Gay v. Board of Engineers & Architects

CourtNebraska Supreme Court
DecidedJuly 2, 2026
DocketS-25-002
StatusPublished

This text of Gay v. Board of Engineers & Architects (Gay v. Board of Engineers & Architects) is published on Counsel Stack Legal Research, covering Nebraska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gay v. Board of Engineers & Architects, (Neb. 2026).

Opinion

Nebraska Supreme Court Online Library www.nebraska.gov/apps-courts-epub/ 07/02/2026 08:08 AM CDT

- 712 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports GAY v. BOARD OF ENGINEERS & ARCHITECTS Cite as 321 Neb. 712

Tobias S. Gay, appellant, v. Board of Engineers and Architects, appellee. ___ N.W.3d ___

Filed July 2, 2026. No. S-25-002.

1. Administrative Law: Judgments: Appeal and Error. A judgment or final order rendered by a district court in a judicial review pursuant to the Administrative Procedure Act may be reversed, vacated, or modified by an appellate court for errors appearing on the record. 2. ____: ____: ____. When reviewing an order of a district court under the Administrative Procedure Act for errors appearing on the record, the inquiry is whether the decision conforms to the law, is sup- ported by competent evidence, and is neither arbitrary, capricious, nor unreasonable. 3. Judgments: Statutes: Rules of the Supreme Court: Appeal and Error. For purposes of construction, Nebraska Supreme Court rules are treated like statutes, and therefore an appellate court independently reviews the conclusion of a lower court. 4. Constitutional Law: Due Process. The determination of whether the procedures afforded to an individual comport with the constitutional requirements for procedural due process presents a question of law. 5. Administrative Law: Appeal and Error. An issue that has not been presented in the petition for judicial review has not been properly pre- served for consideration by the district court. 6. Courts: Rules of the Supreme Court: Appeal and Error. Under Neb. Ct. R. § 6-1518(B) (rev. 2025), a statement of errors shall be filed only in appeals from the county court to the district court. 7. Due Process: Notice. Due process does not guarantee an individual any particular form of state procedure. Instead, the requirements of due process are satisfied if a person has reasonable notice and an opportunity to be heard appropriate to the nature of the proceeding and the character of the rights which might be affected by it. - 713 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports GAY v. BOARD OF ENGINEERS & ARCHITECTS Cite as 321 Neb. 712

8. Administrative Law: Due Process: Notice: Evidence. In proceedings before an administrative agency or tribunal, procedural due process requires notice, identification of the accuser, factual basis for the accusa- tion, reasonable time and opportunity to present evidence concerning the accusation, and a hearing before an impartial board.

Appeal from the District Court for Lancaster County: Andrew R. Jacobsen, Judge. Affirmed.

Clark J. Grant, of Grant & Grant, for appellant.

Michael T. Hilgers, Attorney General, and Benedict Kinnison for appellee.

Funke, C.J., Cassel, Stacy, Papik, Freudenberg, Bergevin, and Vaughn, JJ.

Per Curiam. INTRODUCTION Tobias S. Gay appeals from the district court’s judgment on review from a disciplinary action by Nebraska’s Board of Engineers and Architects (Board). The court imposed the same disciplinary action as the Board: revocation of Gay’s licenses and a prohibition on his applying for licensure for 5 years. Gay argues that the Board violated his due process rights and that the disciplinary action was excessive. We affirm. BACKGROUND Petition and Notice The Board filed a “Petition for Disciplinary Action and Notice of Hearing” and served it upon Gay. The petition alleged the following facts: In Gay’s license renewal application, he set forth that he had “satisfied the mandatory continuing education requirements.” Gay’s license renewal application was randomly selected for a continuing education audit. As part of the audit, Gay was required to submit a continuing education log and attendance - 714 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports GAY v. BOARD OF ENGINEERS & ARCHITECTS Cite as 321 Neb. 712

verification detailing his continuing education for the relevant time period. Gay submitted a log identifying 19 web-based courses taken, along with 19 unsigned certificates of comple- tion. However, the attendance report obtained by the Board indicated that Gay did not attend courses on three reported dates and that the total number of hours he claimed was double the actual hours for the courses. Subsequently, the Board asked Gay to provide signed certificates of completion. Gay informed the Board that he had spoken with the courses’ sponsor, whom Gay stated told him that “the num- ber discrepancies [were] an error and he [would] get that fixed,” and that the sponsor would provide Gay with signed certificates of completion. Gay later provided the Board with a revised log and 19 certificates of completion with the spon- sor’s “wet signature.” However, the Board’s investigation revealed that the sponsor’s practice was to provide certificates with digital signatures, that the sponsor never “wet-signed” any certificates of completion, and that the sponsor did not speak with Gay as Gay had claimed. The petition charged Gay with providing false evidence to maintain his licenses, which constituted grounds for disci- plinary action under Neb. Rev. Stat. § 81-3444 (Reissue 2024). It also set forth that Gay was subject to a prior disciplinary settlement agreement that concerned his competency on two projects in which he provided services beyond his licensure. Pursuant to the settlement agreement, those matters could be considered for disciplinary purposes in the event of any future violation within 5 years. The petition set forth that Gay’s alleged violations were within that 5-year period. The petition further provided that a hearing would be con- ducted on the petition for disciplinary action “during which evidence will be received[,] and a decision will be made as to whether disciplinary action should be taken.” The included notice of hearing provided in full: “YOU AND EACH OF YOU ARE HEREBY NOTIFIED that [the Board] - 715 - Nebraska Supreme Court Advance Sheets 321 Nebraska Reports GAY v. BOARD OF ENGINEERS & ARCHITECTS Cite as 321 Neb. 712

will call up for hearing its Petition for Disciplinary Action before [the Board] on Friday, May 17, 2024, at 9:00 a.m., or as soon thereafter as counsel may be heard.”

Board Hearing At the commencement of the hearing, the hearing officer stated that the hearing would be conducted in accordance with the Board’s promulgated rules and that the rules of evidence would not apply to the hearing because neither party had requested such. The hearing officer also set forth the order in which evidence would be presented, that each party would have the opportunity to cross-examine the others’ witnesses, and that each party would have the opportunity to make a clos- ing argument. The hearing officer asked whether Gay was “represented by counsel today?” Gay replied, “I’m just representing myself today. I have no counsel.” The hearing officer then inquired if the parties were ready to proceed. The Board’s counsel responded affirmatively and was granted permission to call the Board’s first witness. The bill of exceptions contains no response from Gay. The Board elicited testimony from the compliance officer who handled Gay’s audit, introduced related exhibits, and intro- duced an affidavit from the courses’ sponsor, which, together, established the facts set forth above. Upon being asked, Gay did not cross-examine the compli- ance officer and did not object to the receipt of the sponsor’s affidavit. Regarding the affidavit, the bill of exceptions reflects the following: “[Board attorney:] I do have an affidavit I’d like to submit from [the courses’ sponsor]. [Hearing officer:] Okay. [Board attorney:] And that’s been identified as Exhibit 9. [Hearing officer:] Okay. Exhibit is received.” Gay then testified in his own defense.

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