HUNT, J.
C.M. Towle appeals denial of a permanent Class A Dungeness crab fishing license for his boat the Hot Shot. Five months after an Administrative Law Judge (ALJ) issued an initial order granting Towle the Class A license based on "extenuating circumstances," the Washington State Department of Fish & Wildlife (Department), sua sponte, reopened the record and denied the Class A license because during one qualifying season the Hot Shot...
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