Federal Court Finds New York City Not Required To Compensate Employees For Time Spent In Alcohol Rehabilitation By Kathryn J. Russo on October 15, 2014 Posted in Litigation and Other Proceedings, Substance Abuse-Related Disabilities Click here to read our colleague Noel P. Tripp’s blog about a recent decision rejecting three New York Police officers’ claims that they should have been paid for time spent in alcohol rehabilitation and counseling sessions. Makinen v. City of New York, 2014 U.S. Dist. LEXIS 139732 (S.D.N.Y. Sept. 30, 2014).