Newkirk v. Bigard

JUSTICE HARRISON,

dissenting in part:

In my view, the December 11, 1980, order of the Mining Board was void ah initio, and the circuit court erred in dismissing counts I and III of the Newkirks’ complaint. Administrative agencies such as the Mining Board have no general or common law powers; rather, their authority is strictly limited to that conferred by the statutes creating them. (City of Chicago v. Fair Employment Practices Com. (1976), 65 Ill. 2d 108, 113, 357 N.E.2d 1154.) When an order of an agency exceeds this statutory authority, it is void. 65 Ill. 2d 108, 112.

Here, the statute governing the board’s actions dictates that integration orders “prescribe the time and manner in which all the owners in the drilling unit may elect to participate therein.” (Ill. Rev. Stat. 1981, ch. 961/2, par. 5436(d).) Nothing in that statute grants to the board the authority to simply declare, as it did here, that a given landowner must participate in a drilling unit without having first had the opportunity to decide whether he wishes to do so. Thus, since the order of December 11, 1980, was one which the board had no statutory power to make, the dismissal of counts I and III of the Newkirks’ complaint was improper.