Maryland State Police v. Zeigler

ROBERT M. BELL, Judge,

dissenting.

This case presents two questions: (1) whether, in reopening the case,1 after deliberations have begun, to take additional testimony, the administrative agency abused its discretion and (2) whether the procedure followed by the *564agency in taking that additional testimony comported with the dictates of due process. These are separate and distinct inquiries. An affirmative answer to the former, in my opinion, is dispositive, requiring reversal of the administrative agency’s decision. Only a negative answer to the first question will make necessary consideration of the latter.

The Court of Special Appeals articulated two reasons for affirming the judgment of the Circuit Court for Baltimore County, which reversed the decision of the hearing board. First, it held that it was an abuse of discretion for the hearing board to take additional testimony after it had begun its deliberations. As to that basis, analogizing the situation to that of a court reopening a case for the purpose of taking additional testimony after the jury had begun its deliberations and, noting that “[h]ad the fact-finding body in a criminal or civil case reopened for more evidence on the grounds that this case was reopened, it would have equalled an abuse of discretion, as indicated by the relevant persuasive authority,” Maryland State Police v. Zeigler, 85 Md. App. 272, 280, 583 A.2d 1085, 1089 (1991),2 the intermediate appellate court characterized the actions of the hearing board as a “violation of its fairness obligation, constituting an abuse of discretion.” Id. The court also expressed concern that administrative proceedings, like trial proceedings, be finally resolved and that undue emphasis not be given to new evidence offered for the first time after the case has concluded and deliberations have begun. In that regard, the court noted that the hearing board consisted of lay persons, rather than judges, opining that the latter presumably could have placed the new evidence in the proper perspective. Id. at 281, 583 A.2d at 1090.

As to its alternate holding, the Court of Special Appeals was of the view that taking additional testimony after deliberating for more than three hours indicated that the hearing board believed the evidence before it was insuffi*565cient to convict the respondent and, hence, additional evidence was needed. The court noted that where that is the case, the proponent of the issue having failed to meet its burden, due process and fundamental fairness is violated. It concluded, therefore, that the process that was accorded the respondent in this case “deviated from ‘previously declared rules’ for adjudicating similar claims.” Id. at 284, 583 A.2d at 1091.

The majority sees it quite differently. It says that, “considering all of the circumstances, the board’s decision to reopen the hearing was clearly not arbitrary or capricious.” Op. at 559. To reach that conclusion, it rejects, as unsound, the analogy to the reopening of the trial during jury deliberations. As to that, it says, while certainly no less broad, “[t]he discretion of an administrative agency to admit evidence after the hearing is arguably broader than the discretion that is generally accorded trial judges, since one of the reasons given for the wide discretion of an agency to admit post-hearing evidence is that ‘administrative agencies are not generally bound by the ... common-law rules of evidence.’ ” Op. at 557 (citations omitted). The majority relies on administrative law cases in which the agency considered documentary evidence, filed in supplementation of the record after the hearing had concluded, but before the agency rendered its decision. Schultz v. Pritts, 291 Md. 1, 7-10, 432 A.2d 1319 (1981); Montgomery Co. v. Supervisor, 275 Md. 58, 62-63, 337 A.2d 679, 681 (1975); Montgomery Co. v. Nat’l Capital Realty, 267 Md. 364, 375-76, 297 A.2d 675, 681-82 (1972); Dal Maso v. Bd. of County Comm’rs, 238 Md. 333, 337, 209 A.2d 62, 65 (1965); Temmink v. Bd. of Zoning Appeals, 205 Md. 489, 497, 109 A.2d 85, 88-89 (1954); Tidewater Express Lines, Inc. v. U.S., 278 F.Supp. 561, 566-67 (D.Md.1968).3 Conse*566quently, the majority finds unpersuasive the reasons given by the Court of Special Appeals for concluding that the board’s reopening of the hearing to take additional testimony was an abuse of its discretion. That the board was composed of lay persons, and not judges, the majority asserts, is an insufficient basis for holding that the agency’s discretion to reopen a hearing is more limited after deliberations had begun, than before. Nor is the majority troubled by the reasons the board gave for reopening the hearing. Rejecting the argument and holding that they were inadequate, it is persuaded by the fact that “[t]he board said nothing to justify a conclusion that its desire for additional evidence was unreasonable.” Op. at 559.

The majority also rejects the Court of Special Appeals’s conclusion that due process had been denied the respondent. First, it notes that the proper inquiry, for due process purposes, is whether the procedure followed in the taking of additional testimony allowed the respondent a full opportunity to cross-examine and rebut the new evidence. Second, the majority finds no support in the record for the intermediate appellate court’s conclusion that the desire for additional evidence was the product of the board’s attempt to cure a perceived insufficiency of the evidence.

I will not quarrel with the majority’s conclusion that the extent of an administrative agency’s discretion to reopen a *567hearing after deliberations have begun may not be coextensive with that of a trial court and, indeed, may be broader. Nor am I troubled, in this case, by the majority’s due process analysis, whether or not it is sound. I am persuaded, however, that the Court of Special Appeals correctly held that the board abused its discretion when it reopened the case to take additional evidence. An administrative agency acts arbitrarily and capriciously when sufficient bases for the reopening are not apparent on the record; no such bases are apparent on this record. Even though the analogy between administrative and judicial proceedings is not perfect, unlike the majority, I think it is permissible to review cases involving the exercise of judicial discretion to decide the present case.

Recently, in Dyson v. State, 328 Md. 490, 615 A.2d 1182 (1992), we considered the propriety of a trial judge allowing the introduction of evidence after the jury had begun its deliberations. After conducting a detailed survey of cases from across the country which have addressed the subject, our conclusion was that “the majority of courts considering this issue have concluded ... that the interest of justice requires that the trial judge be given some discretion to permit receipt of additional evidence after jury deliberations have begun, but that this discretion is significantly limited and should be exercised with great caution.” Id. at 500, 615 A.2d at 1187. Expanding on that theme, we said:

We agree that a trial judge must exercise the utmost caution in reopening a case to allow the introduction of additional evidence after a jury has begun deliberating. As the Court of Appeals of New York[4] pointed out, the presentation of evidence must come to an end at some time, and the parties must be forewarned that the desirability of maintaining an orderly trial process militates strongly against receiving evidence at that stage of the trial. A premium must necessarily be placed on preparation and diligence, and evidence which is simply the *568product of an afterthought, no matter how pertinent it may have been if timely offered, will not, except in the most extraordinary circumstances, be received at this late stage of the proceedings. There is, of course, the very strong probability that evidence offered at this point will be given undue emphasis in prominence by the trier of fact. Moreover, if the evidence is at all disputed or controversial, fair opportunity must be afforded for cross-examination and rebuttal. And it may be difficult, if not impossible, to permit effective argument concerning additional evidence without permitting an entire set of new closing arguments.
There will, of course be those rare circumstances where this extraordinary relief should be granted. Where, for example a party has painstakingly laid a proper foundation for the introduction of an exhibit and all parties have assumed it is in evidence, but because of an oversight it was not formally offered and received, a trial judge would not err in receiving the exhibit and sending it to the jury. Or, as the Supreme Court of New Jersey speculated in State v. Wolf, [44 N.J. 176, 207 A.2d 670] at 677 [(1965)]:
Suppose while the jury was deliberating, the prosecutor returned to court with a third person who had just confessed to the shooting, and with some reputable eye witness to the killing who identified such person as the perpetrator, could it be said the court was powerless to reopen the defense and permit the jury to hear the new testimony?

328 Md. at 502-503, 615 A.2d at 1188. ■ We were impressed by several factors identified by the Supreme Court of Appeals of West Virginia as valid considerations in guiding a trial judge’s exercise of discretion in this regard:

Whether good cause is shown; whether the new evidence is significant; whether the jury would be likely to give undue emphasis, prejudicing the party against whom it is offered; whether the evidence is controversial in nature; *569and, whether the reopening is at the request of the jury or a party.

328 Md. at 502, 615 A.2d at 1188, citing State v. Thomas, 179 W.Va. 811, 374 S.E.2d 719, 722 (1988).

As the majority points out, an administrative agency abuses its discretion, in the context of an adjudicatory hearing,5 when it acts arbitrarily and capriciously. Dept. of Natural Resources v. Linchester, 274 Md. 211, 224, 334 A.2d 514, 525 (1975); Criminal Injuries Compensation Bd. v. Gould, 273 Md. 486, 501, 331 A.2d 55, 65-66 (1975). See also Maryland Code (1984) § 10-215(g)(3)(vi) of the State Government Article.6 An action is arbitrary and capricious when it is based upon whim or caprice, i.e., when the agency decision is unsupported by any evidence, see Ins. Comm’r v. Nat’l Bureau, 248 Md. 292, 300-301, 236 A.2d 282, 286 (1967); Johnstown Coal & Coke Co. v. Dishong, 198 Md. 467, 474, 84 A.2d 847, 850 (1951); Heaps v. Cobb, 185 Md. 372, 379-80, 45 A.2d 73, 76 (1945), or when it has no discernable rational basis. Turner v. Hammond, 270 Md. 41, 55-56, 310 A.2d 543, 551-52 (1973); Montgomery County v. Anastasi, 77 Md.App. 126, 138-39, 549 A.2d 753, 758 (1988). Whether a ruling is unsupported by evidence or is otherwise arbitrary and capricious necessarily depends upon the particular facts of the case under review. Gianforte v. *570License Comm’rs., 190 Md. 492, 499, 58 A.2d 902, 906 (1948).7

Unless the basis upon which the agency acted is reflected in the record, directly or by rational inferences deducible from evidence in the record, the exercise of discretion by the agency cannot be upheld. Indeed, it cannot even be reviewed. This is so because, in that circumstance, the reviewing court could only assess the rationality of the agency’s decision by resorting to blind faith and uncritical acceptance of the agency’s good faith. Generalities, unlike specific reasons directly related to the case at issue, simply are not informative. They are, therefore, insufficient to provide a basis for taking additional evidence.

This is consistent with Maryland administrative law. Judicial review of agency action is conducted on the record made before the agency unless the court orders, § 10-215(e) and (f), or a statute permits, Maryland Rule B10, the taking of testimony to supplement the record. Motor Vehicles Admin, v. Mohler, 318 Md. 219, 233, 567 A.2d 929, 936 (1990); Howard County v. Davidsonville Civic Ass’n, 72 Md.App. 19, 47, 527 A.2d 772, 786, cert. denied, 311 Md. 286, 533 A.2d 1308 (1987); § 10-210; Maryland Rule B7.8

Moreover, because the court reviews the agency’s basis for decision, Blue Bird Cab Co. v. Md. Dept. of Employment Sec., 251 Md. 458, 466, 248 A.2d 331, 335 (1968); see also Baker v. Bd. of Trustees, 269 Md. 740, 747, 309 A.2d 768, 771-72 (1973), in addition to being in writing or stated in the record, § 10-214(a), an agency decision must meet *571minimum reporting requirements. Hammond, 270 Md. at 55-56, 310 A.2d at 551; Pistoria v. Zoning Board, 268 Md. 558, 570, 302 A.2d 614, 619 (1973); Adams v. Bd. of Trustees, 215 Md. 188, 195, 137 A.2d 151, 155 (1957); Heaps, 185 Md. at 379-80, 45 A.2d at 76; Inst. of Mission Helpers et al. v. Beasley, 82 Md.App. 155, 164, 570 A.2d 382, 386 (1990); Ocean Hideaway Condominium Ass’n v. Boardwalk Plaza Venture, 68 Md.App. 650, 658, 515 A.2d 485, 488 (1986). See § 10-214 which provides:

(b) Contents. — (1) A final decision in a contested case shall contain separate statements of:
(i) the findings of fact; and
(ii) the conclusions of law.
(2) If the findings of fact are stated in statutory language, the final decision shall state concisely and explicitly the facts that support the findings.
(3) If in accordance with regulations, a party submitted proposed findings of fact, the final decision shall state a ruling on each proposed finding.

The obvious purpose of such requirements is to facilitate judicial review.

None of these provisions refers to the exercise of discretion as occurred in the case sub judice, it may be observed. That is true, but it is also not dispositive. Ordinarily an agency exercises discretion at the behest, and to the benefit, of a party to the proceedings. Thus, when one of the parties requests the agency to reopen its case, between the proponent’s motion and the proponent’s opposition, the record ordinarily will reflect the reasons the proponent made the motion, the issue prompting it, and the reasons for the opposition. From these sources, simply by referring to the parties’ arguments, the propriety of the exercise of discretion can be assessed. In other words, in those cases, the reason for the agency’s exercise of discretion is apparent in the record.

The situation is critically different when it is the agency, rather than one of the parties, that is the moving force *572behind the exercise of discretion. Unless the agency puts on the record, as would occur if a party was the movant, the issue with which it is concerned, the competing considerations bearing on that issue, or, after informing them of the issue, allows the parties to do so, the record will reflect only that the agency desires to reopen the proceedings. In that case, the reasons underlying the agency’s decision will not be, and, indeed, could never be, apparent on the record.

To be sure, an agency’s exercise of discretion is, and must be, reviewable. And it is reviewable on the record made before the agency; “decision,” as used in § 10-215(g), is sufficiently broad to encompass the exercise of discretion. See Bd. ofEduc. v. Allender, 206 Md. 466, 475-77, 112 A.2d 455, 459 (1955) (where the agency was charged with obtaining the low bid for a contract and the record reflected that the company to whom the contract was awarded was the lowest bidder, there was no abuse of discretion in the award of the contract to that bidder despite its failure strictly to comply with the bidding specifications); Balto. Import Co. v. Md. Port Auth., 258 Md. 335, 342-44, 265 A.2d 866, 869 (1970) (“[T]he facts alleged ..., if supported by competent evidence, and not justified by the Authority, might well establish a course of conduct so repugnant to fair dealing as to entitle the petitioner to relief.”).

The Court of Special Appeals recognized, I think correctly, that the record does not support, either directly or by inference, the reopening in this case. It characterized the board’s exercise of discretion as unfair, thereby branding it as arbitrary and capricious; it was simply another way of saying that the taking of additional testimony without any apparent, or even discernable, rational basis therefor is not permissible.

After three and a half hours of deliberations, the hearing board decided, unanimously, to call additional witnesses. It explained:

Gentlemen, we have been in deliberation for some time now. We have spent our time reviewing the evidence and *573testimony that has been given so far in this case. It is the opinion of this board, of each member of this board, that there are additional witnesses who have not been called to this hearing who have evidence or testimony to give which is pertinent to this matter. We feel that it is in the best interest of the defendant and the agency, and in the best interest of fairness for the board to call additional witnesses to this hearing.

The respondent’s objection having been overruled and his motion for reconsideration denied, the chairman of the board, by way of further explanation, stated:

The board has discussed the argument put forth by [the respondent’s counsel] [Counsel], I assure you this board is interested in fairness and the perception of fairness. That is the only reason that we adjourned back on September 23rd and decided to call additional witnesses. We are concerned with the fairness, and if [the respondent] Zeigler walks out of here today, that he be — have been given a fair and impartial trial, and the verdict be one that can be viewed as fair and impartial by anyone who views it, particularly [the respondent].
* * * * S)< *
As the board goes, we realize that we are going to decide this case on the facts that have been presented to it. We realize that we do have a job to determine whether the charges should be sustained or not, and most importantly, we have the responsibility to be fair. We are not here to uphold the Maryland State Police, its charges, or what it, or anyone else, wants done, or what the prosecution wants done. We are here to come to a fair determination of the charges that have been placed against [the respondent] Zeigler, irrespective of all the other things that may go on, or any summary issues surrounding the incident.

Neither of these statements is enlightening. They do not explain why the hearing had to be reopened. Not only do they fail to reveal precisely what the board expected the *574additional evidence to show, they do not address at what the additional evidence was directed or why it was so critical as to require reopening of the case. All the statements do is make clear that the board, the trier of facts, wanted to hear additional evidence from specific witnesses, before it decided the case. Without, however, any indication of what that evidence would be or on what issue or issues it would have relevance, neither the significance of that additional evidence nor the propriety of obtaining it, ie., whether there was good cause for it, can be ascertained. Indeed it is probably fair to say that, since it is the board that is both judge and jury, only the board knows.

The board, to be sure, makes a great to do about its duty to be fair, committing, presumably, to discharge that duty without fear or favor. No matter how well intentioned the board may have been, and I don’t question its intention, the statement of its good intentions leaves the parties and a reviewing court without a clue as to what it was about the evidence the board had before it that made it unfair, to the respondent, the State Police, or both, for the case to be decided on that evidence alone. Moreover, invoking fairness, but not explaining what specifically was unfair or the relevance of the additional testimony to that consideration, or its perception, about which the board expressed concern, falls woefully short of providing an adequate record on the basis of which the reopening can be upheld. I repeat, general statements about fairness, and even the board’s good intentions, without more, do not provide sufficient information even to permit a reviewing court adequately to review the board’s exercise of discretion, not to mention uphold it.

The factors which militate against allowing “willy nilly,” the reopening of the trial at the whim of the trial judge also militate against permitting an administrative agency, at its whim, ie., for no good reason or, at least, none that is stated or apparent, from doing so in an administrative *575context.9 It is important that administrative proceedings, like trials, come to an end at some point (it is likewise desirable that administrative bodies be encouraged to be decisive) and that the parties to those proceedings be aware that the process is orderly and certain. Moreover, it is no less important in the administrative, than in the judicial, context that competence, not afterthought, be the preferred standard. More important, however, are two of the factors found significant by the Supreme Court of West Virginia, whether sufficient good cause has been shown to permit the taking of additional evidence and whether that evidence is significant, neither of which have been met here. Because we are not privy to the issue prompting the reopening or specifically what the additional evidence is, we cannot determine if the additional evidence is significant or needed.

Focusing on one of the reasons given by the Court of Special Appeals for finding an abuse of discretion and finding it lacking, the majority concludes that there was no abuse of discretion, observing, “the Board said nothing to justify a conclusion that its desire for additional evidence was unreasonable.” Although it acknowledges, as it must, that the Board did no more than indicate its concern with fairness to the respondent, its responsibilities, and its ability to reach a fair decision on all of the charges, the majority undertakes no additional analysis to test whether those stated reasons were enough affirmatively to demonstrate the absence of arbitrariness. At no point does the majority, as far as the record reveals, consider whether the board’s “reasons” are sufficient, in themselves, to indícate a ration*576al, hence, valid, exercise of discretion. Adopting the majority’s reasoning, it seems inevitable that, whenever an administrative agency allows additional testimony after deliberations have begun, the decision whether it abused its discretion in doing so will be solely that of the agency; because it need not reveal specifically why it believes additional testimony is necessary, judicial review is effectively foreclosed. So long as the agency follows the formula endorsed by the majority, i.e., invokes its commitment to fairness, especially to the defendant, stresses its intent to render a fair decision, and avoids saying anything “to justify a conclusion that its desire for additional evidence was unreasonable,” it may reopen any hearing for any or no reason, without fear either of meaningful review or reversal. Even though administrative agencies generally are not bound by “common-law. rules of evidence,” Mont. Co. v. Nat’l Capital Realty, 267 Md. at 376, 297 A.2d at 681-82, permitting on that basis such a result is absurd.

. It is not at all clear from this record whether what was reopened was the prosecution’s case or the defense’s case. The hearing board specifically did not state whose case was being reopened and there is nothing else in the record that supplies that information.

. The Court of Special Appeals relied most heavily on People v. Olsen, 34 N.Y.2d 349, 357 N.Y.S.2d 487, 313 N.E.2d 782 (1974).

. None of those eases addresses the issue sub judice. In Schultz v. Pritts, 291 Md. 1, 7-10, 432 A.2d 1319 (1981), all parties acquiesced in the submission of the documentary evidence after the close of the hearing. See also Dal Maso v. Bd. of County Comm’rs, 238 Md. 333, 337, 209 A.2d 62, 65 (1965). In Montgomery Co. v. Supervbor, 275 *566Md. 58, 62-63, 337 A.2d 679, 681 (1975), the propriety of permitting intervention, not of reopening the case, was the issue. Indeed, in that case, we recognized, citing the “change of mind” rule, that an administrative agency may not reopen a case without a basis. Id., at 62, 337 A.2d at 681. The thrust of the holding in Mont. Co. v. Nat'l Capital Realty, 267 Md. 364, 375-76, 297 A.2d 675, 681-82 (1972), was that it was not unfair to consider a final draft of a report submitted after the hearing closed, when the preliminary draft of that report, containing the same recommendation, had previously and timely been considered. Although the Court did note that due process procedural guarantees were lacking when the protestants were not afforded the opportunity to challenge the conclusion of a Planning Commission report submitted after the hearing concluded, the issue in Temmink v. Bd. of Zoning Appeals, 205 Md. 489, 497, 109 A.2d 85, 89 (1954), was not the propriety of reopening the zoning hearing to consider that report.

. Olsen, 34 N.Y.2d 349, 357 N.Y.S.2d 487, 313 N.E.2d 782.

. Judicial review of an adjudicatory decision is somewhat broader than of a legislative or quasi-legislative action. Cromwell v. Jackson, 188 Md. 8, 22, 52 A.2d 79, 86 (1947).

. Maryland Code (1984) § 10-215(g)(3)(vi) of the State Government Article provides:

(g) Decision. — In a proceeding under this section, the court may: ******
(3) reverse or modify the decision if any substantial right of the petitioner may have been prejudiced because a finding, conclusion, or decision of the agency:
******
(vi) is arbitrary or capricious.

. The burden is on the proponent of the issue to show that the agency abused its discretion. That does not require that he or she do any more than place the record of the proceedings before the reviewing court and point out the absence of a basis in the record for the action complained about.

. Rule B7.d., providing for a statement in lieu of the record, is instructive. It allows the parties, "with the approval of the agency ... [to] prepare and sign a statement of the case showing how the question arose and was decided, and setting forth so much only of the facts alleged and proved, or sought to be proved, as is essential to a decision of such question by the court.

. It is even more appropriate in this case, involving as it does the Law Enforcement Officers's Bill of Rights, Md.Code (1957, 1992 Repl.Vol.) Art. 27, §§ 727-734D, the purpose of which is to ensure that an accused police officer enjoys certain safeguards. See Moats v. Hagerstown, 324 Md. 519, 526, 597 A.2d 972, 975 (1991); Reed v. Baltimore, 323 Md. 175, 183, 592 A.2d 173, 177 (1991). While not the equivalent of a criminal proceeding, Widomski v. Chief of Police, 41 Md.App. 361, 379, 397 A.2d 222, 232-33 (1979), those safeguards demand that the procedure employed in conduct of the hearing be predictable and regular.