Collins v. Codd, 38 N.Y.2d 269 (1975)

When substantial evidence supports an administrative agency’s determination, the court must sustain that determination, even if conflicting evidence exists or other conclusions could be drawn.

Summary

This case addresses the extent to which a court can overturn an administrative decision. After a departmental hearing involving conflicting testimony regarding a police officer’s conduct during an arrest, the Police Commissioner found the officer guilty of misconduct and imposed a fine. The Appellate Division annulled the Commissioner’s determination, but the New York Court of Appeals reversed, holding that the Commissioner’s decision should be upheld because it was supported by substantial evidence. The Court emphasized that the responsibility for weighing evidence and choosing between conflicting inferences rests solely with the administrative agency, not the courts.

Facts

A complainant and her daughter presented testimony at a departmental hearing alleging that Officer Collins wrongfully threw the complainant to the ground, put his knee in her back, dragged her to a patrol car, pushed her in, and choked her with a nightstick after handcuffing her. Officer Collins, his partner, and two fellow officers presented conflicting testimony, disputing the complainant’s version of events. The Trial Commissioner credited the testimony of the complainant and her daughter.

Procedural History

The Police Commissioner confirmed the Trial Commissioner’s findings and fined Officer Collins 10 days’ vacation. The Appellate Division annulled the Commissioner’s determination. The New York Court of Appeals reversed the Appellate Division’s order and reinstated the Police Commissioner’s determination.

Issue(s)

Whether the Appellate Division erred in annulling the Police Commissioner’s determination of misconduct when that determination was supported by substantial evidence.

Holding

Yes, because where substantial evidence exists to support the administrator’s determination, that determination must be sustained, irrespective of whether a similar quantum of evidence is available to support other varying conclusions.

Court’s Reasoning

The Court of Appeals emphasized the limited role of judicial review in administrative determinations. It stated that the Appellate Division overstepped its bounds by substituting its judgment for that of the Police Commissioner on a matter of witness credibility. The Court reiterated the principle that administrative agencies are responsible for weighing evidence and resolving conflicting testimony. The Court relied on Matter of Stork Rest. v Boland, 282 NY 256, 267, quoting, “Where there is conflict in the testimony produced * * * where reasonable men might differ as to whether the testimony of one witness should be accepted or the testimony of another be rejected, where from the evidence either of two conflicting inferences may be drawn, the duty of weighing the evidence and making the choice rests solely upon the [administrative agency]. The courts may not weigh the evidence or reject the choice made by [such agency] where the evidence is conflicting and room for choice exists”. The court found that because substantial evidence supported the Commissioner’s finding of misconduct, the Appellate Division should not have overturned it, even if other conclusions could also be supported by the evidence. The court effectively deferred to the administrative agency’s expertise and fact-finding role, reinforcing the principle of limited judicial intervention in administrative matters.