What constitutes a proper evidentiary basis for agency findings under substantial evidence review?

What constitutes a proper evidentiary basis for agency findings under substantial evidence review?

• A. A comprehensive record containing reliable, relevant, and probative evidence that a reasonable mind could accept as adequate.
• B. The agency's own belief about its findings.
• C. Any plausible justification, regardless of record.
• D. A mere administrative convenience.

Answer: (A)

In substantial evidence review, the agency’s factual findings must be grounded in a real record. The evidentiary basis is a comprehensive record containing reliable, relevant, and probative evidence that a reasonable mind could accept as adequate to support the finding. This means the support has to be in the record itself—documents, testimony, data, and other admissible material—not just the agency’s own belief, intuition, or post hoc rationalizations. The court isn’t looking for what the agency thinks is convenient or what would be a plausible justification if you skim the record; there must actually be evidence on the record that a reasonable person could rely on to reach the conclusion. Even if other parts of the record point in a different direction, the finding stands as long as substantial evidence supports it. Conversely, if the record lacks that adequate evidentiary support, the finding cannot stand.

In substantial evidence review, the agency’s factual findings must be grounded in a real record. The evidentiary basis is a comprehensive record containing reliable, relevant, and probative evidence that a reasonable mind could accept as adequate to support the finding. This means the support has to be in the record itself—documents, testimony, data, and other admissible material—not just the agency’s own belief, intuition, or post hoc rationalizations. The court isn’t looking for what the agency thinks is convenient or what would be a plausible justification if you skim the record; there must actually be evidence on the record that a reasonable person could rely on to reach the conclusion. Even if other parts of the record point in a different direction, the finding stands as long as substantial evidence supports it. Conversely, if the record lacks that adequate evidentiary support, the finding cannot stand.