R.W. Docks & Slips v. Department of Natural Resources

R.W. Docks & Slips, a marine developer, sought permission from the Department of Natural Resources (DNR) to dredge materials from the bed of Lake Superior under sec. 30.20, Stats., which authorizes the department to enter into contracts with private individuals for the removal of materials from lakebeds. After an investigation, but without a hearing, the department denied the permit and Docks sought judicial review. The trial court concluded that it could not conduct a "meaningful review” of the department’s decision in the absence of an evidentiary record, and, without reaching the merits of…