City of Tucson v. Superior Court (ABC Trade Schools, Inc.)

In City of Tucson v. Superior Court (ABC Trade Schools, Inc.), 127 Ariz. 205, 619 P.2d 33 (App. 1980), the plaintiffs' claims concerned the distribution of certain federal funds. Id. at 206-07, 619 P.2d at 34-35. A sponsor of the Comprehensive Employment and Training Act accepted a recommendation for funding and distributed the funds to the plaintiffs' competitor, which the plaintiffs challenged. Id. The court held that the exhaustion of remedies doctrine applied to bar the plaintiffs' civil claims because the Act provided a thorough administrative procedure under which the secretary was authorized to correct violations and because Congress, relying on the Secretary's expertise, "has established an elaborate system of administrative review, which would appear intended to be exclusive." Id. at 208, 619 P.2d at 36.