Arkansas Contractors Licensing Board v. Pegasus Renovation Co.

T OM GLAZE, Justice,

concurring. I join in the result reached by the majority because there is unquestionably substantial evidence to support the decision rendered by the Arkansas Contractors Licensing Board. However, I am unclear what standard of review the majority is using to reach its decision in affirming the Board.

Obviously, if the Board based its decision on substantial evidence (which we opine it did), the Board’s decision could not be arbitrary, capricious, or an abuse of discretion. E.g., see the Arkansas Administrative Procedure Act, Ark. Code Ann. § 25-15-212(h)(5) and (6); see also Wright v. Arkansas State Plant Board, 311 Ark. 125, 842 S.W.2d 42 (1992). If the issue on review was whether the Board’s action was arbitrary, capricious, or an abuse of discretion (not substantial evidence), the review of the Board’s ruling becomes a closer question. Then the question is whether the Board’s action need only be supported on any rational basis. Someday the court needs to address these two different standards and decide which one applies when reviewing administrative agency decisions.