The following excerpt is from FMC Corp. (Peroxygen Chemicals Div.) v. Unmack, 677 N.Y.S.2d 269, 699 N.E.2d 893, 92 N.Y.2d 179 (N.Y. 1998):
The substantial evidence standard is a minimal standard. It requires less than "clear and convincing evidence" (Matter of Carriage House Motor Inn v. City of Watertown, 136 A.D.2d 895, 524 N.Y.S.2d 930, supra), and less than proof by "a preponderance
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