The petitioner has challenged the constitutionality of the provision in section 22-63-116, 9 C.R.S. (1985 Supp.), authorizing dismissal of a tenured teacher for "other good and just cause." However, it is well-established that this court will not address a constitutional question which is not essential to the disposition of the case before it. Board of County Commissioners v. City County of Denver, 194 Colo. 252, 571 P.2d 1094 (1977); Friedman v. Motor Vehicle Division of Department of Revenue, 194 Colo. 228, 571 P.2d 1086 (1977). Because the hearing officer found, and the Board adopted the finding, that the petitioner's neglect of duty was sufficient in and of itself to warrant her dismissal, we need not address the constitutional issue.

Id., 570 P.2d at 522. See also Hide-A-Way Massage Parlor, Inc. v. Board of County Commissioners, 198 Colo. 175, 597 P.2d 564 (1979) (local governments must adequately define licensing standards for massage parlors); Friedman v. Motor Vehicle Division, 194 Colo. 228, 571 P.2d 1086 (1977) (hearing officer must be guided by articulated standards in the form of rules or regulations); Loesch v. State, 194 Colo. 169, 570 P.2d 530 (1977) (controlled by Elizondo; administrative guidelines required); Andrews v. Director, Division of Labor, 41 Colo. App. 408, 585 P.2d 933 (1978) (Industrial Commission should adopt regulations to assist hearing officers in determining when untimely petitions for review can be excused for "good cause"); Rosenthal v. Department of Revenue, 40 Colo. App. 422, 579 P.2d 1176 (1978) (guidelines insure meaningful review of agency decisions); Emporium, Ltd. v. City of Colorado Springs, 40 Colo. App. 414, 576 P.2d 569 (1978) (guidelines inform the public and the courts of what evidence might be considered material by the licensing authority). Section 42-2-123(11), C.R.S. 1973, stated in part: "In the event that the driver's license is suspended, the department may issue a probationary license for a period not to exceed the period of suspension, which l

Because we affirm the court's ruling on the availability of the statutory physician-patient privilege, it is not essential to the disposition of this case to determine whether the constitutional privilege is unavailable in every circumstances to the respondent in a civil commitment proceeding. See Friedman v. Motor Vehicle Division, 194 Colo. 228, 571 P.2d 1086 (1977); Kirk v. Douglas, 176 Colo. 104, 489 P.2d 201 (1971). I.

Denver Publ'g Co. v. Bd. of County Comm'rs, 121 P.3d 190, 194 (Colo.2005). For example, in Friedman v. Motor Vehicle Div., 194 Colo. 228, 229, 571 P.2d 1086, 1087 (1977), the supreme court declined to decide a constitutional issue because it was not “essential to disposition of the pending case .... [s]ince we are remanding the case for a rehearing which may settle this dispute.” Accord Renteria, 811 P.2d at 799;see also Estelle v. Gamble, 429 U.S. 97, 112 n. 7, 97 S.Ct. 285, 50 L.Ed.2d 251 (1976)