New York Court of Appeals

In the Matter of Richard Rosenthal v. " John " Hartnett, as Hearing Officer of the Administrative Adjudication…

March 24, 197536 N.Y.2d 269

Summary

The New York Court of Appeals held that the Legislature may constitutionally delegate adjudication of traffic infractions to an administrative agency and may require clear and convincing evidence for findings of guilt when only a fine is at stake, finding no due process or equal protection violation. The Court reversed the lower court, reinstated the administrative finding of guilt, and dismissed the petition. Two dissenting opinions argued that abandoning the beyond‑reasonable‑doubt standard violates due process and lacks a rational basis.