Arkansas Department of Human Services Crimes Against Children Division v. Steven D. Mitchell

Summary

The court affirmed the administrative law judge’s determination that Mitchell sexually abused a student and should be listed on the child-maltreatment registry, reversed the circuit court, and vacated the court of appeals’ decision. It held that substantial evidence supported the agency’s finding, that the delayed notice and pre-hearing registry placement did not invalidate the later agency decision because Mitchell received a meaningful postdeprivation hearing, and that he failed to show prejudice. The court also held that the administrative fact-finder properly considered witness-statement summaries, Mitchell’s guilty plea, and statements from his sex-offender assessment.