Deubelbeiss v. Commercial Fisheries Entry Commission

RABINO WITZ, Justice,

dissenting.

The Court holds that there is not a fair and substantial relation between residence in a particular census district and availability of alternative occupations. 689 P.2d at 490. Justice Compton, who concurs with the Court’s holding, believes that “[tjhere is simply no justification for [the] anomalies” the Commission’s regulation creates. 689 P.2d at 494. I disagree. The obvious premise underlying the regulatory scheme is that in primarily urban areas more jobs and more kinds of jobs are available than in primarily rural areas. In general, this is true, and I do not understand my colleagues to be holding otherwise. To the extent that they agree with Deubelbeiss that the Commission’s reliance on census districts “simply bears no realistic correlation to whether a given applicant has alternative occupations available in his domicile,” 689 P.2d at 489, I think both the majority opinion and the concurrence are wrong.

A census district is indeed “a federal population device for determining political representation.” 689 P.2d 489. But it is also an area about which extensive federally collected information is available. Part of this information concerns a district’s rural, suburban or urban character. If the Commission was concerned about distinguishing between rural and urban areas, census district boundaries provide logical, if rough, locations for the necessary lines. My colleagues imply that the Commission should have based its decisions on the road distances between applicants’ homes and urban areas in which they might find work. 689 P.2d at 490 n. 8. Yet lines drawn on this basis may be just as arbitrary as the lines they reject.1

*491If people like Deubelbeiss are automatically allocated fewer points for availability of alternative occupations because they happen to live within a specified distance of an urban center, despite the fact that they reside in a small fishing town,2 then a scheme giving them fewer points is under-inclusive. If people living more than a specified distance from an urban center are automatically awarded the maximum point allotment, even though they might in fact commute to the urban center in search of work, the classification is overinclusive. Thus this alternative suffers from the same weaknesses as the Commission’s regulation. But the choice among admittedly imperfect regulatory answers to complex problems is properly one for the Commission, not this court.3 If the Commission’s choice bears a “fair and substantial relation” to its admittedly proper purpose, Isakson v. Rickey, 550 P.2d 359, 363 (Alaska 1976), we should not disturb it. It does, and we shouldn’t.4

. Their implied alternative is only one of several possibilities. Deubelbeiss suggests that the Commission should have done a town-by-town analysis of the actual availability of alternative occupations. He also intimates that the inquiry should have included an examination of each applicant’s employability.

. I cannot accept the majority’s characterization of Ninilchik as "isolated." 689 P.2d at 490.

. This is true even if one tries to decide this case on statutory grounds. I do not understand the concurrence to be arguing that the regulations are actually inconsistent with AS 16.43.250. One of its objections may be that the regulations are not "reasonably necessary” to implement that statute; but it is clear from Kelly v. Zamarello, 486 P.2d 906 (Alaska 1971), that in applying the "reasonably necessary" test a court should defer to an agency’s choice among acceptable alternatives. To say that we “substitute our judgment” for the agency’s on these matters of judicial review is true, but I am not sure it is relevant. The question we are answering is one which assumes deference to the agency’s decisions.

Similarly, it is for us to decide whether or not a CFEC regulation results in "unjust discrimination," but this fact does not necessarily allow us to reject Commission choices which we believe to be inferior to other alternatives. Rather, we must in effect decide whether a Commission choice denies applicants equal protection of the laws, and the "fair and substantial relation” test we use may or may not call for detailed consideration of possible alternatives, depending on the importance of the right asserted. See, e.g., ALPAC v. Brown, 687 P.2d 264, 270 (Alaska, 1984); see also id. at 279 (Compton, J., dissenting) (calling a statute an "acceptable attempt to meet acknowledged differences").

.This is not the occasion to try to harmonize the various equal protection standards this court has used in Limited Entry cases. See, e.g., CFEC v. Apokedak, 606 P.2d 1255, 1266 (Alaska 1980) (applicant has "important right to engage in economic endeavor”); State v. Ostrosky, 667 P.2d 1184, 1193 (Alaska 1983), appeal dismissed, - U.S. -, 104 S.Ct. 2379, 81 L.Ed.2d 339 (1984) (interest in receiving entry permit by lottery or apprenticeship, as opposed to by purchase or inheritance, is "not of a high order"). Suffice it to say that this is not a challenge to Limited Entry in general or to a particular denial of the right to have one’s application considered; instead, this is an attack on one facet of the point system with which the Commission evaluates applicants. Thus our review should be relatively deferential. Rose v. CFEC, 647 P.2d 154 (Alaska 1982).

This also is not the place to decide whether this matter should first be analyzed under AS 16.43.010(a)’s prohibition of "unjust discrimination” or under the Alaska Constitution's equal protection clause. The Court articulates no reason for its choice, but in practice the two inquiries are difficult to distinguish. See 689 P.2d at 490, and compare Rose v. CFEC (equal protection) with CFEC v. Templeton, 598 P.2d 77 (Alaska 1979) (AS 16.43.010(a)). See also note 3 supra.