Bowen v. Doyal

253 So. 2d 200, 259 La. 839
CourtSupreme Court of Louisiana
DecidedOctober 20, 1971
Docket50945
StatusPublished
Cited by64 cases

This text of 253 So. 2d 200 (Bowen v. Doyal) is published on Counsel Stack Legal Research, covering Supreme Court of Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bowen v. Doyal, 253 So. 2d 200, 259 La. 839 (La. 1971).

Opinions

BARHAM,- Justice.

The Administrator of the División of Employment Security,,;,Department-.pf [843]*843Labor, lias appealed under Louisiana Constitution Article 7, Section 10(2), from a judgment of the district court'which had the effect of declaring unconstitutional a portion of R.S. 23:1634.1

Richard W. Bowen had been adversely affected by a decision of the Board of Review of the Division of Employment Security. That Board of Review had affirmed a decision of the appeals referee approving the local agency’s determination that Bowen was disqualified for unemployment compensation benefits. Bowen timely instituted by petition a suit in the district court of his domicile for review of this adverse ruling, as provided in the statute. Both the administrator and Bowen’s employer, made defendants in the suit, answered the petition, and the administrator admitted that the petitioner was entitled to judicial review of the board’s decision.

The district court on its own motion concluded that it lacked jurisdiction and dismissed the suit, relying upon Albert v. Parish of Rapides, 256 La. 566, 237 So. 2d 380. The court held that the suit was an appeal, and that Section 36 of Article 7 of the Constitution, which delineates the appellate jurisdiction of the district courts, did not confer appellate jurisdiction of this matter. It concluded that R.S. 23 :1634,2 providing for a "petition for re[845]*845view” to be filed in the district court of the claimant’s domicile, could not confer extraconstitutional appellate jurisdiction upon the district court. That court’s finding that this suit was an appeal was error.

Hearings and determinations by administrative agencies are often quasi-judicial, for, like the courts, these bodies adjudicate important rights. Ordinarily there is a board of review within the agency which affords administrative review of or appeal from the original determination or adjudication. Many statutes granting administrative bodies the authority to act adjudicatively contain special provisions for the right of judicial reviezv of the final determination at the highest level within the agency, as does the statute here involved. But even in the absence of such statutory authority, the right of judicial review of administrative proceedings is presumed to exist. Generally the availability of judicial review is necessary to the validity of such proceedings under our legal system and our traditions. The exceptions where judicial review of administrative determination is not given are so limited as not to require discussion in the present case. See 4 Davis, Administrative Law Treatise, §§ 28.01 et seq. (1958) and 1970 Supplement; see also Schwartz, An Introduction to American Administrative Law (2d ed. 1962), Chapt. 7; 2 Cooper, State Administrative Law, Chapt. 18 (1965); Jaffe, The Right to Judicial Review, 71 Harv. L.Rev. 401.

Even in the face of statutory attempts to preclude review of administrative proceedings the United States Supreme Court has determined judicial review to be essential. Estep v. United States, 327 U.S. 114, 66 S.Ct. 423, 90 L.Ed. 567 (1946); Dickinson v. United States, 346 U.S. 389, 74 S.Ct. 152, 98 L.Ed. 132 (1953); Oestereich v. Selective Service System Local Board No. 11, 393 U.S. 233, 89 S.Ct. 414, 21 L.Ed.2d 402 (1968). Moreover, that court appears to act under a presumption [847]*847of reviewability which yields only to affirmative legislative intent in' favor of unreviewability when such intent is based upon ■ reasonable grounds or to special féasori’ for unreviewability because of the pécüliar: subject matter or circumstances. American School of Magnetic Healing v. McAnnulty, 187 U.S. 94, 23 S.Ct. 33, 47 L.Ed. 90 (1902) ; Dismuke v. United States, 297 U.S. 167, 56 S.Ct. 400, 80 L.Ed. 561 (1936); Shields v. Utah Idaho Central R. Co., 305 U.S. 177, 59 S.Ct. 160, 83 L.Ed. 111 (1938) ; Reconstruction Finance Corp. v. Bankers T. Co., 318 U.S. 163, 63 S.Ct. 515, 87 L.Ed. 680 (1943) ; Stark v. Wickard, 321 U.S. 288, 64 S.Ct. 559, 88 L.Ed. 733 (1944); Kent v. Dulles, 357 U.S. 116, 78 S.Ct. 1113; 2 L.Ed.2d 1204 (1958); Brotherhood of Railway and Steamship Clerks, etc. v. Ass’n for Benefit of Non-Contract Employees, 380 U.S. 650, 85 S.Ct. 1192, 14 L.Ed.2d 133 (1965); Abbott Laboratories v. Gardner, 387 U.S. 136, 87 S.Ct. 1507, 18 L.Ed.2d 681 (1967). See also Brotherhood of Railroad Trainmen v. Central of Ga. Ry. Co., 415 F.2d 403 (5th Cir. 1969).

Article 1/ ’Section 6, of the Louisiana Constitution' provides that the courts must bé; ¿¡3en: to every person for adequáte remeolyitby- due process of law-. We have held tliaf'j'aííh.ough'' administrative bodies have power- -to determine as- original propositions tlie matters assigned to them under statute, a party whose legal rights have been adversely affected by that determination may ■test its legal’correctness in the. courts'.. See Meyer v. Board of Trustees, etc., 199 La. 633, 6 So.2d 713, and cases there cited; State ex rel. Rathe v. Jefferson Parish School Board, 206 La. 317, 19 So.2d 153; Parker v. Board of Barber Examiners, 84 So.2d 80 (La.App. 1st Cir. 1955); Pettit v. Penn, 180 So.2d 66 (La.App.2nd Cir. 1965), writs refused 248 La. 696, 181 So.2d 397. Thus, with the presumption that all administrative determinations are reviewable by the court and a conviction that judicial review may even be necessary in the face of legislative attempt to den}' it, in the absence of constitutional restrictions we must not only favor but preserve the right of review. The mandate of Article 1, Section 6, is of overriding concern as we consider the matter before us, which on its face presents a legal .dispute between, an individual and an administrative body.. •.....

The Albert case relied upon by The district court in this suit was 'preceded by Trosclair v. Houma Mun. Fire & Police Civil Serv. Bd., 252 La. 1, 209 So.2d 1. Both involved the question of judiciáf review of adjudications by fire and -police civil service boards. In Trosclair wé incorrectly determined that court review of a determination by a municipal 'fire’^9 police civil' service board under Constitution Article. 14, Section 15,1, did not entail the ex.efcise. of the- exclusive original pirisdictipp- pf the district court,- That-j cpgjgtitu[849]*849tional--.provision, providing fire and police civil'-, service regulations for large munici-.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Meiners v. St. Tammany Fire Protection District 4 Board of Commissioners
31 So. 3d 1076 (Louisiana Court of Appeal, 2010)
Wooley v. State Farm Fire and Cas. Ins. Co.
893 So. 2d 746 (Supreme Court of Louisiana, 2005)
ANR Pipeline Co. v. Louisiana Tax Com'n
815 So. 2d 178 (Louisiana Court of Appeal, 2002)
Lightfoot v. Stalder
808 So. 2d 710 (Louisiana Court of Appeal, 2001)
Brown v. State Farm Fire & Cas. Co.
804 So. 2d 41 (Louisiana Court of Appeal, 2001)
Blair v. Stalder
798 So. 2d 132 (Louisiana Court of Appeal, 2001)
Durousseau v. LA STATE RACING COM'N
724 So. 2d 844 (Louisiana Court of Appeal, 1998)
Jones v. SOUTHERN UNIV. AND a & M COLLEGE
693 So. 2d 1265 (Louisiana Court of Appeal, 1997)
Boeing Co. v. Louisiana Dept. of Economic Development
657 So. 2d 652 (Louisiana Court of Appeal, 1995)
State v. LOUISIANA RIVERBOAT GAMING COM'N & HORSESHOE ENTERT.
655 So. 2d 292 (Supreme Court of Louisiana, 1995)
Jordan v. City of Baton Rouge
652 So. 2d 701 (Louisiana Court of Appeal, 1995)
Kelty v. Brumfield
633 So. 2d 1210 (Supreme Court of Louisiana, 1994)
In re Industrial Pipe, Inc.
626 So. 2d 364 (Louisiana Court of Appeal, 1993)
Zeringue v. Lafourche Parish Office of Eligibility Determination
597 So. 2d 1142 (Louisiana Court of Appeal, 1992)
Matter of American Waste & Poll. Control
588 So. 2d 367 (Supreme Court of Louisiana, 1991)
In the Matter of American Waste & Pollution Control Co.
580 So. 2d 392 (Louisiana Court of Appeal, 1991)
Moore v. Roemer
560 So. 2d 927 (Louisiana Court of Appeal, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
253 So. 2d 200, 259 La. 839, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bowen-v-doyal-la-1971.