Tetra Tech EC, Inc. v. Wisconsin Department of Revenue

ANNETTE KINGSLAND ZIEGLER, J. (concurring).

*591¶135 I agree with the result the court reaches. I concur and write separately because the analysis that the lead opinion employs to reach its conclusions is concerning. First, in my view, it is both unnecessary and inadvisable to rely on constitutional grounds for ending our practice of deferring to administrative agencies' conclusions of law. Deference to administrative agencies was a court-created doctrine and, thus, is one that can be court eliminated. We need not reach for the constitution to so act.

¶136 Second, in interpreting the statute here,…