Matter of Monaghan v. Schroeder

Summary

The Court affirmed the Appellate Division’s revocation of Mr. Monaghan’s driver’s license, holding that CPLR 2308(b) provides adequate process for subpoena enforcement and that due‑process does not require dismissal of the charge when a motorist fails to seek that enforcement. It also found the ALJ’s decision supported by substantial evidence and that the DMV did not act arbitrarily or capriciously.