Facts
- Robert Guillou’s driver’s license was suspended or revoked by the Director of the New Hampshire Division of Motor Vehicles under RSA 263:56.
- RSA 263:56 authorized the director, after a hearing, to suspend or revoke a license “for any cause which he may deem sufficient.”
- The statute did not set substantive standards governing when suspension or revocation could occur.
- The statute did not limit the permissible duration of a suspension or revocation.
- Guillou challenged the statute as an unconstitutional delegation of legislative power under the New Hampshire Constitution’s separation-of-powers provisions.
Issues
- Whether RSA 263:56 unlawfully delegated legislative power by authorizing the director to suspend or revoke licenses for any cause the director deemed sufficient, without statutory standards or limits.
- Whether the statute could be construed to supply sufficient limiting standards to avoid unconstitutionality.
Decision
- The New Hampshire Supreme Court held RSA 263:56 unconstitutional.
- The court concluded the statute delegated legislative authority because it granted the director power “without any guidance or limitation.”
- The court rejected a saving construction, finding no adequate statutory basis to infer standards or temporal limits.
- The court set aside the director’s suspension/revocation authority exercised under the invalid statute, which effectively vacated Guillou’s suspension under that provision.
Legal Principles
- Under the New Hampshire Constitution’s separation of powers, the legislature may not confer on an administrator open-ended authority to impose licensing sanctions without meaningful statutory standards.
- A delegation is invalid where an administrator is empowered to act for “any cause” the administrator deems sufficient, with no guidance on relevant factors or permissible scope of sanctions.
- Although statutes should be construed to avoid constitutional infirmity when fairly possible, courts may not supply missing substantive standards where the text provides no workable limiting principle.
Conclusion
The court invalidated RSA 263:56 because it authorized license suspension or revocation based solely on the director’s unchanneled judgment and without limits on duration, amounting to an impermissible delegation of legislative power in violation of state separation-of-powers requirements.