In Alaska Public Offices Commission v. Not Tammie, 482 P.3d 386 (Alaska 2021), the supreme court held that (1) the governor must explicitly, not implicitly, assign Alaska Public Offices Commission (APOC) hearing officers, and (2) the governor-appointed hearing officer may be an agency employee or commissioner. (Id. at 388–89). During an APOC enforcement action, APOC’s chairperson sat on the panel and acted as the panel’s hearing officer. (Id. at 387). The superior court ruled that it had been improper for the chairperson to act as the hearing officer because the governor had not appointed the APOC chairperson as hearing officer, and that the hearing officer could not be connected with APOC. (Id. at 387–88). APOC appealed, arguing that the governor may implicitly assign a hearing officer by appointing an otherwise-qualified person to serve on a quasi-judicial body, and therefore APOC could have a commissioner serve as the panel’s hearing officer without further input from the governor. (Id. at 388). The supreme court affirmed the lower court’s holding that the governor must explicitly assign APOC hearing officers, and that the governor’s appointment of an individual to a quasi-judicial body such as the APOC was not sufficient as an implicit appointment. (Id. at 388–89). However, the supreme court reversed the lower court regarding whether the governor-appointed hearing officer could be an agency employee or commissioner, holding that hearing officers could be APOC commissioners as long as they remained impartial. (Id. at 389). Affirming in part and reversing in part the lower court’s decision, the supreme court held that (1) the governor must explicitly, not implicitly, assign APOC hearing officers, and (2) the governor-appointed hearing officer may be an agency employee or commissioner. (Id. at 388–89).