PETITION FOR JUDICIAL REVIEW OF ADMINISTRATIVE AGENCY DECISION

(Missouri APA, RSMo § 536.010 et seq.)

[APPROPRIATE Missouri COURT]

Case No.: _________________

[PETITIONER],
Petitioner,

v.

[RESPONDENT STATE AGENCY],
Respondent.

1. DOCUMENT HEADER

1.1 Effective Date. This Petition is deemed filed on the date reflected by the Clerk's endorsement.

1.2 Recitals.
(a) Respondent [STATE AGENCY] ("Agency") issued a final decision dated [DATE OF DECISION] (the "Decision") imposing [DESCRIBE PENALTY/ORDER] against Petitioner.
(b) Petitioner timely seeks judicial review pursuant to the Missouri APA (RSMo § 536.010 et seq.).

2. DEFINITIONS

"Administrative Record" - the complete record of the underlying agency proceeding.

"Agency" - [RESPONDENT STATE AGENCY FULL FORMAL NAME].

"Decision" - the final administrative decision issued by Agency on [DATE].

"Petitioner" - [PETITIONER FULL LEGAL NAME].

3. JURISDICTION, VENUE & GOVERNING LAW

3.1 Statutory Basis. This Court has jurisdiction under the Missouri APA (RSMo § 536.010 et seq.).

3.2 Venue. Venue is proper in this Court.

3.3 Governing Law. This Petition is governed by the Missouri Constitution and the Missouri APA.

4. PARTIES

4.1 Petitioner. Petitioner [PETITIONER NAME] is a [DESCRIBE ENTITY TYPE] with its principal place of business at [ADDRESS].

4.2 Respondent. Respondent [STATE AGENCY] is a state administrative agency.

5. EXHAUSTION OF ADMINISTRATIVE REMEDIES

5.1 Petitioner participated fully in the underlying agency proceeding.

5.2 The Agency issued its final Decision on [DATE]. All administrative remedies are exhausted.

6. STATEMENT OF FACTS

6.1 Overview of Proceedings. On [DATE], Agency commenced administrative enforcement against Petitioner.

6.2 The Decision. On [DATE], the Agency issued its Decision finding [FINDINGS] and imposing [SANCTIONS].

6.3 Prejudice to Petitioner. The Decision adversely affects Petitioner by [DESCRIBE HARM].

7. CLAIMS FOR RELIEF

The Court shall reverse agency action that is:
(a) in violation of constitutional or statutory provisions;
(b) in excess of agency authority;
(c) made upon unlawful procedure;
(d) unsupported by substantial evidence; or
(e) arbitrary or capricious.

8. PRAYER FOR RELIEF

WHEREFORE, Petitioner respectfully prays for judgment:

A. Reversing or vacating the Decision;

B. For costs and attorney's fees as permitted by law;

C. For such other relief as the Court deems just.

9. VERIFICATION

I, [NAME], declare under penalty of perjury that the foregoing is true and correct.

Executed on [DATE], at [CITY, STATE].

___________________________________
[NAME]

10. SIGNATURE BLOCK

Respectfully submitted,

[LAW FIRM NAME]

By: ___________________________________
[ATTORNEY NAME]
Bar No. [####]
[ADDRESS]
[PHONE] | [EMAIL]

Dated: ____________________