Matter of Carroll v. . Knickerbocker Ice Co.
218 N.Y. 435, 113 N.E. 507, 1916 N.Y. LEXIS 1085 (1916)
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Rule of Law:
Under the 'legal residuum rule,' an administrative agency's finding must be supported by a residuum of legal evidence. An award cannot be sustained if it is based solely on hearsay evidence that is contradicted by substantial, competent evidence to the contrary.
Facts:
- Myles Carroll was employed by the Knickerbocker Ice Company as an ice wagon driver.
- On September 22, 1914, Carroll delivered a 300-pound cake of ice to a saloon.
- A helper on the wagon and two saloon employees were present during the delivery and did not observe any accident or see any ice fall on Carroll.
- Later that day, after returning home, Carroll told his wife, Bridget Carroll, that a cake of ice had slipped and fallen on him.
- Carroll repeated this account of an accident to his physician, a neighbor, and hospital staff.
- Medical examinations of Carroll revealed no bruises, discolorations, or other external signs of physical injury.
- Carroll subsequently developed delirium tremens and died on September 28, 1914.
Procedural Posture:
- Bridget Carroll, the decedent's widow, filed a claim for death benefits with the New York workmen's compensation commission.
- The commission found the death was caused by a work-related injury and granted an award to Bridget Carroll.
- The employer, Knickerbocker Ice Company, appealed the commission's decision to the Appellate Division of the Supreme Court.
- A divided panel of the Appellate Division affirmed the commission's award.
- Knickerbocker Ice Company appealed the Appellate Division's judgment to the Court of Appeals of New York.
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Issue:
Under the Workmen's Compensation Law, can an administrative award be sustained if it is based solely on hearsay evidence that is contradicted by substantial, direct evidence?
Opinions:
Majority - Cuddeback, J.
No. While Section 68 of the Workmen's Compensation Law frees the commission from common law rules of evidence and allows for the admission of hearsay, a finding cannot be sustained based entirely on such evidence when it is contradicted by substantial evidence. The statute's goal to ascertain 'substantial rights' requires that there be a 'residuum of legal evidence' to support a claim. In this case, the hearsay statements of the decedent were directly contradicted by eyewitness testimony and the lack of physical evidence. Since the presumption in favor of the claim was overcome by substantial evidence, the remaining hearsay was insufficient on its own to support the award.
Dissenting - Seabury, J.
Yes. The award should be sustained because the legislature, through Section 68, explicitly commanded the commission not to be bound by common law rules of evidence. To judicially impose a 'residuum' rule re-introduces the very technicalities the statute was designed to eliminate. The law sanctions the admission of hearsay, which by necessary implication means the commission is authorized to act upon it if it deems the evidence credible. The commission was justified in believing the decedent's consistent statements, and the court has no power to overturn an award that is supported by what the statute makes legal evidence.
Dissenting - Pound, J.
Yes. The award should be affirmed because the strict exclusionary rule against hearsay is a product of the jury system and should not be rigidly applied to an expert administrative body like the commission. Section 68 allows the commission to adopt a more liberal evidence standard, akin to that in federal courts, which might deem the decedent's statements competent and sufficient as part of the res gestae. The evidence was legally admissible under the statute, and its weight was a question of fact for the commission, not a question of law for the court, to decide.
Concurring - Willard Bartlett, Ch. J.
No. The award cannot be sustained. While the Workmen's Compensation Law permits an award based on hearsay evidence in the absence of substantial evidence to the contrary, that is not the case here. The hearsay evidence of an accident was directly contradicted by the testimony of eyewitnesses. This direct contradiction renders the hearsay insufficient to raise any issue of fact, and therefore it cannot serve as the sole basis for the award.
Analysis:
This case establishes the influential 'legal residuum rule' for administrative law in New York, which was widely adopted by other jurisdictions. It strikes a balance between the statutory relaxation of evidence rules for administrative agencies and the due process need for reliable evidence. The rule requires that while an agency can consider hearsay, its final decision must be supported by at least a minimal amount ('a residuum') of legally competent evidence that would be admissible in a court of law, especially when the hearsay is contradicted. This precedent significantly shaped the standard of judicial review for administrative agency findings for decades.
