Ayala v. Hill
In Ayala v. Hill, 136 Ariz. 88, 664 P.2d 238 (App. 1983) the Court noted that a rule promulgated by the Maricopa County Law Enforcement Officers Merit System Council provided that the Council's decision would be "subject only to administrative review" under the ARA. 136 Ariz. at 92, 664 P.2d at 242.
But the court did not address whether the Council could enact such a rule in the absence of a statute authorizing application of the ARA.
"The sole issue on appeal from the superior court's denial of Ayala's request for special action relief in superior court was whether the Maricopa County Law Enforcement Officers Merit System Commission . . . could rehear and redecide a disciplinary action previously ruled upon by the commission, absent statutory authority or an express rule permitting it do so." Id. at 89, 664 P.2d at 239.