Brown v. Civil Service Commission

In Brown v. Civil Service Commission, Docket No. CV-85-0081A, 1984 WL 48861 (D. Guam App. Div. October 22, 1984), the school board failed to adopt personnel regulations as required under the same law requiring GEDCA to do so, 4 GCA 4105. The Appellate Division case stated that an agency's personnel rules must be "scrupulously adhered to," even if those rules are more generous than what the Constitution requires. In analyzing the principle that an agency must adhere strictly to its own rules, the Appellate Division concluded that later school board regulations adopted by Executive Order were null and void, leaving the previously promulgated regulations in effect. Id. at 2.