90 N.Y.2d 662 (1997)
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Under Retirement and Social Security Law § 803, a teacher’s own assertion can constitute substantial evidence of eligibility for retroactive membership in the New York State Teachers’ Retirement System (TRS), provided the school district’s denial of membership lacks a rational basis.
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Summary
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This case consolidates four CPLR article 78 proceedings regarding teachers seeking retroactive membership in TRS under Retirement and Social Security Law § 803. The court addresses whether teachers demonstrated eligibility for retroactive membership by substantial evidence and whether the school districts had a rational basis for denial. The Court of Appeals held that a teacher’s assertion, without more, can constitute substantial evidence and that only the Kingston Board of Education provided a rational basis for denying retroactive membership because those teachers had previously been members of TRS. Thus, the court reversed the Appellate Division in Clark and affirmed in the remaining three cases.
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Facts
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Several part-time and substitute teachers sought retroactive membership in TRS, which would grant them better benefits based on earlier tier status. They filed applications as per Retirement and Social Security Law § 803, asserting they hadn’t expressly declined membership or participated in procedures explaining the option to join. The school districts denied these applications, triggering article 78 proceedings.r
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Procedural History
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Each case followed a similar path: teachers applied for retroactive membership, school districts denied, and teachers initiated article 78 proceedings. The Supreme Court’s decisions varied, with some granting the petitions and others dismissing them. The Appellate Division then reviewed these decisions, leading to the appeal to the Court of Appeals. The Court of Appeals consolidated the cases to resolve the common issue of substantial evidence and rational basis.r
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Issue(s)
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1. Whether a teacher’s own assertion, without further documentation, constitutes