## Facts

- Benjamin Haug, a SUNY Potsdam student, was charged with sexual misconduct under the university’s code of student conduct.
- After a disciplinary hearing, SUNY found Haug responsible and, after internal review, imposed expulsion.
- Haug filed a CPLR article 78 proceeding challenging the determination, arguing it lacked substantial evidence and improperly relied on hearsay credited over his live testimony.
- The Appellate Division annulled SUNY’s determination as unsupported by substantial evidence.
- SUNY appealed to the New York Court of Appeals.

## Issues

1. Under CPLR 7803(4), did substantial evidence support SUNY’s finding that Haug violated the student code of conduct, requiring judicial deference to SUNY’s fact-finding?
2. Did the Appellate Division exceed its role by effectively reweighing evidence and credibility in concluding the determination lacked substantial evidence?

## Decision

- The Court of Appeals reversed the Appellate Division’s order, with costs.
- The court held the Appellate Division misapplied the substantial-evidence standard by failing to defer to the administrative fact-finder.
- The matter was remitted to the Appellate Division to consider issues raised but not previously decided.

## Legal Principles

- In Article 78 review under CPLR 7803(4), courts may not upset an administrative determination on questions of fact where substantial evidence supports the result.
- The substantial-evidence standard is minimal; it is less than a preponderance of the evidence.
- Review focuses on rationality: whether the record contains relevant proof a reasonable mind may accept as adequate to support the conclusion, and whether the inference drawn is reasonable and plausible (not necessarily the most probable).
- If substantial evidence exists, a reviewing court may not substitute its judgment for the agency’s, including on credibility and the weighing of conflicting proof.

## Conclusion

The Court of Appeals reinstated deference-centered Article 78 review in the university discipline context, holding that where the record permits a reasonable inference supporting the university’s finding, courts must uphold the determination and may not reweigh hearsay, live testimony, or credibility.


Haug v. State Univ. of N.Y. at Potsdam, 32 N.Y.3d 1044 (N.Y. 2018)