Wednesday, October 28, 2015

admin. law - agency interpretation of statute - level of deference

Lancaster County v. PLRB – Pa. Supreme Court – October 27, 2015
To the extent the issues before us concern statutory interpretation, i.e., a legal standard, we note:
[A]n administrative agency’s interpretation [of a statute] is be to given
‘controlling weight unless clearly erroneous.’ However, when an
administrative agency’s interpretation is inconsistent with the statute itself,
or when the statute is unambiguous, such administrative interpretation
carries little weight. Appreciating the competence and knowledge an
agency possess in its relevant field, our Court [has] opined that an appellate
court ‘will not lightly substitute its judgment for that of a body selected for its
expertise whose experience and expertise make it better qualified than a
court of law to weigh facts within its field.’ Moreover, we have emphasized
that this high level of deference is especially significant in the complex area
of labor relations.  Lancaster County v. PLRB, ___ Pa. ___, 94 A.3d 979, 986 (2014) (quotations and
citations omitted).
Although the Board’s interpretation of the statute is consistent with [the statute], and  thus should be given due deference, the Commonwealth Court effectively substituted, without justification, its own judgment [over that of the agency] .  See Lancaster County, ___ Pa. at ___, 94 A.3d at 986.  The Commonwealth Court’s holding. . . contravenes the plain language of [the statute] , and since there is no indication the Board’s interpretation is clearly erroneous, it should be given controlling weight. See id.
If the case is old, the link may have become stale and may not work, but you can use the case and date to find the opinion in another source (e.g., Westlaw, Lexis, Google Scholar)