The term substantial evidence is a legal term that means evidence of enough relevance, quality and quantity to satisfy a certain standard in a case. The term substantial evidence is used in many different fields of law. For example, it is used quite often in civil law relating to appeals and administrative decisions. It is also used in some criminal cases. State statutes define the term substantial evidence differently, so a litigant should look to the context of the case, as well as to any definitions provided in the statute in which the term is contained.
State Definitions for Substantial Evidence
A litigant may have to examine a guide to evidence for a particular state to understand how that state defines substantial evidence. As an example, a guide to New York's Evidence statutes provides that the burden of persuasion necessary to rebut a presumption is substantial evidence. Yet the guide does not define the term itself – the litigant has to look at case law to find the term's legal definition.
The relevant case in this situation is 300 Gramatan Ave. Assoc. v. State Div. of Human Rights, 45 NY2d 176, 180 . This case states that substantial evidence is material related to the charge or controversy which involves a weighing of the quality and quantity of the proof. Substantial evidence is relevant proof that a reasonable mind may accept as adequate to support a conclusion or ultimate fact.
Substantial Evidence in Appeals
In California, an appellate court can use the substantial evidence standard. This standard involves the appellate court reviewing the record of the trial court’s proceedings to make sure there is substantial evidence that reasonably supports the lower trial court’s decision. The substantial evidence standard is one of three types of standards that an appellate court can use. The other two standards are: abuse of discretion standard and de novo standard.
Importance of State Statutes
In New York, the term substantial evidence is meaningful in the context of Civil Practice Laws and Rules Article 78. This statute concerns a proceeding against a body or officer, like a lawsuit against the City of New York or a police officer working for the city. New York Codes, Rules and Regulations (NYCRR) 1000.15(d)(2)(c) provides that oral argument is not permitted on transferred cases, pursuant to CPLR Article 78, if the sole issue is whether there is substantial evidence to support the challenged determination.
Definition in State Administrative Laws
The term substantial evidence can be defined in multiple ways by administrative law courts. These are a specific set of civil courts set up for administrative agencies in which the agencies decide matters pertaining to agency regulations.
In Oregon, the Land Use Board of Appeals (LUBA) has issued numerous cases to delineate the meaning of the substantial evidence. For example, in the case of Reeves v. Washington County, 24 Or LUBA 483 (1993), the court found substantial evidence is evidence that a reasonable person would accept as adequate to support a conclusion. In Brandt v. Marion County, 23 Or LUBA 316 (1992), the court held substantial evidence is evidence that a reasonable person would rely on in reaching a decision.
In Washington state, the analysis of evidence presented in a set of criminal cases gives a broader understanding of the meaning and application of substantial evidence there. Here the term substantial evidence means evidence of such a quantity and type that a jury could reasonably have concluded there was proof the defendant committed a charged offense. The substantial evidence rule in criminal law in this state is that when there is an absence of proof on an element of the crime charged, the court must determine if there was substantial evidence tending to establish circumstances in support of a finding on an element of the crime. If there is substantial evidence, the issue of the defendant’s guilt must be resolved by the jury, not by the court.
Federal Definitions for Substantial Evidence
Federal courts may use the term substantive evidence differently than do state courts. Federal circuits may also define the term differently from one another. For example, the U.S. Courts for the Ninth Circuit provides that substantial evidence means evidence that is more than a mere scintilla, or more than a tiny trace or spark of evidence. To this court, substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, even if it is possible to draw a contrary conclusion from the evidence.
The Ninth Circuit further addresses the term substantial evidence by stating that an agency’s findings of fact must be upheld if supported by substantial evidence in the record. Case law holds that the clearly erroneous standard for evidence should be rejected. The substantial evidence standard of review for agency findings should be reaffirmed.
The Ninth Circuit holds that in a civil case, the court of appeals reviews a jury verdict to determine whether it is supported by substantial evidence. Neither the trial court nor the appellate court is allowed to weigh the evidence or assess the credibility of witnesses in determining whether substantial evidence exists. As to criminal cases, a jury verdict must stand if it is supported by substantial evidence.
Federal Agency Decisions
An individual can get a better understanding of how the substantial evidence standard works in practice in administrative law by looking at cases in which the court used this standard. The Appeals Council (AC) of the U.S. Social Security Administration uses a substantial evidence standard to review an administrative law judge’s (ALJ’s) decision. The AC relies on the understanding of substantial evidence that is stated in the Code of Federal Regulations, a portion of federal law.
The definition at 20 CFR 404.901 provides substantial evidence as a reasonable mind might accept as adequate to support a conclusion. The AC explains substantial evidence requires less in support of a finding or conclusion than a preponderance of the evidence. The AC uses the standard to note that it will deny a person’s request for review or decline to take own motion review if substantial evidence supports an ALJ’s action, findings or conclusions and there is no other basis for review present.
- California Courts: Appeals Process
- California Code of Civil Procedure: Sections 1084-1097 Writ of Mandate
- New York Courts: Appeals to the Appellate Division
- New York State Senate: Article 78, Proceedings Against Body or Officer
- Oregon Land Use Board of Appeals: Definitions of Substantial Evidence
- United States Courts for the Ninth Circuit: Definition
- New York Courts: Guide to New York Evidence, Article 3 Privilege
- New York State Law Reporting Bureau: Matter of Sullivan v. County of Rockland (2014) NYSlipOp 06593 [121 AD3d 700]
- U.S. Social Security Administration: Administrative Law Judge's Action, Findings, or Conclusions Not Supported by Substantial Evidence
- Electronic Code of Federal Regulations:Section 404.901 Definitions
- Washington Municipal Research and Services Center: 79 Wn.2d 512
Jessica Zimmer is a journalist and attorney based in northern California. She has practiced in a wide variety of fields, including criminal defense, property law, immigration, employment law, and family law.