Coats v. State, 334 Or. 587

Summary

The Supreme Court of Oregon held that a circuit court had jurisdiction to adjudicate the parties’ breach-of-contract claims but lacked jurisdiction to review the validity of administrative rules incorporated into the contract. Because the validity of the rules was not necessary to resolve the contract dispute, the court concluded that the exception recognized in Hay v. Department of Transportation did not apply. The court vacated the Court of Appeals’ decision and remanded for consideration of whether the incorporated rule, construed as a contract term, excluded the quarry workers and truck drivers from prevailing-wage requirements.

Holdings

1. The circuit court lacked jurisdiction to review the validity of BOLI's rules, either facially or as applied to Coats, because the Oregon Administrative Procedure Act did not authorize circuit-court review in the circumstances presented and the Hay exception did not apply.
2. The circuit court had jurisdiction to adjudicate the parties' breach-of-contract claims even though it lacked jurisdiction over the rule challenge.

Questions Presented

1. Whether a circuit court had subject-matter jurisdiction to review the validity of BOLI rules incorporated into a public-works contract.
2. Whether the validity of those rules was placed at issue in a separate breach-of-contract action under the exception recognized in Hay v. Department of Transportation.
3. Whether the circuit court had jurisdiction over the parties' remaining contractual dispute and whether the quarry qualified under the contractual exception for a permanent, previously established facility.

Disposition

vacated