Legal Memorandum: Reasoning behind the Ruling in NY

Issue: Under New York law, is an administrative agency required to state the reasoning behind a ruling?

Area of Law: Administrative Law, Administrative Law & Regulation (Federal and State), Litigation & Procedure
Keywords: Reasoning behind a ruling; Aadministrative agency
Jurisdiction: New York
Cited Cases: 66 N.Y.2d 516; 498 N.Y.S.2d 111; 760 N.Y.S.2d 462
Cited Statutes: None
Date: 07/01/2006

Generally, with respect to adjudicatory administrative decisions within the same agency, the failure to provide reasons for rejecting an earlier decision on point is itself considered to be arbitrary and grounds for reversal.  Matter of Charles A. Field Delivery Serv., Inc., 66 N.Y.2d 516, 520, 498 N.Y.S.2d 111, 115 (1985) (“[W]hen an agency determines to alter its prior stated course it must set forth its reasons for doing so . . . [and] [a]bsent such an explanation, failure to conform to agency precedent will, therefore,  require reversal on the law as arbitrary, even though there is in the record substantial evidence to support the determination made.”); Klein v. Levin, 305 A.D.2d 316, 760 N.Y.S.2d 462, 465 (1st Dept. 2003) (“[A] decision of an administrative agency which neither adheres to its own prior precedent nor indicates its reason for reaching a different result on essentially the same facts is arbitrary and capricious.”). 


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