Substantial Evidence Standard
Administrative Law · Lesson 11
Substantial Evidence Standard
這一課問的是：機關之事實認定是否有整體記錄中實質證據之支持？
ActorActObjectStandardConsequence
Issue · what this lesson is really about
Is the agency's factual finding supported by substantial evidence in the whole record?
這一課問的是：機關之事實認定是否有整體記錄中實質證據之支持？
Trigger words & phrases that should flag this issue:
substantial evidencefactual findingALJreasonable mindwhole record
Core Terminology · 7 must-know
Tap a card to flip and reveal the meaning.
§ 706(2)(E)
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Substantial evidence review for formal proceedings.
§ 706(2)(E)。
substantial evidence
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More than scintilla; such relevant evidence as reasonable mind might accept.
實質證據。
whole record
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Court must consider the whole record, including contrary evidence.
整體記錄。
Universal Camera
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Substantial evidence review on the record considered as a whole.
Universal Camera。
ALJ credibility
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Reviewing body normally accepts ALJ credibility findings.
ALJ 信用判斷。
preponderance vs substantial
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Substantial evidence less demanding than preponderance.
實質證據低於優勢。
Rule Sentence · the workhorse
Under APA § 706(2)(E), agency factual findings in formal proceedings are reviewed under the substantial evidence standard — such relevant evidence as a reasonable mind might accept as adequate, considering the whole record including evidence detracting from the finding.
Sentence Anatomy · 5 roles, 5 colors
Every rule sentence breaks into five visual roles.
Actor 行為人reviewing court審查法院
Act 行為reviewing factual findings審查事實認定
Object 對象agency findings機關認定
Standard 法律標準substantial evidence on whole record整體記錄之實質證據
Consequence 後果upheld or set aside維持或廢棄
Casebook Snapshot · a real American case
Universal Camera Corp. v. NLRB
Holding. Substantial evidence review requires consideration of the whole record, not just evidence supporting the agency's decision; evidence opposing the finding must be weighed in the analysis.
Why it matters. Universal Camera requires whole-record review — agencies cannot ignore contrary evidence.
Universal Camera：須整體記錄審查；不可忽視相反證據。
Common Mistakes · what trips students
✗ substantial evidence = preponderance。
✓ Substantial evidence is lower than preponderance.
實質證據低於優勢。
Mini IRAC · build the Application
Issue. Is the NLRB's finding that the employer committed an unfair labor practice supported by substantial evidence where the evidence is mixed?
Rule. Substantial evidence review requires consideration of the whole record, including evidence detracting from the finding.
Application (model). The NLRB found a ULP based on some evidence; substantial contrary evidence also exists. Because Universal Camera requires consideration of the whole record, the fact that contrary evidence exists doesn't automatically defeat the finding — the question is whether reasonable minds could accept the agency's view given the whole record.
Pick the right element for each blank:
g1.
g2.
Conclusion. Therefore, if reasonable minds could accept the NLRB's view considering all evidence, the finding survives; otherwise it must be vacated.
MBE Check · multiple choice
Substantial evidence vs preponderance of the evidence — which is more demanding?
Practice Drill · tap to build the rule
Drop the chips here in correct order:
Tap chips to add → tap chips in the target to remove: