Anna Miglio, CSC Docket No. 2024-163, 2024-164

BackgroundThe appeal of Anna Miglio, Correctional Police Sergeant, Department of Corrections, removal, effective July 18, 2023, on charges, was heard by Administrative Law Judge Mamta Patel (ALJ), who rendered her initial decision on June 30, 2025. Exceptions were filed on behalf of the appellant and a reply was filed on behalf of the appointing authority.

AnalysisHaving considered the record and the ALJ’s initial decision, and having made an independent evaluation of the record, including a thorough review of the exceptions and reply, the Civil Service Commission (Commission), at its meeting on August 13, 2025, adopted the ALJ’s Findings of Facts and Conclusions of Law and her recommendation to uphold the removal.

The Commission makes the following comments. There is no serious dispute as to the sustained charges in this matter. Rather, the appellant challenges the imposition of removal, arguing mitigating factors, such as the appellant’s prior work history. The Commission rejects these contentions. In recommending upholding the removal, the ALJ stated the following:

In this case, Miglio has been employed by the DOC since August

2009 and has served in a supervisory role as a sergeant since February

2017. As a public servant whose conduct is visible to the public, her personal involvement with Putnam and failure to recuse herself could reasonably be perceived to have compromised her objectivity or independence. As LaBonne and Lane testified, officers are guided in maintaining the highest standards of integrity, a principle instilled from the beginning. Miglio’s training records show her consistent completion of ethics training since 2010, with the most recent sessions held in

January and February 2022. During this period, she was involved in a romantic relationship with Putnam. Miglio was aware of her obligation to report the relationship but chose not to disclose it, following Putnam’s request for secrecy. Her actions demonstrate susceptibility to undue influence by a subordinate’s request. Additionally, Miglio assisted

Putnam in preparing for his interview before the selection panel and did not recuse herself during his interview, despite their personal relationship. This is particularly egregious given her position as

Putnam’s supervisor. Motivated by personal interest, Miglio, who is entrusted with authority, chose to prioritize her own benefit and favor one candidate over others who did not receive similar attention. This conduct exemplifies a violation of ethical standards, putting personal interests above adherence to established rules and _ recusal responsibilities. Each of these factors individually undermines Miglio’s trustworthiness as a corrections officer, and collectively, they cast doubt on her qualification to serve as a sergeant within the DOC.

Furthermore, what is more troubling is Miglio’s failure to admit her mistakes and accept responsibility, which makes her unfit to continue as a corrections officer. Therefore, 1 CONCLUDE that Miglio must be removed from her employment in the DOC.

Regarding the penalty, similar to its assessment of the charges, the Commission’s review of the penalty is de novo. In addition to its consideration of the seriousness of the underlying incident in determining the proper penalty, the Commission also utilizes, when appropriate, the concept of progressive discipline. West New York v. Bock, 38 N.J. 500 (1962). In determining the propriety of the penalty, several factors must be considered, including the nature of the appellant’s offense, the concept of progressive discipline, and the employee’s prior record. George v. North Princeton Developmental Center, 96 N.J.A.R. 2d (CSV) 463. However, it is well established that where the underlying conduct is of an egregious nature, the imposition of a penalty up to and including removal is appropriate, regardless of an individual’s disciplinary history. See Henry v. Rahway State Prison, 81 N.J. 571 (1980). It is settled that the theory of progressive discipline is not a “fixed and immutable rule to be followed without question.” Rather, it is recognized that some disciplinary infractions are so serious that removal is appropriate notwithstanding a largely unblemished prior record. See Carter v. Bordentown, 191 N.J. 474 (2007). Even when a law enforcement officer does not possess a prior disciplinary record after many unblemished years of employment, the seriousness of an offense may nevertheless warrant the penalty of removal where it is likely to undermine the public trust. In this regard, the Commission emphasizes that a law enforcement officer is held to a higher standard than a civilian public employee. See Moorestown v. Armstrong, 89 N.J. Super. 560 (App. Div. 1965), cert. denied, 47 N.J. 80 (1966). See also, In re Phillips, 117 N.J. 567 (1990).

Here, the Commission wholeheartedly agrees with the ALJ’s assessment of the penalty. It is clear that as a law enforcement employee, the appellant’s misconduct was egregious and cannot be minimized. Such misconduct is inimical to what the public expects from a law enforcement officer, and in this case, a supervisory law enforcement officer, who is held to a higher standard. While the Commission acknowledges the appellant’s previously unblemished disciplinary history, it cannot ignore the serious ethical and moral breaches committed by the appellant. As such, a penalty less than removal would serve to undermine the public trust. Accordingly, the Commission finds the penalty of removal neither disproportionate to the offense nor shocking to the conscious.

ORDER

The Civil Service Commission finds that the action of the appointing authority in removing the appellant was justified. The Commission therefore upholds that action and dismisses the appeal of Anna Miglio.

ClosingThis is the final administrative determination in this matter. Any further review should be pursued in a judicial forum.