Dept. of Public Safety v. MacLafferty

In Dept. of Public Safety v. MacLafferty, 230 Ga. 22 (195 SE2d 748) (1973), after a hearing, an official of the Department of Public Safety (DPS) revoked MacLafferty's driver's license. Without having sought review of the officer's decision by the DPS, MacLafferty sought to overturn the revocation of her driver's license in superior court. The superior court affirmed the officer's decision. On appeal, the Court of Appeals reversed, holding that the hearing officer erred in making certain findings of fact. Our Supreme Court granted certiorari, however, and reversed the Court of Appeals decision. The Supreme Court cited provisions in the Administrative Procedure Act requiring a complainant to exhaust administrative remedies and prohibiting a court from considering any objection to an agency decision unless such objection was raised before the agency. The Court, therefore, held that MacLafferty had no standing to complain of the hearing officer's decision because she did not exhaust her administrative remedies by applying to the agency for review of the officer's decision and by not first complaining to the agency of the matters sought to be litigated in court. The Court pointed out that a review by the agency would have afforded the agency the opportunity to address MacLafferty's complaints with its own personnel and without burdening the courts.