Matter of Miller v. Schwartz, 72 N.Y.2d 870 (1988)
There is no general constitutional right to discovery in administrative proceedings; such matters are regulated by statute or rule.
Summary
This case addresses whether a driver charged with speeding has a right to pre-trial discovery of information related to the radar device used to measure his speed during an administrative adjudication. The New York Court of Appeals held that there is no constitutional right to discovery in administrative proceedings, and since no statute or rule provided for such discovery in this case, the driver’s request was properly denied. The court emphasized that discovery in such contexts is governed by statute or regulation, not constitutional mandate.
Facts
On October 15, 1984, a Suffolk County police officer charged the petitioner, Miller, with speeding. Suffolk County adjudicates traffic violations administratively. Before his administrative trial, Miller’s attorney requested documents and information from the Traffic Violations Bureau regarding the radar device used to measure his speed, including testing and operating procedures. The Bureau denied the request, citing a rule that excludes CPLR and Criminal Procedure Law motion practice and discovery procedures.
Procedural History
Miller initiated an Article 78 proceeding to compel discovery related to the radar device. He argued that the rule denying discovery violated his due process rights, hindering his ability to cross-examine witnesses effectively. The lower courts likely denied the Article 78 petition. The Court of Appeals affirmed the denial, effectively upholding the administrative decision and the rule prohibiting pre-trial discovery.
Issue(s)
Whether the denial of pre-trial discovery of information relating to a radar device in an administrative traffic violation proceeding violates the petitioner’s due process rights.
Holding
No, because there is no general constitutional right to discovery in administrative proceedings; such matters are regulated by statute or rule, and the petitioner had no statutory or regulatory right to pretrial discovery in this case.
Court’s Reasoning
The Court of Appeals stated that pre-trial discovery is not a constitutional right in either criminal or administrative cases. The Court cited Weatherford v. Bursey, 429 US 545, 559, regarding criminal cases and National Labor Relations Bd. v. Interboro Contrs., 432 F.2d 854, 857-858, regarding administrative proceedings. The Court emphasized that discovery in administrative hearings is governed by statute or agency rules. Because no statute or rule provided Miller with a right to pre-trial discovery concerning the radar device, the Bureau’s denial was proper. The decision underscores the principle that administrative agencies have broad discretion to determine their own procedures, as long as those procedures comport with due process. In this context, due process does not automatically mandate pre-trial discovery. This case clarifies that individuals facing administrative charges do not have the same discovery rights as those in criminal court, and must rely on specific statutes or regulations to obtain such information. The court offered no dissenting or concurring opinions.