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.
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