Boyd v. Perales
The petitioner sought to expunge a 1976 child abuse report from the State Central Register, which alleged that her children were left bound and unsupervised, arguing it was irrelevant to her current child care employment. This challenge was initiated via a CPLR article 78 petition and transferred to the Appellate Division. An Administrative Law Judge had previously expunged two later reports but maintained the 1976 report. The court confirmed the respondents' determination, finding substantial evidence supported the ALJ's conclusion that the petitioner's serious lack of judgment in 1976 remained relevant to child care. Furthermore, the court dismissed the petitioner's due process argument as it was raised for the first time on appeal.