Halperin v. City of New Rochelle

In Halperin v. City of New Rochelle, 24 AD3d 768 (2d Dept 2005), the court held that a "substantial evidence" question arises "only where a quasi-judicial evidentiary hearing has been held." The court noted that public hearings related to zoning issues are informational and not evidentiary or adversarial (Id.). Therefore, those determinations are reviewed under the "arbitrary and capricious" standard rather than the "substantial evidence" standard (Id.). Further, "the determination of a land use agency must be confirmed if it was rational and not arbitrary and capricious" (Id.)