Gloucester Cty. Welfare Bd. v. NJ CIV. SERV. COMM'N.

HANDLER, J.,

dissenting.

Gail Denton, the recipient of a law degree, was provisionally appointed Deputy Director of Welfare in Gloucester County and sought to compete for permanent appointment in an open examination to be given by the Department of Civil Service. The educational requirement for the position contained in the Department’s Notice of Examination was “a Master’s Degree in social work or social welfare or public administration or business administration from an accredited college or university....” Denton’s timely application for the open examination was rejected by the Department because she was “below minimum requirements in education.”

Denton sought to reverse this determination through the administrative appeals process, arguing that her law degree was “equivalent or superior to the masters degrees listed” and noting that much of her law school curriculum related to social work, public administration and business. She contended that

the basis for the qualifications is to ensure that candidates for the position are educationally prepared. I don’t believe that there could be a question as to whether I was educationally prepared to be Deputy Director, especially if you compare the curriculum for the Masters degrees listed with my curriculum at law school, and the Civil Service job description for Deputy Director.

After administrative appeals to the Department’s Director and Assistant Director of Examinations were unsuccessful, Den-ton sought relief from the Civil Service Commission, which also rejected her claim. The Commission’s written opinion noted that in other instances “the Civil Service Commission has held *400that the concept of substitution of other than the specified degrees would not be applicable to stated requirements for Welfare Department positions.”1 The Commission found

that the announced educational requirements for the examination at issue present a broad spectrum of academic achievement on a Master’s degree level which would provide necessary background to function in the high level administrative position at issue and makes no provision for substitution of related degrees. Further, these requirements are uniformly administered, being part of the applicable job specification, and were developed in concert with the New Jersey Division of Public Welfare.
The record, as presented, lists several law school courses which appellant contends shows [sic] an equivalence or similarity to those courses which would support a Master’s degree found in the announced requirements. This presentation lacks any substantive penetration of this allegation by way of documentation through course catalogue comparison or appropriate academic corroboration. The Commission in accordance with its prior decisions, as set forth above, finds that Ms. Denton was properly declared ineligible for the instant examination.

In upholding the Commission’s action, the majority of this Court stresses that the Commission’s refusal to accept degrees other than those listed in the examination announcement was a reasonable exercise of its administrative responsibility to ensure the efficiency of the Civil Service. Although I believe that the Commission has the rightful authority to institute a policy restricting the substitution of degrees, the nature of the policy that it has adopted is by no means clear. The Commission’s decision in this matter appears initially to indicate that no substitution of degrees is permitted in Welfare Department *401positions. But it then finds that Denton failed to establish that her law school courses “show[ed] an equivalence or similarity to those courses which would support a Master’s degree found in the announced requirements.” (Emphasis added.) Similarly, the Director of Examinations had found that he “simply d[id] not have authority to accept substitutions which are not specifically allowed in the examination announcement” while the Assistant Director had rejected Denton’s claim because the law degree and the listed master’s degrees were “fundamentally different in approach, preparation and eventual application.” The inference that Denton could have been eligible to compete for this position if she had made a sufficient showing of “equivalence or similarity” runs counter to the Commission’s professed no-substitution rule.

This uncertainty as to the parameters of the agency’s policy is aggravated by the apparent conflict between an absolute prohibition on the substitution of degrees and the Commission’s own regulations governing examinations. N.J.A.C. 4:1-8.1 et seq. Under the Commission’s rules, the educational requirements announced in the Notice of Examination are the “established minimum qualifications requirements....” N.J.A.C. 4:1-8.-3(c)(4) (emphasis added). If the master’s degrees listed in the examination announcement represent minimum qualifications, the Commission is obligated to determine whether Denton’s law degree meets or exceeds this minimum. An absolute no-substitution policy would contravene the intent of this regulation because applicants whose educational qualifications equalled or exceeded the minimum qualifications would be excluded from competing in open examinations.

It is difficult for this Court to resolve the ambiguity as to the nature of the substitution policy established by the Commission in the adjudicatory process and its interrelationship with the agency’s regulations. Because a broad range of practices represent permissible exercises of the agency’s discretion, the confusion and conflict is best resolved on remand to the agency. Cf. Dougherty v. Human Serv. Dep’t, 91 N.J. 1, 12 (1982) *402(remanded for agency to determine whether waiver of a regulation in plaintiff’s case served purpose of statute); Texter v. Human Serv. Dep’t, 88 N.J. 376 (1982) (remand for agency to consider amending income eligibility standards). On remand, the agency in a proper exercise of its authority would resolve the conflict by clarifying its policy and by providing Denton a fair opportunity to demonstrate that her law degree fell within the permissible range of degrees that would satisfy the educational requirement under this clarified policy. Because the majority upholds the determination of the Commission without a remand, I dissent from the opinion of the Court.

For reversal — Chief Justice WILENTZ and Justices CLIFFORD, SCHREIBER and GARIBALDI — 4.

For remandment — Justices POLLOCK, HANDLER and O’HERN — 3.

The Commission cited four of its prior decisions as precedents for a no-degree substitution rule. Two of these decisions involved candidates who failed to satisfy the minimum requirement for prior relevant experience; these decisions do not directly address the degree substitution question. In the other two cases, the Commission refused to permit individuals with Bachelor’s degrees to be promoted to positions that required Master’s degrees. In the Matter of Allen, PC 23 (October 7, 1980), aff’d on other grounds, sub nom. Mercer Cty. Welfare Bd. v. Civil Serv. Comm’n, No. A-1201-80-T4 (App.Div. filed October 5, 1981); In the Matter of Dietrich and Chrizanowski, PC 3605B and PC 3606B (July 28, 1981). Because these individuals had only Bachelor’s degrees, they were unable to claim that their degrees met the minimum requirements. Instead, they unsuccessfully sought a waiver of the educational requirement, not a substitution of an equivalent or similar degree for the required degree.