Chambers v. Department of Public Welfare, 19 A.3d 1

Chambers, an adult with mental retardation, challenged a DPW termination from the Consolidated Waiver program.
Centre County’s Administrative Entity (County Services) monitors ISPs and requires minimum quarterly face-to-face visits.
Guardian, Chambers’ caregiver, received a July 9, 2009 termination notice and challenged it on July 22, 2009.
ALJ found uncooperative conduct by the Guardian precluded monitoring; Secretary upheld the ALJ’s decision.
Chambers argued the record relied on hearsay and lacked substantial evidence to support the findings; the Commonwealth Court reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Notice sufficiency	Chambers contends notice inadequately described the allegations.	DPW argues notice was sufficient to inform and initiate challenged action.	DPW notice adequate
Pre-hearing due process deficiencies	Guardian alleges procedural gaps before hearing violated due process.	County/DPW disputes that any due process violation occurred.	Not resolved on substantial basis
ALJ hearing conduct regarding cross-examination	Guardian asserts cross-examination restrictions violated DPW regulations.	Hearing conduct complied with applicable rules.	Not resolved on substantial basis
Substantial evidence supporting factual findings	Key findings rest on hearsay and uncorroborated notes, lacking substantial evidence.	DPW argues corroborative elements and inferences support findings.	No substantial evidence supporting necessary factual findings; reversed

Six L's Packing Co. v. Workers' Comp. Appeal Bd. (Williamson), 2 A.3d 1268 (Pa. Cmwlth. 2010) (hearsay and corroboration issues in evidentiary weight)
Kyu Son Yi, DVM v. State Bd. of Veterinary Med., 960 A.2d 864 (Pa. Cmwlth. 2008) (ephemeral, non-positive evidence cannot support findings)
Gibbs v. Dep't of Pub. Welfare, 947 A.2d 233 (Pa. Cmwlth. 2008) (scope of review for DPW reconsideration decisions)