million), Department of Parks and Recreation ($650.8 million).
3. The Legal Aid Society - Cop Accountability Project. “NYC Lawsuit Payouts for Police Misconduct Trackers, 2022–2025,” (Published annually).
4. Office of the New York City Comptroller. “Annual Claims Report, Fiscal Year 2023,” Bureau of Law and Adjustment (Published April 16, 2024). Documenting 10-year historical payout tables, tort and law claims splits, Gulino payouts, and agency breakdowns.
5. NYC Daily TL;DR. “How the NYC Budget Process Works: A Resident’s Guide,” (Published May 2026; updated June 2026). Explaining Charter § 236, § 249, and § 258 Financial Plan modifications.
6. New York City Charter. Chapter 5, § 93(i). “Powers and Duties of the Comptroller: Settlement of Claims.”
7. New York City Charter. Chapter 17, § 394. “Powers and Duties of the Corporation Counsel: Defense of Actions.”
8. Mayor’s Office of Management and Budget (OMB). Expense Budget (NYC Open Data, mwzb-yiwb), Agency 098 (Miscellaneous), Unit of Appropriation 002 (Other Than Personal Services), budget code 2007, object code 719 (Judgements and Claims), Preliminary, Executive and Adopted publications, Fiscal Years 2024 to 2027. data.cityofnewyork.us/resource/mwzb-yiwb
9. Office of the New York City Comptroller. “Wreckless Spending: The Accelerating Cost of City Car Crash Settlements,” Policy Report (February 2023). Proposing Agency Accountability reforms.
10. United States District Court for the Southern District of New York. Gulino v. Board of Education of the City School District of the City of New York, Docket No. 1:96-cv-08414. Memorandum Decisions and Special Master Orders.
11. Wood, Kimba M., U.S. District Judge. Gulino v. Board of Education, 907 F. Supp. 2d 492 (S.D.N.Y. 2012). Finding liability under Title VII for use of the Liberal Arts and Sciences Test.
12. Federal Rules of Civil Procedure. Rule 53 (“Masters”) and Rule 54(b) (“Judgment on Multiple Claims”).
13. Teachers’ Retirement System of the City of New York (TRSNYC). “Annual Comprehensive Financial Report (ACFR), Fiscal Year Ended June 30, 2024.” Reporting actuarial impact of Gulino service credits.
14. Center for Constitutional Rights. Gulino v. Board of Education Litigation Overview and Class Counsel Filings.
15. New York City Administrative Code. Title 7, Chapter 2, § 7-201(c)(2). “Actions Against the City: Prior Written Notice Requirement (The Pothole Law).”
16. New York City Administrative Code. Title 7, Chapter 2, § 7-210. “Liability of Real Property Owner for Failure to Maintain Sidewalk.” Enacted via Local Law 49 of 2003.
17. United States District Court for the Southern District of New York. Nunez v. City of New York, Docket No. 1:11-cv-05845. Reports of the Independent Monitor Steve J. Martin (2022–2025).
18. United States Code. Title 20, Chapter 33. “Individuals with Disabilities Education Act (IDEA),” 20 U.S.C. § 1400 et seq.
19. Supreme Court of the United States. Florence County School District Four v. Carter, 510 U.S. 7 (1993). Establishing tuition reimbursement rights for private specialized placements.
20. NYC Comptroller’s Office. Interactive Claims Dashboard. Accessible at comptroller.nyc.gov/services/for-the-public/claims-dashboard/overview/.
21. FOX 5 New York. “What to know about Mark Levine, NYC’s new comptroller” (January 2026). Levine sworn in January 1, 2026, succeeding Brad Lander. fox5ny.com/news/what-know-about-mark-levine-nycs-comptroller
22. New York City Independent Budget Office. “A Life Line? An Examination of City Operating Support to New York City Health + Hospitals,” Fiscal Brief (November 2022). H+H reimburses the City for malpractice insurance, H+H’s share of fringe benefits, and retiree health costs, estimated at roughly $285 million in Fiscal Year 2023, against a roughly $17 million annual credit budgeted back to H+H for Fiscal Years 2023-2025. ibo.nyc.gov. Claims-filing practice per NYC Health + Hospitals Office of Legal Affairs service requirements and the Comptroller’s Annual Claims Report, Fiscal Year 2023.
23. New York City Council Finance Division. “Report on the Fiscal 2027 Preliminary Plan, the Fiscal 2027 Preliminary Capital Commitment Plan, and the Fiscal 2026 Preliminary Mayor’s Management Report for the Committee on Education” (March 2026). Due Process Cases budget, “also known as Carter Cases,” $1.49 billion in Fiscal 2026 as of the Preliminary Plan (a new Unit of Appropriation, 476, carries this funding from Fiscal 2027: $1.55 billion), covering tuition payments for Carter and Connor cases and legal fees for due process cases. council.nyc.gov/budget/wp-content/uploads/sites/54/2026/03/Department-of-Education.pdf
24. NYC Comptroller. “Annual Comprehensive Financial Report” for Fiscal Year 2025 and Fiscal Year 2024, General Fund schedule of budget and actual, Judgments and claims: adopted $877.2 million, actual $1,376.2 million (Fiscal 2025); adopted $1,164.6 million, actual $1,516.8 million (Fiscal 2024). ACFR Fiscal 2025, ACFR Fiscal 2024