New York State: Where the Crimes Are

By Bennett Liebman
Government Lawyer in Residence
Albany Law School

One of the more familiar tropes in upstate New York revolves around the origins of crime. The notion has long been that crime is like the New York State Thruway. It starts at New York City and works its way up through the rest of New York State. It is regarded as one of New York City’s least attractive exports, as young urbanites branch out bringing crime to the hinterlands. The issue is whether this trope has any accuracy in 21st century New York State.

Measurements of Crime

The FBI measures seven types of criminal acts. There are four violent crimes: murder and non-negligent homicide, rape, robbery, and aggravated assault. There are three measured non-violent crimes: burglary, larceny, and motor vehicle theft. Traditionally, crime rates are measured based on the incidence of crime per 100,000 inhabitants.[1] Adding the violent crime rate and non-violent crime rate provides the overall crime rate for a given area.[2] While there are numerous precautions involved in comparing crime rates,[3] the fact is that these rates are generally used to provide a snapshot of the amount of crime occurring in any given location.

From 1965-1994, the crime rate in New York State was in the top half of the states in the country.[4] From 1965-1993, New York State’s violent crime rate was either the highest or the second-highest in the nation. The property crime rate in New York State during that period was always in the top half of all states.

Yet since 1990, the  number of crimes and the rate of crime in New York State have fallen dramatically.[5] The crime rate went from 6,363.8 crime incidents per 100,000 inhabitants (in 1990?) to 2,100 in 2014. The crime rate fell by more than two-thirds. New York State, whose crime rate was the eighth highest in the nation in 1990, ranked 47th in the nation in 2014.

The crime rate has fallen significantly in the nation as well. The index crime rate in the nation in 1990 was 5,802.7. It is, as of 2014, 2,961.6, a reduction of 49%. Thus, while crime has fallen in the nation, it has fallen far faster in New York State. In 1990, the crime rate was 9.7% higher in New York State than in the rest of the nation. By 2014, the crime rate in New York State was more than 29% lower than the national average.

The New York City Experience

In 1990, the index crime rate for New York City was 9,699.1, with a violent crime rate of 2,383.6. By 2014, that rate had decreased to 2,185.4. The crime rate had decreased in New York City by 75.4%.  (Violent crime decreased by 75.5%.) In 1990, the crime rate in New York City was 52.4% higher than the state average. In 2014, it was 5.4% over the State level. The rate of property crime in New York City was 6.2% lower in New York City than the state average. New York City’s overall crime rate was 26.2% lower than the nation as a whole.

New York City v. Urban Upstate Counties

With the huge decrease in crime in New York City, the 2014 statistics show there are areas of upstate New York that have higher overall crime rates than New York City.[6] These include the following 15 counties: Albany, Broome, Chautauqua, Chemung, Erie, Fulton, Genesee, Monroe, Montgomery, Niagara, Oneida, Onondaga, Rensselaer, Schenectady and Tompkins.

Bronx County has by far the highest violent crime rate in the State, but there are 11 upstate counties with higher crime rates than the Bronx. These are: Albany, Broome, Chautauqua, Erie, Fulton, Genesee, Monroe, Niagara, Onondaga, Rensselaer, and Schenectady.

New York County (Manhattan) has the highest crime rate of the five counties within New York City. This is certainly understandable given how many commuters work in New York County and the fact that New York County appears to be the most significant tourist destination in the country.[7] Nonetheless, there are four counties – Albany, Broome, Erie and Schenectady – that have higher crime rates than New York County.

The counties with the five highest crime rates in the state are: (1) Schenectady (3,270.9), (2) Broome (3,203.5), (3) Erie (3,076.1), (4) Albany (2,975) and (5) New York (2,908.4). Currently, the crime rate in Schenectady County is nearly 50% higher than it is in New York City.[8]

One can understand a higher crime rate for Erie County. It is right on the Canadian border. People commute to work there. It is close to the tourist area of Niagara Falls. To a certain extent, Albany serves as a commuter hub for state government workers – although the number of traditional State employees has fallen over the past quarter century.[9] But there is hardly an influx of tourists or commuters into Schenectady and Broome counties which might account for their high crime rates.

New York City v. Upstate Cities[10]

Since there are 15 upstate counties that have higher overall crime rates than New York City, it is hardly surprising that almost all of the significant upstate cities have crime rates that are considerably higher than that of New York City.[11]

Of the state’s 10 largest cities outside the metropolitan New York area,[12] nine of the ten have higher crime rates than New York City. The only significant upstate city with a lower crime rate than that of New York City is the City of Rome, the smallest of the ten largest upstate cities. Perhaps of greater significance, Rome is also the only upstate city of the ten largest cities with a lower violent crime rate than that of New York City.

Some of the upstate cities had violent crime rates that are significantly higher than that of New York City. Buffalo and Niagara Falls had violent crime rates that were more than double that of New York City.[13]

The highest overall crime rates in the upstate cities in order are: (1) Albany, (2) Niagara Falls, (3) Buffalo, (4) Binghamton, (5) Troy, (6) Syracuse, (7) Schenectady, (8) Rochester, (9) Utica, and (10) Rome.  Every city ‒ except for Rome – has a crime rate double that of New York City. Albany’s crime rate was triple that of New York City.

Again, demographic considerations might account for some of the rankings of Niagara Falls and Buffalo.[14] However, it is hard to find an outside reason for the crime rates in Albany, Binghamton and Troy.

Some Added Bright Spots

Besides the overall general improvement in crime rates, there are particular areas of the State where the crime rate is especially law. The suburban counties around New York City have low crime rates, and Putnam County – which has in recent years become more of a suburb of New York City ‒ has the lowest crime rate in the State.

The State’s rural counties also have generally low crime rates. Much of the Adirondack area also has a comparatively low crime rate. The counties of Clinton, Essex, Franklin, Hamilton, Herkimer, Lewis, Saratoga, Warren and Washington, which comprise much of the Adirondack Park area, have crime rates lower than the State average, which might seem surprising in light of their large number of tourists and their comparatively low number of residents.[15] Essex and Lewis have the third and fifth lowest crime rates in the State respectively.

This low crime rate seems most pronounced both in Warren and Saratoga counties. Besides their presence in the Adirondack Park, these counties have significant other tourist venues. Warren County has Lake George and a very large amusement park in The Great Escape. Saratoga has two racetracks, one racino, and a large performing arts center.[16]

Where the Crime Is

The New York State crime statistics demonstrate to us where the problems are. While violent crime is still comparatively higher in New York City than in much of the State, the primary locus of crime in New York State is now in the urban areas of upstate New York. The trope of criminal behavior making its way north and west from New York City no longer has any truth. Instead, Schenectady County is the county with the highest crime rate. Albany is the city with the highest crime rate. The nine largest cities in upstate New York now have higher overall crime rates and higher violent crime rates than New York City. Instead of crime following the State Thruway from New York City, crime is now like the Mohawk and Hudson Rivers flowing east and south from the high crime areas to New York City.


[1] The index crime rate — refers to the sum of these seven crimes.  The four specified violent crimes are a subset of the overall index crime rate.

[2] This paper uses data derived from the FBI’s uniform crime reports. These reports and their accompanying charts are issued by the FBI and the State Division of Criminal Justice Services. See generally and The statistics used to demonstrate current conditions are from the 2014 calendar year. See, for example,

[3] See In addition to the factors noted, the number of non-residents generally visiting or working in an area also would affect an area’s crime rate. Thus, New York County – with numerous commuters and visitors ‒ might be expected to have a higher crime rate. Similarly, counties in New York with numerous tourists (Niagara County, the counties in the Adirondacks, and Saratoga County) might be expected to have a somewhat higher crime rate. Some urban counties in upstate New York State which have experienced a downturn in employment over the past several decades due to the departure of major private employers (Erie, Monroe, Onondaga and Schenectady) might be expected to have a lower crime rate. The same might be true of a county like Sullivan County in the Catskills which has anecdotally experienced a decrease in tourism.

[4] See generally

[5] Id.


[7] See;

[8] 49.67% higher.

[9] See Danny Hakim, “Albany’s Two Payrolls: One Is Anybody’s Guess,” New York Times, July 27, 2010.

[10] Much of the information is from

[11] Id. This particular chart utilizes a slightly higher crime rate for New York City than that of in footnote 5.

[12] This excludes the cities of Yonkers, White Plains and New Rochelle in Westchester County.

[13] The highest violent crime rate for an upstate city of decent size was the City of Newburgh in Orange County. Newburgh, with a population of 28,378, had a violent crime rate that was 142.7% higher than that of New York City.

[14] Niagara Falls has proximity to Canada, a major tourism attraction in the falls, a major casino, and a large entertainment facility in Artpark.

[15] The crime rates in Oneida County and Fulton County, which are partially located in the Adirondack Park, have crime rates higher than the state average. This can be explained partially by the presence of older urban areas in these counties south of the Adirondack Park (Utica in Oneida County, Gloversville and Johnstown in Fulton County) with high crime rates.

[16] The City of Saratoga Springs, which is where the racetracks, racino and performing arts center are located, has a crime rate slightly above the State average, but considerably less than most cities in upstate New York of its population size of 27,496.

The Governor’s Power of Removal: An Added Mechanism for Ethics Enforcement in New York State

By Bennett Liebman
Government Lawyer in Residence
Albany Law School

Introduction to the New York Ethical Environment

In New York State, ethics oversight and enforcement is diffused and scattered across a wide number of agencies and authorities. Most every State agency has its own internal ethics officer[1] as well as a Procurement Integrity Officer.[2] There are three separate ethics commissions. There is a general joint commission on public ethics,[3] a legislative ethics commission[4] and an Ethics Commission for the Unified Court System.[5]

There is an overall State inspector general.[6] For specific agencies, there is a gaming inspector general,[7] a welfare inspector general,[8] a workers’ compensation fraud inspector general,[9] a Metropolitan Transportation Authority inspector general,[10] a Medicaid inspector general,[11] an inspector general for the Port Authority,[12] an inspector general for the Justice Center,[13] a New York City Watershed inspector general,[14] and an inspector general in the Department of Corrections and Community Supervision.[15] There is an independent business integrity counsel at the New York Racing Association.[16]

There is a code of ethics for State officers and employees.[17] At the local level, there is also a requirement of a code of ethics since “the governing body of each county, city, town, village, school district and fire district” is required to adopt a code of ethics.[18] The State Comptroller is required to “adopt a code of ethics setting forth standards of conduct for members of the Advisory Council for the New York State and Local Retirement Systems.”[19] Thousands of State and local government officers and employees must file financial disclosure statements.[20]

There are police review boards, and a department of investigations in the City of New York. State and local comptrollers oversee government operations as does the State Attorney General. The State Attorney General and the State Comptroller have their own public corruption efforts and have established a joint task force on public integrity.[21]

On top of that, there are district attorneys in each of New York’s 62 counties who prosecute violations of the Penal Law, and the State Attorney General also prosecutes public integrity cases.[22]

We have created a vast bureaucracy of ethics laws, codes and monitors throughout New York State. Yet, the perception has been that the integrity of New York State and local government has not been measurably improved,[23] and the federal prosecutors ‒ most notably the United States Attorney for the Southern District of New York Preet Bharara ‒ are the people actually enforcing the ethics and anti-corruption laws governing State officials. United States Attorney Bharara has won convictions against 27 public officials, including Speaker of the Assembly Sheldon Silver and State Senate leader Dean Skelos.[24]

 Federal Enforcement of the Ethics Laws

Until the early 1970’s, United States attorneys did not generally prosecute state and local officials.[25] Herbert Stern, the United States Attorney for New Jersey, has been widely credited with beginning the effort to use federal criminal laws to attack local corruption.[26]

Utilizing Stern’s example, federal prosecutors began to use federal criminal laws to pursue local corruption. New York State federal prosecutors successfully prosecuted Nassau County Republican leader Joseph Margiotta,[27] Syracuse mayor Lee Alexander,[28] Bronx borough president Stanley Simon,[29] a host of major political figures in New York City involved with the parking violations scandal of the 1980’s,[30] and other government officials.[31]

In contrast, prosecutions of major state elected officials by local district attorneys has appeared to be on the decrease as the federal law enforcement officials have largely overrun the field.[32] That has seemingly left a general ethics punishment void, as there appear to be few effective enforcement sanctions for official behavior that, while clearly improper, does not rise to the level of a federal crime. In New York State, it seems to be either a federal crime, or bust.

The suggestion here is that in order to remedy significant misconduct, we go back in time and start reusing the power of the governor to remove public officials.

The Governor’s Removal Powers

Under the State Constitution and the applicable statutes, the governor enjoys broad removal power over local and state officers. Under the Constitution, “the governor may remove any elective sheriff, county clerk, district attorney or register within the term for which he or she shall have been elected.”[33] In dealing with crimes involving bribery, “any district attorney who shall fail faithfully to prosecute a person charged with the violation in his or her county of any provision of this article which may come to his or her knowledge, shall be removed from office by the governor, after due notice.”[34]

For State officials, the Constitution provides “Except as otherwise provided in this constitution, the heads of all other departments and the members of all boards and commissions, excepting temporary commissions for special purposes, shall be appointed by the governor by and with the advice and consent of the senate and may be removed by the governor, in a manner to be prescribed by law.”[35]

Finally, the Constitution gives the Legislature the right to provide generally for the power and procedure for removals from office.[36]

Section 33 of the Public Officers Law adds to the listing of officers removable by the governor. They include “officer appointed by the governor for a full term or to fill a vacancy, whose appointment is not required by law to be made by and with the advice and consent of the senate, any county treasurer, any county superintendent of the poor, any register of a county or any coroner, except as otherwise provided by special provisions of law.”[37] Also removable by the governor are “the chief executive officer of every city and the chief or commissioner of police, commissioner or director of public safety or other chief executive officer of the police force.”[38] The governor, for example, can remove the mayor of the City of New York,[39] as well as the City police commissioner,[40] a borough president,[41] the comptroller,[42] and the public advocate.[43]

In addition to the Public Officers Law’s § 33 powers, the series of laws that have been enacted to deal with municipal financial crises in New York give the governor significant additional removal powers. These laws further enhancing the governor’s removal powers over municipal officers and employees include the laws establishing the Nassau County Interim Finance Authority,[44] the Buffalo Fiscal Stability Authority,[45] the Erie County Fiscal Stability Authority,[46] the New York State Financial Emergency Act for the City of New York,[47] and the New York State Financial Emergency Act for the City of Yonkers.[48]

Section 34 of the Public Officers Law provides for the manner in which the governor can exercise his or her removal powers. The governor need not personally investigate or hear the removal case. The governor can appoint a State judge, a county judge or an individual appointed by the governor to hold the hearing on the removal case[49] and to make findings on the case to the governor.[50] The governor can request a local district attorney or the attorney general to help investigate the removal case in order to provide assistance to the person designated by the governor to report on the removal decision.[51] Accordingly, the Public Officers Law provides a governor with numerous options on how to handle a removal proceeding. The governor can handle the removal proceedings personally. Conversely, the governor can delegate much of the fact finding and the investigatory portion of the removal proceedings to individuals designated by the governor.

 Short History of Gubernatorial Removals

Up until the first third of the twentieth century, gubernatorial removals were considered a major part of the governor’s powers. Many of the most illustrious governors of the state – Charles Evans Hughes, Al Smith, Franklin Roosevelt, Theodore Roosevelt – all were involved significantly in removal proceedings. In probably the most famous removal proceeding, Governor Franklin Roosevelt heard the removal proceeding against New York City mayor Jimmy Walker in 1932. While Walker resigned before a decision was reached, Roosevelt’s handling of the case convinced many observers that he was not merely a jovial lightweight and that he had the gravitas needed to serve as president.

The last time that the power of the governor was invoked to remove an official was in 1974 when Governor Malcolm Wilson initiated removal proceedings and charges against the sheriff of Schoharie County.[52] The sheriff, however, forfeited his office before the charges were heard, and Governor Wilson did not hold any formal proceedings against the sheriff.[53]

The last major removal case to have been determined by a governor seems to be the decision of Governor Herbert Lehman not to remove Kings County Attorney William F.X. Geoghan in 1936.[54]

While there may have been no formal removal cases in the past 80 years, there actually is a rich and full body of precedents on how the removal power is to be exercised. These have involved decisions on removal standards by a former chief justice of the United States in Governor Hughes as well as statements by former presidents Franklin and Theodore Roosevelt.[55] Governor Samuel Tilden, the State’s governor in the wake of the infamous Tweed Ring, provided his views on the nature of removals.[56] In short, there are perceptible standards that are in place that can be used to deal with gubernatorial removals.

Utility of the Removal Powers

It is actually somewhat surprising that the removal powers have not been utilized in recent years. We have had activist governors such as Eliot Spitzer and Andrew Cuomo who clearly believe that the best defense is a good offense. The removal power can demonstrate that the governor is on the offensive on ethics issues.

As mentioned previously, another advantage of the removal powers is that governors can largely choose their levels of involvement. A governor in a major case can serve as the factfinder and actually hold the hearing. In minor cases, or in cases where the officer seeking to be removed is a political opponent of the governor, the governor might choose a widely esteemed factfinder and appoint the State attorney general to assist the factfinder’s investigation. This would permit a governor ‒ initiating a removal processing – to be almost totally neutral in judging the actual removal of the officer. The removal power can make a governor both an activist and a neutral.

There are also numerous available candidates for potential removals. There is low hanging fruit among State board members. The Public Officers Law allows for the creation of vacancies whenever a member of a board, authority or commission appointed by the governor has three consecutive unexcused absences.[57]  The governor could work with the division of the budget and the independent authorities budget office[58] to identify such individuals and have them removed for nonfeasance.

In recent months, the conduct of several county district attorneys has been called into question. The County Executive in Suffolk County has urged the District Attorney in that county to resign[59] and has threatened to go to the Governor’s office to have the District Attorney removed.[60] The conduct of the District Attorney in Rensselaer County has been put into question after the District Attorney proceeded to present a case to a grand jury where jurisdiction over the case appeared to be lodged with the State Attorney General.[61] The county legislature in St. Lawrence County has voted that it has no confidence in the county District Attorney and has called on the State to review her actions.[62]

In New York City, there had been speculation that the Governor would be called upon to consider the removal of former comptroller John Liu in 2012.[63] With both federal and State prosecutors reviewing the conduct of New York City mayor Bill DeBlasio,[64] there may be calls for the Governor to review the conduct of the Mayor.

In short, there may be ample targets should the Governor decide to utilize the removal powers vested in that office. The removal powers give the Governor significant powers over local and State officials. It gives the Governor the opportunity to impose and apply meaningful sanctions without having to be involved in the criminal process. There is also considerable precedent on how the removal process can be utilized.

From a political perspective, it affords a governor the ability to be an activist in pursuing corruption and malfeasance in government. At the same time, the procedures in Section 34 of the Public Officers Law would allow the governor to be almost a neutral noncombatant in the actual process of investigating and adjudicating any removal decision.

The removal process could work both on a public policy and on a political level. It can provide effective penalties for official misconduct. Similarly, it could provide political benefits to a governor who wanted to be proactive in pursing corruption. It is surprising that this power has fallen out of favor over the past 75 years.


[1] State Finance Law § 139-j.9; NYCRR § 8.3; 19 NYCRR § 932.7.

[2] 9 NYCRR § 4.189.

[3] Executive Law § 94.

[4] Legislative Law § 80.

[5] 22 NYCRR § 7400.4.

[6] Executive Law § 52.

[7] Racing, Pari-Mutuel Wagering and Breeding Law § 1368.

[8] Executive Law § 46.

[9] Workersʼ Compensation Law § 136.

[10] Public Authorities Law § 1279.

[11] Public Health Law § 31.

[12] Unconsol. Laws § 6405.

[13] Executive Law § 552.

[14] 9 NYCRR § 5.86.

[15] 7 NYCRR §5.52; 7 NYCRR § 701.8.; 7 NYCRR § 1901.2.

[16] Racing, Pari-Mutuel Wagering and Breeding Law § 206.

[17] Public Officers Law § 74.

[18] General Municipal Law § 806.

[19] 2 NYCRR § 320.5.

[20] Public Officers Law § 73-a; General Municipal Law §§ 811, 812; N.Y. Ct. Rules § 40.2.


[22] Westlaw Journal Government Contract, “New York Fights Fraud Against State Government,” March 7, 2011.

[23] Frank Anechiarico and James B. Jacobs, The Pursuit of Absolute Integrity: How Corruption Control Makes Government Ineffective, University of Chicago Press (1996).

[24] Joseph Spector, “Preet Bharara: The Man Behind NY Corruption Busting,” Rochester Democrat and Chronicle, December 27, 2015.

[25] Herbert M. Suskin, “Federal Prosecution of Local Corruption,” 29 University of Miami L. Rev. 390 (1975);   Herbert J. Stern, “Prosecutions of Local Political Corruption under the Hobbs Act: The Unnecessary Distinction Between Bribery and Extortion,” 3 Seton Hall L. Rev. 1 (1971). See also United States v. Addonizio, 451 F.2d 49, 72 (3d Cir. 1971), cert. denied, 405 U.S. 936 (1972).

[26] See Paul Hoffman, Tiger in the Court, Playboy Press (1973). The book is subtitled “The US Attorney who Prosecuted 8 Mayors, 2 Secretaries of State, 2 State Treasurers, 2 Powerful Political Bosses and 64 other Public Officials.” See also Herbert J. Stern, Diary of a DA: The True Story of the Prosecutor Who Took on the Mob, Fought Corruption, and Won, Skyhorse Publishing (2012).

[27] United States v. Margiotta, 688 F.2d 108 (2d Cir. 1982).

[28] United States v. Alexander, 860 F.2d 508 (2d Cir. 1988).

[29] United States v. Biaggi, 672 F. Supp. 112 (S.D.N.Y. 1987); aff’d 909 F.2d 662 (2nd Cir. 1990), cert. denied, sub nom. Simon v. United States, 499 U.S. 904 (1991).

[30] United States v. Friedman, 854 F.2d 535, cert. denied, Lazar v. United States, 490 U.S. 1004 (1989).

[31] The federal conviction of New York State Assembly Speaker Melvin Miller was overturned in U.S. v. Miller, 997 F.2d 1010 (2nd Cir. 1993).

[32] In the 1970’s and the 1980’s, the district attorney’s offices in New York City prosecuted Assembly Speaker Perry Duryea and Assembly majority leader John Kingston, People v. Duryea 76 Misc.2d 948 (Sup. Ct. 1974), aff’d 44 A.D.2d 663 (1st Dept. 1974); Assembly Speaker Stanley Steingut (Steingut v. Gold, 54 A.D. 2d 481 (2nd Dept. 1976) aff’d 42 N.Y. 2d 311 (1977), and Senate minority leader Manfred Ohrenstein, along with several other senators. (People v. Ohrenstein, 153 A.D.2d 342 (1st Dept. 1989), aff’d 77 N.Y. 2d 38 (1990). In 2007, based on prior State investigations, the Albany County district attorney did prosecute State Comptroller Alan Hevesi.

[33] N.Y. Const. art. XIII, § 13(a).

[34] N.Y. Const. art. XIII, § 13(b).

[35] N.Y. Const. art. V, § 4.

[36] N.Y. Const. art. XIII, § 5.

[37] Public Officers Law § 33.1.

[38] Public Officers Law § 33.2.

[39] NYC Charter § 9.

[40] NYC Charter § 431.

[41] NYC Charter § 81.

[42] NYC Charter § 92.

[43] NYC Charter § 24.

[44] Public Authorities Law § 3669.4.(c).

[45] Public Authorities Law § 3858.3.(c).

[46] Public Authorities Law § 3959.3.(c).

[47] Unconsol. Laws, Ch. 22, § 1.3.

[48] Unconsol. Laws, Ch. 23, § 11.3. See also New York State Financial Emergency Act of Nineteen Hundred Eighty-four for the City of Yonkers, Unconsol. Laws, Ch 23-A, § 12.3.

[49] Public Officers Law §34.1.

[50] Public Officers Law §34.3.

[51] Public Officers Law §34.2.

[52] Public Papers of Governor Malcolm Wilson, 766 (1974).

[53] Id. at 772.

[54] Public Papers of Governor Herbert Lehman, 728 (1936).

[55] See for example “Memorandum by Counsel for District Attorney Geoghan Accompanying Answer to Charges Setting Forth Decisions of Governors and Their Commissioners in Removal Proceedings,” Public Papers of Governor Herbert Lehman 701 (1936). See also “The Counsel to Proponents Submits Memorandum Relating to General Principles Applicable to the Governor’s Decision in Removal Decisions,” Public Papers of Governor Herbert Lehman 710 (1936); “Opinion In the Matter of the Charges against John F. Ahearn, President of the Borough of Manhattan, in the City of New York,” Public Papers of Governor Charles Evans Hughes 275 (1907).

[56] “Letter of Hon. Samuel J. Tilden to the Hon. Wm. H. Wickham, “February 17, 1875, in 1 Proceedings at the Trial of Joel B. Erhardt, DeWitt C. Wheeler and Sidney P. Nichols before Hon. Smith Ely, Jr., Mayor of New York, Dec. 20, 21 and 22, 1877 (1877).

[57] Public Officers Law § 30.3.

[58] Public Authorities Law § 4.

[59] David Winzelberg and Claude Solnik, “Bellone Calls for Spota to Resign,” Long Island Business News, May 12, 2016.

[60] Joye Brown, “Steve Bellone Pushes Fight With Thomas Spota to New Level,” Newsday, May 15, 2016.

[61] “The AG vs. the DA,” New York Post, May 2, 2016.

[62] Susan Mende, “County Wants Rain Probe,” Ogdensburg Journal, April 19, 2016.

[63] “How to Bounce Liu,” New York Post, March 3, 2012; Jon Lentz, “What Happens If John Liu Resigns?,” City and State, February 29, 2012.

[64] See “Corruption Probes in N.Y. State: A Primer,” Buffalo News, May 8, 2016.