The statute providing for the proceeding may regulate the time in which an administrative proceeding may be brought[i].  A failure to comply with a statute may bar the administrative proceeding.  Some of such statutes are merely directory and do not preclude the administrative agency from taking action after the expiration of the stated time[ii].

The question of laches is turned on, if there are no statutory time limitations applicable to a particular administrative proceeding[iii].  In administrative proceedings, if the challenged administrative action has been unreasonably delayed resulting in prejudice to a party against whom the action was taken, the doctrine of laches applies[iv].

[i]Edgerton v. International Co., 89 So. 2d 488 (Fla. 1956).

[ii] Application of Koch Exploration Co., 387 N.W.2d 530 (S.D. 1986).

[iii] Bultas v. Board of Fire & Police Comm’rs, 171 Ill. App. 3d 189 (Ill. App. Ct. 1st Dist. 1988)

[iv] Robert F. Kennedy Medical Ctr. v. Belshe, 13 Cal. 4th 748 (Cal. 1996)