Idaho State Athletic Commission v. Office of the Administrative Rules Coordinator
Annotate this CaseIn this case, the Idaho State Athletic Commission and the Idaho Division of Occupational and Professional Licenses sought a declaratory ruling that provisions of the Idaho Administrative Procedure Act (APA) requiring legislative approval of pending administrative fee rules violated the Idaho Constitution. They also sought a Writ of Mandamus directing the Office of the Administrative Rules Coordinator to publish the Athletic Commission’s 2022 administrative rules in the Idaho Administrative Code. The Idaho Supreme Court held that it had jurisdiction to consider the case, but dismissed the petition for a declaration of unconstitutionality and denied the petition for a Writ of Mandamus. The court concluded that the APA requirement for legislative approval of pending administrative rules did not violate the Idaho Constitution's separation of powers, enactment, presentment, or administrative rules provisions. In reaching this conclusion, the court emphasized that administrative rulemaking authority was a legislative delegation, not a constitutional power, and that the legislature was free to modify the process by which administrative rules were enacted.
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