Boever v. South Dakota Board of Accountancy

ZINTER, Circuit Judge.

As the result of an “adverse quality review,” the South Dakota Board of Accountancy (Board) commenced an administrative disciplinary proceeding against John W. Boever (Boever), a certified public accountant. After the disciplinary proceeding was concluded, Boever filed a complaint in circuit court challenging the constitutionality of the statutes which authorize quality reviews and the discipline of accountants. Because there was no indication further disciplinary proceedings were anticipated, the circuit court dismissed the complaint concluding that Boever’s…