BRAZIL, C.J.:
The Kansas State Board of Agriculture (KSBA or Board) filed a 16-count complaint against Kermit Kams, a crop duster, alleging violations of the Kansas Pesticide Law (KPL), K.S.A. 2-2438a et seq. The complaint sought the assessment of civil penalties, a refusal of Kams' pesticide business application, and a revocation of his commercial applicator certificate. The KSBA hearing officer found Kams in violation of the KPL under each count of the complaint...
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