Washington Law Review




In June 1962, plaintiff applied to the State Liquor Control Board for change of location of his tavern license. Plaintiff proposed to move his tavern business around the corner and across the street from its former location. The Board investigated the proposed move, and, after careful consideration, notified the plaintiff of the Board's approval. In reliance on this notice of approval, plaintiff spent his life's savings acquiring, remodeling, and equipping the new location. Thereafter, without a formal hearing, the Board informed the plaintiff that approval of the proposed move had been withdrawn. The plaintiff sought a writ of mandamus directed to the Board to compel effectuation of the change of location, or to show cause why it should not do so. The trial court concluded that, according to applicable statutory provisions, it did not have jurisdiction to review actions of the Board. On appeal, a divided court reversed. Held: If the action of the Washington State Liquor Control Board in revoking prior approval of a change in license location is arbitrary and capricious, the superior court has jurisdiction to review and set aside the decision. State ex rel. Shannon v. Sponburgh, 66 Wash. Dec. 2d 126, 401 P.2d 635 (1965).

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