Chevy Chase Citizens Ass'n v. District of Columbia Council

KERN, Associate Judge

(concurring in the result) :

I agree with the result reached by the majority but quite disagree with its construction of the contested case provisions of the District of Columbia Administrative Procedure Act (DCAPA).

Focusing on Section 1-1502(8) of D.C. Code 1973, which defines a contested case, and substituting for each term therein the definition for it contained elsewhere in Section 1502, a contested case may be defined thus:

A process [either] of rule-making, disposing finally of any matter, or licensing before the Commissioner, Council, or any agency in which the legal rights, duties, or privileges of specific persons entitled to be admitted as parties to such process are required by provision of any law (other than the DCAPA itself) or the Constitution to be determined after a hearing before the said Commissioner, Council or agency.

Nowhere in this definition of contested case enacted by Congress in 1968 is there any qualification of the phrase “after a hearing”, which the majority concludes must be construed to mean “after a trial-type hearing” (emphasis added). Nor, with all deference, do I find, as the majority appears to find, that the Congressional definition of contested case, as set forth above, is “nonsense” unless so qualified.

*318The source of the majority’s concern is that if an administrative law proceeding is a contested case within the meaning of the DCAPA then (1) the proponent of the proposed rule or order has the burden of proof, (2) every party thereto has the right to submit rebuttal evidence and conduct cross-examination, (3) the Commissioner, Council or agency, as the case may be, is required to maintain an official record, and (4) the decision rendered must be in writing accompanied by findings of fact and conclusions of law and is subject to judicial review in this court. D.C.Code 1973, §§ 1-1509, 1-1510. The majority seems to fear that this panoply of procedure will impair the workings of government if “contested case” is read as written.

An examination of the D.C.Code reveals that some 65 sections or subsections require a hearing before governmental action may be taken. This requirement exists in connection with three general categories of activity: (1) Grant, denial or revocation of licenses or applications; (2) Regulation of specific classifications of groups or persons, and (3) Governmental action affecting both identifiable specific persons and the remainder of the community. See Appendix. Only the last category appears to me to present any potential for practical difficulty if the provisions of a contested case dealing with cross-examination, maintaining a record, etc., are applicable. However, this possible difficulty is virtually eliminated by (1) the statutory right of the administrative body conducting a contested case to exclude irrelevant, immaterial and unduly repetitious evidence 1 and (2) the requirement in the definition of contested case that there must be specific persons entitled to be admitted as parties to the on-going administrative process affecting their legal rights, duties or privileges.

Given what I believe to be the clear and workable definition of contested case contained in Section 1502(8) which Congress only recently enacted after considerable study,2 I would apply that statute as enacted rather than now rewrite the statute upon the basis of how we deem an administrative proceeding would best be conducted. See District of Columbia v. M.E.H., D.C. App., 312 A.2d 561, 567-570 (1973) (dissenting opinion).

In the instant case the Council proposed to close a street and Section 7-402 requires a hearing be held. The owners of the property abutting the street to be closed are in my view persons entitled to be admitted as parties to such administrative process since their legal rights and duties will certainly be affected by the Council’s action.3 Accordingly, I view the street-*319closing here to be a contested case. However, Section 7-405 goes on to provide that if an objection to the street-closing is made “then the Commissioner . . . shall institute a proceeding in rem in Superior Court of the District of Columbia for the closing of such street . . . and for the ascertainment of damages and the assessment of benefits resulting from such closing. . . . ” (Emphasis added.) The definition of contested case specifically excludes “any matter subject to a subsequent trial of the law and the facts de novo in any court”. I am constrained to conclude that the Council’s action here falls within that express exclusion, and therefore concur in the dismissal of the petitions for lack of jurisdiction.

APPENDIX

1. Licenses and Applications

D.C.Code §§ 2-129, 2-253 (c), 2-433, 2-462, 2-517, 2-605, 2-606, 2-810, 2-920, 2-922, 2-1028, 2-1110, 2-1304, 2-1405, 2-1809(a) and (b), 2-2006(b) and 2 — 2409(f); §§ 3-214; 7-408, 25-115(b), 25-118; 26-602, 26-606; 29-417; 31-902 ; 35-222(b), 35-405, 35-426, 35-1306, 35-1339, 35-1340; 43-307, 43-416; 44-307, 44-416; '44-302(c); 45-1608; 47-2344 (d) and (i), 47-2806.

2. Regulations

D.C.Code §§ 1-252, 1-253, 1-257 ; 2-253(b), 2-914, 2-2110; 5-415, 5-705(a), 5-711, 5-718(a); 6-812(b); 7-115, 7-122; 36-407(a), 36-408(d), 36-434; 47-300.

3. Action by Government

D.C.Code §§ 1-231 (controlling outdoor ad signs on public and private property), l-244(f) (change names of highways); 5-706 (c) (lease or sell property in a redevelopment area); 7-311 (close alley or street), 402 (close public way), 7-950(a) (rental of air space); 47-1106 (assessing property owner for public improvement).

. The administrative entity before whom the contested case is held, whether it he the Commissioner, the Council or an agency, “shall exclude irrelevant, immaterial and unduly repetitious evidence.” D.C.Code 1973, § l-1509(b). (Emphasis added.)

. The majority draws upon the Model State Administrative Procedure Act to support its construction of the DCAPA but it appears to me that our APA was deemed unique by its framers. Thus, the Committee report states:

Obviously, all the provisions of the usual model State Administrative Procedure Act may not successfully be applied literally to the varied operations of the many different administrative agencies in the District of Columbia. Hence, the model act has been revised in many respects to meet local conditions, so the reported bill is well developed and provides a comprehensive District of Columbia Administrative Procedure Act. (Emphasis added.) H.R.Rep.No.202, 90th Cong., 1st Sess. 4-5 (1967).

.The procedural rights granted by the DCAPA in contested cases apply only to parties. D.C. Code 1973, § 1-1509. The SEA, on the other hand, provides that any “person interested” has a right to be heard, D.C.Code 1973, § 7-402, and to file written objections to the dosing decision, forcing the Council to resort to a proceeding in rem to finalize its order. D.C.Code 1973, §§ 7-404, 7-405. It is clear that residents of the neighborhood surrounding the subject property are persons interested. It would follow, therefore, that representative advocates of their interests are entitled to be admitted as parties to the proceeding if those interests are not adequately represented by the abutting property owners.