Two different courtrooms
Administrative litigation in New York usually runs through one of two systems. Decisions of state and local agencies are commonly challenged in state court through an Article 78 proceeding, which asks whether the agency acted within the law and had a sound basis for its decision. Some cases that turn on whether a hearing decision was supported by substantial evidence are sent to the Appellate Division. Federal agency actions are generally challenged in federal court under the Administrative Procedure Act or a statute specific to that agency, and some statutes route review directly to a federal court of appeals. Both systems impose filing deadlines, and some are short.
How much courts defer
Courts reviewing agency action do not usually retry the facts. They look at the record the agency assembled and ask whether the decision holds up under the applicable standard. In federal court, the Supreme Court in recent years ended the doctrine that required judges to defer to an agency's reasonable reading of an ambiguous statute, so legal interpretation is now decided by the court, though agency expertise can still carry weight. New York courts follow their own deference rules, which were not changed by that federal ruling. Factual findings and policy judgments still receive significant respect in both systems.
What relief usually looks like
The most common result of a successful challenge is not a reversal but a remand, which sends the matter back to the agency to decide again under the correct rule or with a fuller explanation. Courts can also set aside a rule or decision, and they may pause it while the case proceeds, although that requires a separate showing. The Supreme Court has limited nationwide injunctions, while questions about other broad remedies remain debated. Before filing, we review the final decision, the record, and whether every internal step was completed. We also consider timing, since some challenges must be brought quickly after a rule or decision issues.
