CONSTITUTIONAL LAW - WRIGHT V. CITY OF MOBILE

Wright v. City of Mobile, [Ms. 2130156, Oct. 24, 2014] __ So. 3d __ (Ala. Civ. App. 2014). An administrative tribunal hearing a personnel matter cannot address constitutional issues. An appeal to circuit court from a ruling of that tribunal presents only limited issues, not including any constitutional issues. The Alabama Administrative Procedure Act gives broader authority to agencies, but it does not apply to counties, municipalities, or any agencies of local government. Instead, constitutional issues relating to administrative proceedings outside the scope of the AAPA can be raised only in a subsequent, independent proceeding. Thus, Wright's due-process challenges to the order suspending her from the City of Mobile Police Department presented nothing for review. The Court also rejected her argument that the City did not comply with the pertinent local rule.