What is the current state of the law in the context of the statute that authorizes counsel to attend before an administrative agency?

62. Before returning to the terms of the statute here in question it is helpful to refer to a similar trend in the United States courts in applying the due process provisions of the Fourteenth Amendment to administrative law. The position in the United States federal law would seem to be that the right to and role of counsel before an administrative agency turns on the nature of the power exercised by the agency. These powers have been broadly grouped into legislative, investigative and adjudicatory categories. The United States' decisions emphasize the same distinctions apparent in the Canadian authorities such as St. John and Guay v. Lafleur, supra.