Lewis Tesser, a partner at Tesser, Ryan & Rochman, and Timothy Nolen, an associate with the firm, write that Article 78 proceedings must be commenced within four months of an agency's final determination. However, with agencies sometimes acting informally, amending or editing their decisions, and issuing multiple "decisions," it can be difficult to determine when the final decision of an agency was made.
When Is Administrative Determination 'Final'?
New York Law Journal
October 11, 2013