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City of Soldotna v. State

ADMINISTRATIVE LAW
Supreme Court of Alaska (2024)
Ryan Ciemny

In City of Soldotna v. State, 2024 WL 4312593 (Alaska Sept. 27, 2024), the supreme court held that it is within the Local Boundary Commission’s (the Commission) statutory authority to convert an annexation petition and subject it to local vote instead of legislative review if the Commission has a reasonable basis. (Id. at 1, 9). The City of Soldotna sought to expand its boundaries by annexing adjacent land and submitted an annexation petition to the Commission. (Id. at 1–2). During the public comment period and public hearing, it became clear that the public was largely opposed to the annexation. (Id. at 2). As a result, the Commission converted the petition from one subject to legislative review into a local action in accordance with its authority granted by 3 Alaska Admin. Code § 110.610(a). (Id. at 3). On appeal, Soldotna argued that the Commission’s decision was irrational because it was contrary to the best interest of the state. (Id. at 2). Soldotna also argued that the Commission exceeded its authority in adopting § 110.610(a) because it lacks standards or procedures for when a petition can be converted. (Id. at 3). The supreme court affirmed the lower court’s decision, reasoning that the legislature specifically granted discretionary authority to the Commission to establish procedures whereby boundaries may be adjusted by local action. (Id. at 4). The Court also reasoned that § 110.610(a) provides a sufficient standard by requiring that the Commission determine if the “balanced best interests of the locality and state are enhanced by local participation.” (Id. at 6). The Court concluded that the Commission underwent a significant review process in determining if annexation was appropriate and in light of the negative public response to the annexation, the Commission had a reasonable basis for converting the petition to a local vote. (Id. at 7–9). Affirming the lower court’s decision, the supreme court held that it is within the Local Boundary Commission’s (Commission) statutory authority to convert an annexation petition and subject it to local vote instead of legislative review if the Commission has a reasonable basis. (Id. at 1, 9).

City of Soldotna v. State

ADMINISTRATIVE LAW
Supreme Court of Alaska (2024)
Ryan Ciemny

In City of Soldotna v. State, 2024 WL 4312593 (Alaska Sept. 27, 2024), the supreme court held that it is within the Local Boundary Commission’s (the Commission) statutory authority to convert an annexation petition and subject it to local vote instead of legislative review if the Commission has a reasonable basis. (Id. at 1, 9). The City of Soldotna sought to expand its boundaries by annexing adjacent land and submitted an annexation petition to the Commission. (Id. at 1–2). During the public comment period and public hearing, it became clear that the public was largely opposed to the annexation. (Id. at 2). As a result, the Commission converted the petition from one subject to legislative review into a local action in accordance with its authority granted by 3 Alaska Admin. Code § 110.610(a). (Id. at 3). On appeal, Soldotna argued that the Commission’s decision was irrational because it was contrary to the best interest of the state. (Id. at 2). Soldotna also argued that the Commission exceeded its authority in adopting § 110.610(a) because it lacks standards or procedures for when a petition can be converted. (Id. at 3). The supreme court affirmed the lower court’s decision, reasoning that the legislature specifically granted discretionary authority to the Commission to establish procedures whereby boundaries may be adjusted by local action. (Id. at 4). The Court also reasoned that § 110.610(a) provides a sufficient standard by requiring that the Commission determine if the “balanced best interests of the locality and state are enhanced by local participation.” (Id. at 6). The Court concluded that the Commission underwent a significant review process in determining if annexation was appropriate and in light of the negative public response to the annexation, the Commission had a reasonable basis for converting the petition to a local vote. (Id. at 7–9). Affirming the lower court’s decision, the supreme court held that it is within the Local Boundary Commission’s (Commission) statutory authority to convert an annexation petition and subject it to local vote instead of legislative review if the Commission has a reasonable basis. (Id. at 1, 9).