Sprenger v. Public Service Commission

ELDRIDGE, Judge,

concurring:

I concur in both the judgment and in the Court’s opinion. Nonetheless, I believe that some of the petitioners’ arguments, and the premises upon which they are based, warrant additional comment.

The petitioners have brought this action under the Declaratory Judgments Act, Maryland Code (1974, 2006 Repl. Vol.), §§ 3-401 et seq. of the Courts and Judicial Proceedings Article, to challenge an adjudicatory administrative decision of the Public Service Commission. The simple, short and dispositive answer to all of the petitioners’ arguments is that no such *34declaratory judgment action mil lie. It has been expressly precluded by the General Assembly.

Maryland Code (1998, 2006 Supp.), §§ 3-101 through 3-209 of the Public Utility Companies Article, sets forth a special administrative remedy before the Public Service Commission, with detailed provisions for judicial review, encompassing cases such as the present one. In Bell Atlantic v. Intercom, 366 Md. 1, 782 A.2d 791 (2001), this Court comprehensively reviewed these statutory provisions and held that the statutorily specified administrative-judicial review remedy was “primary” and that a litigant “may not circumvent” the statutory remedy “by filing an independent judicial action,” Bell Atlantic v. Intercom, swpra, 366 Md. at 25-26, 782 A.2d at 805-806.

Since the statutory administrative-judicial review remedy was primary, rather than exclusive, the Court in Bell Atlantic further held that, when the administrative remedy had been invoked and fully exhausted, and a judicial review action had been filed, the Circuit Court could entertain together the judicial review action and a previously stayed common law tort or breach of contract action. The reason for permitting both actions to be considered together when the administrative-judicial review action was primary, rather than exclusive, is that the litigant may, under the common law actions, be entitled to “remedies beyond the scope of the Commission,” Bell Atlantic, 366 Md. at 28, 782 A.2d at 807. See also, e.g., Maryland Reclamation v. Harford County, 382 Md. 348, 367, 855 A.2d 351, 362 (2004); Kim v. Comptroller, 350 Md. 527, 536-537, 714 A.2d 176, 180 (1998); McCullough v. Wittner, 314 Md. 602, 612-613, 552 A.2d 881, 886 (1989); Md.-Nat’l Cap. P. & P. Comm’n v. Crawford, 307 Md. 1, 18, 511 A.2d 1079, 1087-1088 (1986). Neither Bell Atlantic nor any of the other above-cited opinions, however, held that a separate declaratory judgment action would lie to challenge the administrative decision; no declaratory judgment action was brought in any of these cases.

The Declaratory Judgments Act, in § 3-409(b) of the Courts and Judicial Proceedings Article, unambiguously states as follows:

*35“Special form of remedy provided by statute.—If a statute provides a special form of remedy for a specific type of case, that statutory remedy shall be followed in lieu of a proceeding under this subtitle.”

This Court has consistently held that, where a statutory administrative-judicial review remedy is exclusive or primary, the above-quoted provision in the Declaratory Judgments Act prohibits a declaratory judgment action brought to challenge an adjudicatory administrative decision rendered within the agency’s jurisdiction. Although a common law or other type of statutory action may sometimes be entertained along with the judicial review action when the administrative-judicial review remedy is primary instead of exclusive, a declaratory judgment proceeding may not be brought. The plain language of the statute, as well as the opinions of this Court, make this clear.

For example, in Hartman v. Prince George’s County, 264 Md. 320, 286 A.2d 88 (1972), opponents of an administrative decision, like the petitioners in the present case, attempted to bring a declaratory judgment action challenging the decision. This Court, in an opinion by Chief Judge Hammond, after quoting the language now codified as § 3-409(b) of the Declaratory Judgments Act (then codified as Code (1957, 1971 Repl. VoL), Art. 31A, § 6), stated (264 Md. at 323, 286 A.2d at 89):

“This Court consistently has applied the rule of § 6 that declarations will not be given where £a statute provides a special form of remedy for a specific type of case’ because ‘that form of remedy must be followed.’ See Reiling v. Comptroller, 201 Md. 384, 94 A.2d 261; Tanner v. McKeldin, 202 Md. 569, 97 A.2d 449 (right to vote must be determined as Art. 33 provides and liability to income tax must be determined as the Income Tax Act provides); Albert v. Public Service Commission, 209 Md. 27, 41, 120 A.2d 346....”

Similarly, in Gingell v. Board of County Commissioners for Prince George’s County, 249 Md. 374, 377, 239 A.2d 903, 905 (1968), this Court affirmed the dismissal of a declaratory *36judgment action challenging an adjudicatory administrative decision, saying, inter alia, that

“where a statute provides a specific form of remedy in a specific case then this remedy must be followed. Code (1957), Article 31A, Section 6.... ”

Very recently, this Court unanimously reaffirmed the interpretation of the Declaratory Judgments Act that, where a statute provides a primary administrative-judicial review remedy for a specific type of case, a declaratory judgment action challenging an administrative decision in such a case, rendered within the agency's jurisdiction, is prohibited. Prince George’s County v. Ray’s Used Cars, 398 Md. 632, 922 A.2d 495 (2007), and eases there cited.1 See also, e.g., Fertitta v. Brown, 252 Md. 594, 598, 599-600, 251 A.2d 212, 214, 215 (1969) (“We think this is one of those relatively rare instances of a petition for declaratory relief in which a demurrer properly was filed, as a justified challenge to the availability of the remedy sought to be used [to challenge an administrative decision]. * * * Declaratory Proceedings were not intended to and should not serve as a substitute for appellate review or a belated appeal”); Poe v. Baltimore City, 241 Md. 303, 315-316, 216 A.2d 707, 713-714 (1966) (discussing and applying the provision of the Declaratory Judgments Act precluding an action under that statute where the Legislature has provided a specific form of remedy); Baltimore v. Seabolt, 210 Md. 199, 204, 210, 123 A.2d 207, 209, 212 (1956) (same).2

*37Consequently, although I agree with the Court that this case “is inexorably linked” to the judicial review action because both actions are challenges to the same administrative decision by the Public Service Commission, the decision in this case is not dependent upon or linked to the decision in the judicial review action. In light of § 3-409(b) of the Declaratory Judgments Act, the instant declaratory judgment action will not lie regardless of whether the Public Service Commission’s decision in the judicial review action is upheld or overturned.

The petitioners rely on the fact that, at the time this action was brought, the judicial review action was no longer pending at the circuit court level. Nevertheless, as numerous opinions by this Court illustrate, the status of the judicial review action is immaterial. It does not matter whether the judicial review action had even been filed, or was pending before the agency, or was pending before a circuit court, or was pending before an appellate court, or had been terminated. What precludes an action under the Declaratory Judgments Act is the fact that the General Assembly has enacted “a special form of remedy for [this] specific type of ease,” § 3-409(b) of the Courts and Judicial Proceedings Article. The existence of the statute providing a special form of remedy, not the status of a case, if any, brought under that statute, is what precludes a declaratory judgment action.

Similarly, it is also immaterial whether the parties in the two actions are the same or are different. Instead, it is the *38provision of a statutory special form of remedy, not who happens to invoke that remedy, which takes the present case outside of the scope of the Declaratory Judgments Act.3

The same is true regarding the petitioners’ “notice” argument. Although I fully agree with the Court that the notice given by the Public Service Commission met the statutory notice requirement, it is not an issue appropriate for declaratory judgment consideration. Section 3-409(b) simply prohibits a declaratory judgment action. If, in some other case, the notice given by an administrative agency were to violate statutory or constitutional requirements, and an aggrieved person were prejudiced by the lack of notice and unable, because of such insufficient notice, to appear before the agency, a common law mandamus action might well lie to require that administrative officials comply with the law. Cf. Murrell v. Baltimore, 376 Md. 170, 192-199, 829 A.2d 548, 561-565 (2003); Gisriel v. Ocean City Board of Supervisors of Elections, 345 Md. 477, 497-500, 693 A.2d 757, 767 (1997), and cases there cited. An action under the Declaratory Judgments Act, however, does not lie.

Judges RAKER and HARRELL join this concurring opinion.

. It should be noted that the statutory administrative-judicial review proceedings applicable in the Ray's Used Cars, Hartman, and Gingell cases have not been held to be exclusive. The holding that no action could be brought under the Declaratory Judgments Act was deemed applicable regardless of whether the administrative-judicial review proceedings were deemed exclusive or primary. See Prince George's County v. Ray’s Used Cars, supra.

. There are a few "exceptions” to the principle that a declaratory judgment action, challenging an adjudicatory administrative decision made within the agency’s jurisdiction, will not lie. In reality, however, they may not be "exceptions” but may be consistent with the principle. Thus, where the declaratory, judgment challenge is not to the agency's decision within the sphere of its valid jurisdiction, but is directed at the *37legislative validity of the enactment as a whole, which the agency is applying, a declaratory judgment will lie under some circumstances. See, e.g., Montgomery County v. Broadcast Equities, 360 Md. 438, 452-461, 758 A.2d 995, 1002-1007 (2000); Harbor Island Marina v. Calvert Co. Bd. of Com’rs, 286 Md. 303, 308-309, 407 A.2d 738, 741 (1979); Pressman v. State Tax Commission, 204 Md. 78, 83-84, 102 A.2d 821, 824-825 (1954). Also, when an agency ultimately decides that it has no jurisdiction over a particular type of case, and that decision is not reversed upon judicial review, a stayed declaratory judgment action involving the controversy may proceed in court. State v. State Board of Contract Appeals, 364 Md. 446, 458-459, 773 A.2d 504, 511-512 (2001). The case at bar falls within no "exceptions” to § 3-409(b) of the Declaratory Judgments Act.

. It is conceivable, I suppose, that one aggrieved by administrative action may have standing to challenge that action in court, but, because of a peculiar and limiting statute relating to standing before the agency, would not have standing to appear at the adjudicatory administrative proceedings. Under such circumstances, the person may be entitled to bring a common law or equitable action in court challenging the administrative decision. Such person could not, however, bring a declaratory judgment action.