Legacy Foundation Action v. Citizens Clean Election

Summary

The court held that a party may collaterally challenge an administrative order for lack of subject matter jurisdiction because an order entered without jurisdiction is void. Although an agency may initially determine its own jurisdiction and that determination may ordinarily become final, issue preclusion did not apply here because the Commission acted as both advocate and adjudicator, depriving Legacy of a neutral and full adjudication. The court vacated the court of appeals’ decision, reversed the superior court, and remanded for an independent jurisdictional determination.