Matter of Peng v. Poole
The petitioner, Mexia Peng, initiated a CPLR article 78 proceeding to review a determination made by the New York State Office of Children and Family Services (OCFS). OCFS had previously denied her request to change an "indicated" report of child abuse and maltreatment to "unfounded." The underlying report stemmed from an allegation that Peng struck a five-year-old child in the face with a ruler as punishment. The Appellate Division, Second Department, confirmed OCFS's determination, stating it was supported by substantial evidence in the record. The court denied the petition and dismissed the proceeding on the merits, also noting that hearsay evidence is permissible and can be sufficiently probative in administrative hearings.