Notice: This opinion is subject to correction before publication in the PACIFIC REPORTER. 

Readers are requested to bring errors to the attention of the Clerk of the Appellate Courts, 

303 K Street, Anchorage, Alaska 99501, phone (907) 264-0608, fax (907) 264-0878, email 

corrections@appellate.courts.state.ak.us. 

THE SUPREME COURT OF THE STATE OF ALASKA 

ALASKA POLICE 

STANDARDS COUNCIL, 

Appellant, 

v. 

LANCE PARCELL, 

Appellee. 

) 

) 

) Supreme Court No. S-15364 

Superior Court No. 1JU-12-00728 CI 

O P I N I O N 

No. 6999 – April 17, 2015 

) 

) 

) 

) 

) 

) 

) 

) 

Appeal from the Superior Court of the State of Alaska, First 

Judicial District, Juneau, Louis J. Menendez, Judge. 

Appearances: Kathryn R. Vogel, Assistant Attorney General, 

Anchorage, and Michael C. Geraghty, Attorney General, 

Juneau, for Appellant. Stephen F. Sorensen, Simpson, 

Tillinghast, Sorensen, & Sheehan, P.C., Juneau, for 

Appellee. 

Before: Fabe, Chief Justice, Winfree, Stowers, Maassen, and 

Bolger, Justices. 

WINFREE, Justice. 

I. INTRODUCTION 

The level of deference we afford to an underlying decision often is key to 

the resolution of an appeal, and this case makes that point crystal clear. A police 

officer’s employment was terminated for abuse of alcohol, sexually offensive remarks 

made to two female officers, and alleged dishonesty during the subsequent police 
 

 

 

 

 

 

 

 

 

investigation. An arbitrator concluded that terminating the officer’s employment was an 

excessive penalty and ordered the officer’s reinstatement. The superior court affirmed 

the arbitration decision and we affirmed the superior court based on the deference that 

must be given to an arbitration decision. However, the Alaska Police Standards Council 

revoked the officer’s police certificate after concluding that the officer was not of good 

moral character and was dishonest. The superior court reversed the decision to revoke, 

substituting its judgment for the Council’s. But because the Council’s decision, like that 

of the arbitrator, is entitled to deference, we reverse the superior court’s decision and 

affirm the Council’s decision to revoke the officer’s police certificate. 

II. FACTS AND PROCEEDINGS 

This is the second time the underlying facts of this case have come before 

us. In 2006 the Airport Police and Fire Department of the Alaska Department of 

Transportation terminated Lance Parcell’s employment for harassing conduct and 

evasiveness during the Department’s subsequent review. In State v. Public Safety 

1 Employees Ass’n (PSEA 2010) we affirmed a superior court decision refusing to vacate

a labor arbitrator’s decision to reinstate Parcell.2 

The Alaska Police Standards Council subsequently revoked Parcell’s police 

certificate, but the superior court on appeal reversed the Council’s decision. The Council 

now appeals from the superior court’s decision. 

In PSEA 2010 we introduced most of the relevant factual background: 

[Parcell] had been employed as an officer with the 

Department for approximately four years when he was 

terminated on August 24, 2006. The termination was based 

on two events that occurred in May 2006 while [Parcell] was 

1 235 P.3d 197(Alaska 2010). 

2 Id. at 203. 

-2­ 6999 
 

 

 

 

 

 

 

 

 

 

 

working at the Alaska Law Enforcement Academy in Sitka, 

Alaska and on [Parcell’s] conduct during the subsequent 

investigation. 

On May 5, 2006, [Parcell] and two other training 

officers went to a bar in Sitka, and [Parcell] became 

extremely intoxicated. While at the bar, [Parcell] slid toward 

a female officer on a couch and made inappropriate sexual 

remarks, telling her “that he wanted to make her come, that 

he could make her scream, [and] that he could push her 

buttons.” The female officer told him to stop, but he repeated 

the comments several times. Because [Parcell] was too 

intoxicated to walk home that night, another officer drove 

him home. When they returned to the Academy, [Parcell] 

vomited outside and then, after the hallways were cleared of 

recruits, he was helped into an Academy building to a room 

where he could sleep. [Parcell] apologized to the female 

officer in person the following day and by email several days 

later. [Parcell] stated during the internal investigation and to 

the arbitrator that he does not remember making these 

inappropriate remarks to the female officer. 

On the evening of May 17, 2006, [Parcell] stared at 

another female officer while they were watching television 

and later sent her unwelcome text messages in which he 

invited her to “go on a beer run,” “go out and have fun,” and 

join him in the room where training officers are allowed to 

sleep to “talk to him if she wanted.” She told him to stop 

sending the messages, but he continued to do so. The 

following morning, [Parcell] sent the officer an email calling 

her his “sexy new friend,” telling her she had “a great [a]ss” 

and “very nice tits,” and stating that he wanted to see her 

nipple rings. The female officer wrote an email expressing 

her anger with his behavior, and [Parcell] subsequently sent 

her an email apology. [Parcell] testified at arbitration that he 

was up all night drinking prior to sending the email, a fact 

supported by the female officer’s statement during the 

investigation that she smelled alcohol on [Parcell] when she 

saw him that morning. 

-3- 6999
 
 

 

 

 

 

Following these events, another officer filed a 

complaint regarding [Parcell’s] behavior. Upon receiving the 

complaint, Lauri Burkmire, Chief of the Department, initiated 

an administrative inquiry, assigning a lieutenant to conduct 

witness interviews and a site visit. In his report, the 

lieutenant “concluded that [Parcell’s] conduct violated . . . 

Department rules relating to unbecoming conduct, courtesy, 

sexual harassment, private conduct and truthfulness, immoral 

conduct (deception), and harassment” and identified “eight 

instances in which he felt [Parcell] had been less than truthful 

in the investigation.” 

After reviewing the report, Chief Burkmire sent 

[Parcell] a letter directing him to attend a meeting on August 

18, 2006 to discuss “inconsistencies in your claims and your 

honesty regarding this matter.” She reminded [Parcell] of his 

obligation to be honest and warned that failure to do so could 

result in his dismissal. [Parcell] attended the meeting with his 

representative from [the Public Safety Employees 

Association] and, according to the arbitrator, admitted that he 

had not been honest in his interview with the lieutenant. At 

arbitration, [Parcell] testified that his dishonesty in his 

interview during the investigation was limited to 

downplaying the extent of his drinking. Chief Burkmire 

terminated [Parcell] several days after their meeting. 

[Parcell] testified at arbitration that immediately 

following his termination, he enrolled in an outpatient 

alcoholic treatment program, which he successfully 

completed in eight months. At the time of his testimony 

before the arbitrator, he claimed he had been sober for fifteen 

months. He acknowledged that his remarks on May 5 and his 

email of May 18 were “inappropriate and rude,” admitted that 

he had “failed to uphold the high standard of his profession,” 

[ ] and stated that he was “very ashamed of his behavior.” 3

3 Id. at 199-200 (internal footnote omitted). 

-4- 6999 
 

 

 

 

 

 

The parties in this case stipulated to these facts and they are quoted verbatim in the 

Council’s decision. 

After the Department terminated Parcell the Public Safety Employees 

Association filed a grievance on his behalf, and the matter eventually went to arbitration.4 

The arbitrator found, in relevant part, that: (1) Parcell’s behavior was “totally contrary 

to [his] professional responsibility,” “sexually offensive,” and “as far over the line as one 

could imagine”; and (2) “although the Department did not establish that [Parcell] had 

lied, it did prove that he ‘was evasive, misleading and not forthcoming’ in the 

investigatory process.”5

 By only “the slimmest margin” the arbitrator found that Parcell 

should be reinstated. The Department then moved in the superior court to vacate the 

arbitration decision, but the superior court denied the Department’s request. 

The Department appealed to this court and in PSEA 2010 we affirmed the 

superior court’s decision, noting the “deferential standard” afforded arbitration 

decisions, which was “key to the decision we reach[ed].”6 And we explained that “[i]f 

we were reviewing this case in the first instance, or under a less deferential standard, we 

likely would not have reached this conclusion.”7 

While Parcell’s employment matter was progressing, the Alaska Police 

Standards Council independently sought to revoke Parcell’s police certificate. The 

revocation proceedings were stayed pending resolution of the employment matter, but 

after our PSEA 2010 decision the Council served Parcell with its “Third Amended 

Accusation” and resumed the revocation proceedings. The thrust of the Council’s 

4 Id. at 200. 

5 Id. (alteration in original). 

6 Id. at 201. 

7 Id. at 202. 

-5- 6999
 
 

 

 

 

 

 

 

 

 

position was that because Parcell lacked good moral character and was dishonest, 

revocation of Parcell’s certificate was appropriate. 

A hearing officer was appointed, but Parcell and the Council agreed that an 

evidentiary hearing was unnecessary and stipulated to the facts noted in our PSEA 2010 

decision. The hearing officer found that the Council did not meet its burden in proving 

that: (1) Parcell had been discharged for cause;8

 or (2) Parcell is not a person of good 

moral character.9 The hearing officer therefore concluded that revocation of Parcell’s 

police certificate was unwarranted, stating that “[p]er the stipulation of the parties, 

Parcell’s conduct was egregious, rude, and grossly offensive” but not sufficient to 

establish a lack of good moral character. 

The Council disagreed with the hearing officer’s proposed decision and 

pursued revocation. 10 Parcell provided the Council additional evidence to establish his 

good moral character. The Council issued a written decision evaluating whether Parcell: 

(1) had been terminated for conduct that “would cause a reasonable person to have 

substantial doubt about [his] honesty, fairness, and respect for the rights of others and for 

8 See 13 Alaska Administrative Code (AAC) 85.110(b)(3) (2014) (requiring 

revocation when an officer “has been discharged . . . from employment as a police officer 

in this state or any other state or territory for cause for conduct that would cause a 

reasonable person to have substantial doubt about an individual’s honesty, fairness, and 

respect for the rights of others”). 

9 See 13 AAC 85.110(a)(3) (providing for discretionary discharge when an 

officier “does not meet the standards in 13 AAC 85.010(a) or (b)”); 13 AAC 

85.010(a)(3) (requiring that a person hired as a police officer “is of good moral 

character”). 

10 AS 44.62.500 allows agencies to adopt hearing officer decisions, but an 

agency is not required to adopt a hearing officer’s decision and “may decide the case 

upon the record, including the transcript, with or without taking additional evidence, or 

may refer the case to the same or another hearing officer to take additional evidence.” 

-6- 6999
 
 

 

 

 

 

11 12 the laws of this state”; and (2) is not of “good moral character.” In addition to the 

evidence of Parcell’s inappropriate sexually offensive remarks, the Council considered 

the evidence that he had been dishonest during the department’s subsequent 

investigation, stating: 

Parcell “was evasive, misleading, and not forthcoming”. . . 

[and t]he agreed upon facts, the arbitrator decision, superior 

court order, and Supreme Court opinion leave no room to 

debate that [the Department chief and investigating officer] 

are of the opinion that Parcell was dishonest in eight specific 

instances during the administrative investigation. Parcell’s 

engaging [in] the dishonest behavior renders him unable to 

effectively perform the duties of a law enforcement officer in 

connection with making applications to the court — 

including search and arrest warrant applications, and court 

testimony. 

The Council concluded that Parcell “is not a person the citizens of our great 

State of Alaska can entrust with private personal information, the lives and safety of 

themselves and their loved ones, and be counted on to do the right things for the right 

reasons” and that his “dishonesty significantly and substantially impairs his ability to 

perform the responsibilities of a law enforcement officer.” The Council revoked 

Parcell’s certificate. Parcell appealed to the superior court. 

The superior court concluded that the Council’s moral character 

determination was not entitled to deference because good moral character “is a standard 

eligibility requirement in professions serving the public” so its meaning “is not one 

11 13 AAC 85.110(b)(3). 

12 13 AAC 85.110(a)(3) (“The council will, in its discretion, revoke a . . . 

certificate upon a finding that the holder . . . does not meet the standards in 

13 AAC 85.010(a) or (b).”); 13 AAC 85.010(a)(3) (“A participating police department 

may not hire a person as a police officer unless the person . . . is of good moral 

character.”). 

-7- 6999
 
 

 

 

 

unique to the Council.” The court agreed with the hearing officer’s statement that a 

person lacking good moral character has character flaws “that are ingrained, lasting, or 

causing consistent behavioral or decision making problems.” The court then summarized 

various certificate-revocation decisions from other jurisdictions involving police officers 

who had behaved more egregiously than Parcell. It faulted the Council for not 

considering the good aspects of Parcell’s character, including his employment for four 

years before the May 2006 incidents, his maintaining sobriety since the incidents, and 

that he “was actively engaged in the community, and had the support of his local 

[r]abbi.” Finally, the court concluded that the Council’s interpretation of “good moral 

character” was unreasonable. 

The superior court also reviewed the Council’s finding that Parcell had been 

dishonest. The court concluded that the finding was not supported by substantial 

evidence and disagreed that Parcell’s conduct “would be considered exculpatory 

information in cases in which he is involved, such that the arbitrator’s findings would 

preclude Parcell from performing his duties as a police officer.” 

The Council appeals. 

III. STANDARD OF REVIEW 

“Where the superior court is acting as an intermediate court of appeals, we 

directly review the agency decision. Questions of fact are reviewed for substantial 

evidence. Questions of law involving agency expertise are reviewed using the 

reasonable [or rational] basis test . . . .”13 We have explained that: 

[T]wo circumstances generally call for rational basis review: 

(1) “where the agency is making law by creating standards to 

13 West v. Municipality of Anchorage, 174 P.3d 224, 226 (Alaska 2007) 

(internal footnotes omitted) (citing Thoeni v. Consumer Elec. Servs., 151 P.3d 1249, 

1253 (Alaska 2007); State v. Pub. Safety Emps. Ass’n, 3 P.3d 409, 413 (Alaska 2004)). 

-8- 6999
 
 

 

 

 

be used in evaluating the case before it and future cases,” and 

(2) “when a case requires resolution of policy questions 

which lie within the agency’s area of expertise and are 

inseparable from the fact’s underlying the agency’s 

[ ] decision.” 14

“Where questions of law do not involve agency expertise, the appropriate standard of 

review is ‘substitution of judgment . . . .’ ”15 “We review an agency’s application of its 

own regulations for whether the agency’s decision was ‘arbitrary, unreasonable, or an 

abuse of discretion.’ ”16 

IV.	 DISCUSSION 

A.	 It Was Error To Apply The Substitution Of Judgment Standard To 

The Council’s Decision On Good Moral Character. 

Noting the “primary public interest that applicants meet minimum standards 

for employment as police officers”17 the legislature created the Alaska Police Standards 

Council.18 The Council may “establish minimum standards for employment as a police 

officer”19 and the Council may establish mandatory qualifications for police officers 

“including minimum age, education, physical and mental standards, moral character, 

14 W. States Fire Protection Co. v. Municipality of Anchorage, 146 P.3d 986, 

989 (Alaska 2006) (quoting Tesoro Alaska Petroleum Co. v. Kenai Pipe Line Co., 746 

P.2d 896, 903 (Alaska 1987)). 

15 Alaska Exch. Carriers Ass’n v. Regulatory Comm’n of Alaska, 202 P.3d 

458, 460 (Alaska 2009) (quoting Tesoro Alaska Petroleum Co., 746 P.2d at 903). 

16 Id. at 461 (quoting Griffiths v. Andy’s Body & Frame, Inc., 165 P.3d 619, 

623 (Alaska 2007)). 

17 AS 18.65.130. 

18 AS 18.65.140. 

19 AS 18.65.220. 

-9-	 6999
 
 

 

 

and experience.”20 If an applicant satisfies the Council’s mandatory qualifications, then 

“[t]he [C]ouncil shall issue a certificate evidencing satisfaction of the requirements.”21 

But if a police officer fails to continue to satisfy the Council’s standards, the Council 

may revoke the officer’s certificate.22 

The Council has adopted regulations establishing grounds for mandatory 

23 24 revocation and grounds for discretionary revocation. The Council may in its 

discretion revoke an officer’s certificate if the officer is not “of good moral character.”25 

In its regulations the Council has defined good moral character as: 

the absence of acts or conduct that would cause a reasonable 

person to have substantial doubts about an individual’s 

honesty, fairness, and respect for the rights of others and for 

the laws of this state and the United States; for purposes of 

this standard, a determination of lack of “good moral 

20 AS 18.65.240(a) (emphasis added). 

21 AS 18.65.240(b). 

22 AS 18.65.240(c). 

23 13 AAC 85.110(b) (requiring revocation for conviction of a felony, 

conviction of specific misdemeanors, use, possession, or sale of controlled substances, 

and “discharge[] . . . as a police officer . . . for conduct that would cause a reasonable 

person to have substantial doubt about an individual’s honesty, fairness, and respect for 

the rights of others and for the laws of this state”). 

24 13 AAC 85.110(a) (granting the Council discretion to revoke a certificate 

for falsification or omissions in a certificate application, for discharge or resignation 

under threat of discharge for reasons that adversely affect the officer’s ability to perform 

duties, and for failure to meet the basic standards for police officers). 

25 See 13 AAC 85.110(a)(3) (providing for discretionary revocation when an 

officer “does not meet the standards in 13 AAC 85.010(a) or ( b)”); 13 AAC 85.010(a)(3) 

(explaining that a department may not hire a person as an officer unless the person “is 

of good moral character”). 

-10- 6999
 
 

 

 

 

 

 

character” may be based upon all aspects of a person’s 

[ ] character . . . . 26

We must determine the amount of deference owed to the Council’s 

application of its regulations. The Council’s Third Amended Accusation included two 

counts for revocation: (1) mandatory revocation under 13 AAC 85.110(b)(3) — due to 

Parcell’s discharge from the Department; and (2) discretionary revocation under 13 AAC 

85.110(a)(3) — due to Parcell’s lack of good moral character. In its Final Decision the 

Council concluded that discretionary revocation was appropriate because Parcell was not 

of good moral character.27 

The superior court concluded that the Council’s moral character 

determination was not entitled to deference because moral character “is a standard 

eligibility requirement in professions serving the public” and “not one that requires the 

Council’s specialized knowledge or technical expertise.” The superior court further 

noted that “courts frequently consider character” and that “while the Council may be 

26 13 AAC 85.900(7). 

27 The Council also concluded that mandatory revocation was appropriate 

because Parcell was: 

discharged from employment as a police officer “for conduct 

that would cause a reasonable person to have substantial 

doubt about an individual’s honesty, fairness, and respect 

forth [sic] rights of others and for the laws of this state and 

the United States or that is detrimental to the integrity of the 

police department where the police officer worked . . . .” 

The superior court held that the Council waived mandatory revocation and that our 

decision in PSEA 2010, affirming the arbitrator’s decision that Parcell not be discharged 

for cause, precludes revocation under 13 AAC 85.110(b)(3). Parcell briefed this 

decision, but the Council limited its appeal to discretionary revocation. We therefore do 

not address the court’s decision on mandatory revocation under 13 AAC 85.110(b)(3). 

-11- 6999
 
 

 

 

 

 

experienced in determining good moral character, that determination does not inherently 

call for the Council’s expertise.” Substituting its judgment for the Council’s, the court 

concluded that “[t]he term ‘lacking in moral character’ should then generally refer to 

flaws in one’s character that are engrained, lasting or causing consistent behavioral or 

decision making problems.” 

Substitution of judgment is not the proper standard of review in this case. 

The Council correctly argues that the revocation decision based on the determination that 

Parcell lacked good moral character was a policy determination involving agency 

expertise, properly reviewed for a rational or reasonable basis. “The rational basis test 

may be appropriate even when interpreting commonly used words, if there are technical 

and policy reasons to defer to the administrative agency, and especially if the legislature 

has granted the agency broad discretion.”28 

The legislature created the Council to “establish minimum standards for 

employment as a police officer.”29 And the legislature gave the Council discretion when 

making revocation decisions.30 We therefore defer to the Council’s reasonable 

interpretation and application of its regulations. 

B.	 The Council Reasonably Determined That Parcell Was Not Of Good 

Moral Character. 

Relying on the facts that Parcell was “a person who engaged in behavior 

‘totally contrary to his professional responsibility,’ ‘sexually offensive,’ and ‘as far over 

the line as one could imagine’ ” and that Parcell was “ ‘evasive, misleading and not 

28 W. States Fire Protection Co. v. Municipality of Anchorage, 146 P.3d 986, 

989 (Alaska 2006). 

29 AS 18.65.220. 

30 See AS 18.65.240(c) (“The council may deny or revoke the certificate of 

a police officer who does not meet the standards adopted under (a)(2) of this section.”). 

-12-	 6999
 
 

 

 

 

 

 

 

 

forthcoming’ in the investigatory process” the Council determined that Parcell was not 

of good moral character.31 

Parcell argues that “there must be a pattern of behavior to show the lack of 

good moral character and not one isolated incident.” In support of his argument Parcell 

cites cases from other jurisdictions,32 but he fails to point to any precedent or clear 

statement establishing that this is the law in Alaska. We are not persuaded that a single 

transgression or incident of misconduct, no matter how egregious, never will be 

sufficient to support a reasonable determination that a police officer is not of good moral 

character. And in this case the Council relied on two separate incidents, as well as 

Parcell’s evasive behavior during the subsequent investigation. 

Parcell echoes the superior court’s notation of “the Council’s apparent 

failure to consider ‘all aspects’ of Parcell’s character as permitted by the definition of 

good moral character under 13 AAC 85.900(7).” In order to show his good moral 

character Parcell submitted evidence to the Council that he had completed alcohol 

treatment and maintained his sobriety, was actively involved in his community, and that 

he received his local rabbi’s support. The Council’s decision did not explicitly mention 

31 The Council also determined that Parcell’s evasive behavior during the 

Department’s investigation would be subject to a mandatory Brady disclosure and that 

this would limit Parcell’s ability to effectively perform his duties as a police officer. See 

Brady v. Maryland, 373 U.S. 83, 86-88 (1963) (requiring disclosure of exculpatory 

information); see also Giglio v. United States, 405 U.S. 150, 154 (1972) (“When the 

reliability of a given witness may well be determinative of guilt or innocence, 

nondisclosure of evidence affecting credibility falls within [the] general [Brady] rule.” 

(quoting Nupue v. Illinois, 360 U.S. 264, 269 (1959)) (internal quotation marks 

omitted)). We do not address the Brady issue because it is not necessary for our 

resolution of this case. 

32 See, e.g., Albert v. Fla. Dep’t of Law Enforcement, Criminal Justice 

Standards & Training Comm’n, 573 So.2d 187 (Fla. Dist. App. 1991); Cuff v. Dep’t of 

Pub. Safety Standards & Training, 198 P.3d 931 (Or. 2008). 

-13- 6999
 
 

 

 

 

 

 

 

 

 

this evidence of Parcell’s character, but that does not mean the Council did not consider 

it33 — the Council had no obligation to list all aspects of Parcell’s character in its 

decision. Even if the Council’s decision could have said more, our review is limited to 

determining whether the Council’s decision was reasonable. 

Parcell finally argues that in his employment case the arbitrator and this 

court “did not conclude th[at] Parcell was dishonest” and that we have previously held 

that Alaska “does not have [an] explicit, well-defined and dominant public policy that 

requires police officers to be completely honest.”34 Parcell correctly notes that in his 

employment case the arbitrator concluded that Parcell’s “conduct fell short of lying,” but 

the arbitrator’s findings that Parcell admitted lying on one occasion and that Parcell was 

evasive during the subsequent investigation support the Council’s conclusion that Parcell 

was dishonest. And the fact that there is no legal requirement to terminate a police 

officer’s employment for minor acts of dishonesty does not limit the Council’s discretion 

to revoke that officer’s certification. 

The stipulated facts establish that Parcell’s harassing conduct was beyond 

offensive and inappropriate and that Parcell then was evasive during the Department’s 

review. The Council concluded, based on these specific facts, that Parcell did not have 

the moral character required of a police officer in Alaska. There is no evidence in the 

record that the Council considered inappropriate facts or failed to consider relevant facts. 

33 See 13 AAC 85.900(7) (“[A] determination of lack of ‘good moral 

character’ may be based upon a consideration of all aspects of a person’s character.”). 

34 See State v. Pub. Safety Emps. Ass’n (PSEA 2011), 257 P.3d 151, 161 

(Alaska 2011) (“While Alaska’s laws are explicit in favoring an honest police force, they 

are not explicit in requiring a policy of absolute zero tolerance toward any dishonest by 

law enforcement officials, no matter how minor.” (Emphasis in original.)). 

-14- 6999
 
 

 

 

 

In PSEA 2010, when ultimately affirming the arbitrator’s decision to 

reverse Parcell’s termination, we expressly noted that “[i]f we were reviewing this case 

in the first instance, or under a less deferential standard, we likely would not have 

reached this conclusion.” 35 The Council was reviewing the case in the first instance and 

came to a different conclusion than the arbitrator in the employment case, and here we 

again review the decision under a deferential standard of review. We conclude that the 

Council’s revocation decision was reasonable. 

V. CONCLUSION 

The judgment of the superior court is REVERSED and the Council’s 

revocation of Parcell’s police certificate is AFFIRMED. 

35 235 P.3d 197, 202 (Alaska 2010). 

-15- 6999