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2006-11-22_Answering_Brief_re_Calvert
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2006-11-22_Answering_Brief_re_Calvert
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C, <br /> (1) In violation of constitutional or statutory provisions; or <br /> (2) In excess of the statutory authority or jurisdiction of the agency; or <br /> (3) Made upon unlawful procedure; or <br /> (4) Affected by other error or law; or <br /> (5) Clearly erroneous in view of the reliable, probative, and substantial <br /> evidence on the whole record; or <br /> (6) Arbitrary, or capricious, or characterized by abuse of discretion or <br /> clearly unwarranted exercise of discretion." <br /> The Hawaii Supreme Court has interpreted HRS Section 91-14(g) as follows: <br /> In order to preserve the function of administrative agencies in <br /> discharging their delegated duties and the function of this court <br /> in reviewing agency determinations, a presumption of validity is <br /> accorded to decisions of administrative bodies acting within their <br /> sphere of expertise and one seeking to upset the order bears "the <br /> heavy burden of making a convincing showing that it is invalid <br /> because it is unjust and unreasonable in its consequences." <br /> (Citations omitted.) In re Hawai`i Electric Light Co., 60 Haw. 625, <br /> 630, 594 P.2d 612 (1979). <br /> Therefore, in determining whether the standard of overturning the decision of the Board <br /> has been met, the Board is entitled to a presumption of validity. <br /> The Hawaii Supreme Court has elaborated on the standard by stating that the Findings of <br /> Fact("FOP) of a board will be reviewed under the clearly erroneous standard. Curtis v. Board <br /> of Appeals of the County of Hawai`i, 90 Hawaii 384, 393, 978 P.2d 822 (1999). Under this <br /> standard, the court considers whether the finding is clearly erroneous in view of the reliable, <br /> probative, and substantial evidence on the whole record. A reviewing court will not disturb <br /> agency findings unless it is left with a"definite and firm conviction that a mistake has been <br /> made." Aio v. Hamada, 66 Haw. 401, 406, 664 P.2d 727, 731 (1983). <br /> An agency's Conclusions of Law ("COL") are freely reviewable to determine if the <br /> agency's decision was in violation of constitutional or statutory provisions, in excess of statutory <br /> authority or jurisdiction of agency or affected by other error of law. Curtis, supra. The <br /> 3 <br />
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