BALMER, J.
Petitioner J. R. Simplot Company (Simplot) seeks judicial review of an order of the Oregon Department of Agriculture (department), which denied a refund of inspection fees that Simplot had paid to the department. The Court of Appeals affirmed that order, holding that ORS 293.445(2) contains a three-year limitations period that had expired and thus barred the department from providing Simplot a refund. We affirm the Court of Appeals, but we do so on different...
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