The Agency’s Determination Was Based Upon Its Own Precedents and Related Jurisprudence and Was Therefore “Rationally Based”—The Determination Should Not, Therefore, Be Disturbed by a Court—A Court May Not Substitute Its Own Judgment for that of the Agency
The First Department, in a full-fledged opinion by Justice Acosta, reversed Supreme Court’s denial of a motion to dismiss a petition to annul an agency-determination. The underlying proceedings involved two nurses accused of submitting false time sheets. In seeking a hearing allowed by the collective bargaining agreement, the union, on behalf of the nurses, requested certain documents relevant to the allegations from the New York City Human Resources Administration (HRA). HRA refused to turn over the documents, arguing that such “discovery” is not allowed in disciplinary actions (by the relevant regulations). The Board (of Collective Bargaining) ultimately ruled that some, but not all, of the requested documents (those kept in the regular course of business) should be turned over. HRA filed an Article 78 petition seeking to annul the Board’s determination. Supreme Court denied the union’s motion to dismiss the petition. The 1st Department held the petition should have been dismissed. In reviewing an agency determination, the court looks only at whether the determination is rationally based. Here the Board’s determination was based upon its own precedents and related jurisprudence. Therefore, the determination must stand. A court cannot substitute its own judgment for that of the agency:
“In reviewing an administrative agency determination, courts must ascertain whether there is a rational basis for the action in question or whether it is arbitrary and capricious” … . “A court cannot simply substitute its judgment for that of an administrative agency when the agency’s determination is reasonable” … . Moreover, “[i]t is well settled that the construction given statutes and regulations by the agency responsible for their administration, if not irrational or unreasonable, should be upheld” … . “Broad deference must therefore be accorded determinations of the Board, which … is the body charged with interpreting and implementing the [regulations] and determining the rights and duties of labor and management in New York City” … .
Given this deferential standard of review, we are compelled to hold that the petition should have been dismissed. The Board’s decision had a rational basis and was not arbitrary and capricious. To be sure, the Board engaged in a relatively expansive interpretation of the duty to furnish information embodied in [the regulations], when it determined that the duty applies in the context of these disciplinary proceedings instituted pursuant to the Agreement. But its interpretation was based on the holdings of some nine prior decisions and was not irrational … . The Board based its decision on its own precedents and related jurisprudence, and its interpretation of the [regulations], a statutory provision within its purview and expertise, was sufficiently reasonable to preclude our “substitut[ing] another interpretation” … . Matter of City of New York v New York State Nurses Assn., 2015 NY Slip Op 04437, 1st Dept 5-26-15