What standard governs review of agency factual findings in Article 78?

• A. Clear and convincing evidence.
• B. Beyond a reasonable doubt.
• C. Substantial evidence.
• D. Preponderance of the evidence.

Answer: (C)

Substantial evidence governs how a court reviews the agency’s factual findings under Article 78. When someone challenges an agency’s determinations, the court defers to the agency’s factual conclusions if they’re supported by substantial evidence in the record—evidence that a reasonable person could rely on to reach the same result and that is more than a mere scintilla. The court doesn’t reweigh every piece of evidence or substitute its own view of the facts; it asks whether the record as a whole provides a plausible basis for the agency’s findings. If the factual findings aren’t supported by substantial evidence, or if the agency’s decision is arbitrary or capricious, relief can be granted. The other standards—beyond a reasonable doubt, preponderance of the evidence, or clear and convincing evidence—apply to different contexts (criminal trials or particular civil determinations) and are not the standard used for reviewing agency factual findings under Article 78.