In the Matter of Joan Brown v. Miodrag Ristich, as Director of Willowbrook State School

Summary

The New York Court of Appeals held that unsworn testimony from witnesses who cannot understand an oath is admissible in administrative disciplinary proceedings under Civil Service Law §75 when a sufficient foundation shows rudimentary testimonial capacity, and that such admission does not violate the petitioner's due‑process rights nor the substantial‑evidence standard. The Court reversed the Appellate Division and reinstated the administrative dismissal of the attendant.