Matter of Charles A. Field Delivery Serv. (Roberts)

In Matter of Charles A. Field Delivery Serv. (Roberts) (66 NY2d 516 [1985]) the issue before the administrative agency was whether drivers working for the respondent were employees or independent contractors. As the Court of Appeals pointed out, whether an employer-employee relationship exists is basically a question of fact, and one which often arises in the context of Unemployment Insurance Law cases. On the basis of facts that were essentially identical to those of two prior cases which had been upheld by the Court of Appeals, the agency came to a diametrically opposite conclusion with respect to workers employed by Charles A. Field Delivery Service. Remanding the case to the Unemployment Insurance Appeal Board, to reconsider the facts, the Court of Appeals stated: "From the policy considerations embodied in administrative law, it follows that when an agency determines to alter its prior stated course it must set forth its reasons for doing so. Unless such an explanation is furnished, a reviewing court will be unable to determine whether the agency has changed its prior interpretation of the law for valid reasons, or has simply overlooked or ignored its prior decision." (Id. at 520.)