Matter of Acosta v. Lang, 13 N.Y.2d 1079 (1963)
When there are two equally acceptable answers to a question on a civil service exam, the selection of only one as correct is arbitrary and capricious.
Summary
This case concerns the validity of a civil service examination. Petitioners challenged the rejection of their answers to exam questions, arguing that their answers were equally as valid as the keyed answers. The Court of Appeals held that when multiple equally valid answers exist for a question, the agency’s decision to accept only one is arbitrary. This decision underscores the importance of fair and rational testing procedures in civil service examinations, providing a basis for judicial review when agencies act arbitrarily.
Facts
Candidates took a civil service examination. After the exam, some candidates protested certain questions, arguing their answers were as correct as the official answers. The agency administering the examination refused to accept any answers other than the keyed answers.
Procedural History
The petitioners initiated legal action challenging the agency’s determination. The lower courts ruled in favor of the petitioners, ordering a hearing to determine if the protested answers were equally valid. The case then reached the New York Court of Appeals.
Issue(s)
Whether an agency acts arbitrarily when it refuses to accept multiple equally valid answers to a question on a civil service examination.
Holding
Yes, because when there are two equally acceptable answers to a question, the selection of one as the correct answer is arbitrary and capricious.
Court’s Reasoning
The Court of Appeals reasoned that a civil service examination must be administered fairly and rationally. Refusing to acknowledge the validity of multiple correct answers undermines this principle. The court relied on precedent, citing Matter of Fink v. Finegan, 270 N.Y. 356 and Matter of Gruner v. McNamara, 298 N.Y. 395, which established that selecting only one correct answer when multiple exist is arbitrary. The Court emphasized that an agency’s discretion in administering examinations is not unlimited and is subject to judicial review when that discretion is exercised arbitrarily. The court quoted, “Where there are two equally acceptable answers to a question, the selection of one as the correct answer must be deemed to be the result of an arbitrary decision.” This quote encapsulates the core reasoning behind the decision.