22 N.Y.2d 430 (1968)
When an administrative agency’s determination hinges on the credibility of a key witness, particularly one with questionable credibility, the agency must make explicit findings of fact to support its decision, especially when the evidence is contested and contradictory.
Summary
This case addresses the necessity of explicit findings by the State Liquor Authority (SLA) when its decision relies heavily on a witness of questionable credibility. The Court of Appeals reversed the Appellate Division’s order, holding that the SLA’s determination could not stand without clear findings of fact regarding the witness’s testimony. The court emphasized that when the primary witness’s testimony is contested, contradictory, and deemed incredible by the hearing officer, it is crucial to ascertain whether the SLA relied on any material part of that testimony. Without such findings, the court cannot determine if the SLA’s decision was based on substantial evidence.
Facts
The case involves a determination by the State Liquor Authority (SLA) regarding a violation. A key witness provided contested and contradictory evidence during the hearing. The hearing officer found the witness’s testimony to be incredible. A State Trooper also testified, but his testimony did not cover all elements of the alleged violation.
Procedural History
The case was initially heard by the State Liquor Authority. The Appellate Division reviewed the SLA’s determination. The New York Court of Appeals then reviewed the Appellate Division’s order.
Issue(s)
Whether the State Liquor Authority’s determination can stand without explicit findings of fact, especially when the determination relies heavily on the testimony of a witness of low credibility who provided contested and contradictory evidence.
Holding
No, because in the absence of explicit findings of fact, the court cannot determine whether the State Liquor Authority relied on substantial evidence, especially when a key witness’s credibility is questionable and their testimony is contested and contradictory.
Court’s Reasoning
The Court of Appeals reversed the Appellate Division’s order, emphasizing the critical importance of factual findings in administrative decisions, particularly when the credibility of a key witness is in question. The court noted that the principal witness provided contested and contradictory evidence and was deemed incredible by the hearing officer. The court reasoned that without knowing whether the SLA relied on any material part of the witness’s testimony, it could not determine whether the SLA’s determination was supported by substantial evidence. The court stated, “Lacking findings of fact the determination may not stand.” The court further explained that because the State Trooper’s testimony did not cover all elements of the violation, the witness’s testimony was crucial. Judges Scileppi and Bergan dissented, arguing that the SLA’s findings were sufficiently explicit and supported by substantial evidence, and that the court should not substitute its judgment for that of the authority in evaluating witness testimony, citing Matter of Stork Rest. v. Boland, 282 N. Y. 256.