Maryland State Police v. Zeigler

This case presents two questions: (1) whether, in reopening the case,1 after deliberations have begun, to take additional testimony, the administrative agency abused its discretion and (2) whether the procedure followed by the *564agency in taking that additional testimony comported with the dictates of due process. These are separate and distinct inquiries. An affirmative answer to the former, in my opinion, is dispositive, requiring reversal of the administrative agency’s decision. Only a negative answer to the first question will make necessary consideration of the latter.

The Court of Special…