Under CPLR Article 78, what standard governs the agency's factual findings?

Under CPLR Article 78, what standard governs the agency's factual findings?

• A. De novo
• B. Substantial evidence review (correct)
• C. Abuse of discretion
• D. Clear error

Answer: (B)

When a court reviews an agency decision under CPLR Article 78, it defers to the agency’s factual findings as long as they are supported by substantial evidence in the record. Substantial evidence means enough relevant proof, taken as a whole, that a reasonable person would accept as adequate to support the agency’s conclusions. The court does not reweigh the entire record or substitute its own judgment for the agency’s on factual matters; if the findings are so supported, they stand even if other evidence could support different results. De novo review would require the court to reassess the facts from scratch, which is not how Article 78 factual findings are treated. The other options don’t fit because they refer to different standards of review (such as evaluating the decision’s rationality or discretion) rather than the sufficiency of the agency’s factual findings.

When a court reviews an agency decision under CPLR Article 78, it defers to the agency’s factual findings as long as they are supported by substantial evidence in the record. Substantial evidence means enough relevant proof, taken as a whole, that a reasonable person would accept as adequate to support the agency’s conclusions. The court does not reweigh the entire record or substitute its own judgment for the agency’s on factual matters; if the findings are so supported, they stand even if other evidence could support different results.

De novo review would require the court to reassess the facts from scratch, which is not how Article 78 factual findings are treated. The other options don’t fit because they refer to different standards of review (such as evaluating the decision’s rationality or discretion) rather than the sufficiency of the agency’s factual findings.