Richards v. Young

I do not join the majority opinion because it does not comport with the plain language or legislative purpose of the statutes.

Sections 227.40(5) and 806.04(11) provide that the Joint Committee for Review of Administrative Rules (JCRAR) must be served in specified declaratory judgment actions. JCRAR apparently was served in this case. The statutes are silent regarding the time of service. Both statutes explicitly provide that JCRAR does not become a party to the action until after the approval of the Joint Committee on Legislative Organization (JCLO).1 Thus the statutes do not require JCRAR to…