Justia Government & Administrative Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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In the case before the Supreme Court of Minnesota, clerical and technical employees of the Anoka County Sheriff's Office, represented by the Law Enforcement Labor Services, Inc. (the Union), submitted a petition to the Bureau of Mediation Services (the Bureau) to determine an appropriate collective bargaining unit. The County opposed the unit, proposing a broader, county-wide unit. The Bureau found the County's unit to be the more appropriate choice. The Union appealed this decision, arguing that the Bureau had made numerous errors of law.The Supreme Court held that the Bureau did not improperly compare the Union's proposed unit to that of the County's. The Court determined that under the Public Employment Labor Relations Act (PELRA), overfragmentation is one of the "other relevant factors" that the Bureau is allowed to consider when analyzing statutory factors for a unit determination. However, the Court found that the Bureau gave priority and effectively controlling weight to its four-unit preference and the related overfragmentation concerns over the specific factors listed in PELRA. This was deemed to be an error of law.Consequently, the Court reversed the decision of the Bureau and remanded for further proceedings, instructing that a bargaining unit determination must now be made by the Bureau giving appropriate weight and consideration to the statutory factors in PELRA. View "Anoka County, Minnesota vs. Law Enforcement Labor Services, Inc." on Justia Law

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In a dispute with the Department of Human Services (DHS) in Minnesota, Nobility Home Health Care, Inc. (Nobility) was found to have violated Minnesota Statutes section 256B.064 and Minnesota Rule 9505.2165 by failing to maintain health service records as required by law and by submitting claims for services for which underlying health service records were inadequate. The Minnesota Supreme Court held that such conduct constitutes "abuse" under the statute, even if there was no intent to deceive the DHS. However, the court declined to interpret or apply the phrase "improperly paid... as a result of" abuse in the statute, which governs the grounds for monetary recovery. The court reversed the decision of the court of appeals and remanded the case to the DHS for further analysis of this issue. The court's decision means that DHS's demand for an overpayment for Nobility’s first-time paperwork errors may not be reversed unless the DHS also establishes that the provider was improperly paid because of that abuse. View "In the Matter of SIRS Appeal by Nobility Home Health Care, Inc" on Justia Law

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In Minnesota, a man convicted of taking pornographic photographs of a child was ordered by a district court to pay restitution for therapy costs and lost wages incurred by the child's mother. The appellant argued that the mother, as a secondary victim, was only eligible for restitution for losses suffered directly by the child. The State contended that under Minnesota Statutes section 611A.01, family members of the direct victim are part of a singular class of victims because when a child suffers, their parents suffer as well. The Minnesota Supreme Court agreed with the State's argument and affirmed the lower court's decision. It held that Minnesota Statutes section 611A.01(b) creates a singular class of victims that includes the direct victims of a crime and, if the direct victim is a minor, those family members of the minor who incur a personal loss or harm as a direct result of the crime. View "State of Minnesota vs. Allison" on Justia Law

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The Supreme Court affirmed the decision of the Minnesota Tax Court affirming the assessment of the Commissioner of Revenue assessing tax on an apportioned share of Cities Management, Inc.'s (CMI) income from the sale of the S corporation, holding that the income from the corporation's sale was apportionable business income.CMI, which did business in Minnesota and Wisconsin, and its nonresidential partial owner filed Minnesota tax returns characterizing the sale of CMI's goodwill as income that was not subject to apportionment by the State under Minn. Stat. Ann. 290.17. The Commissioner disagreed and assessed tax on an apportioned share of the corporation's income from the sale. The tax court affirmed. The Supreme Court affirmed, holding that CMI's income did not constitute "nonbusiness" income under section 290.17, subd. 6 and may be constitutionally apportioned as business income. View "Cities Management, Inc. v. Commissioner of Revenue" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming the final order of the Commissioner of the Department of Human Services' (DHS) concluding that Trinity had engaged in the abuse outlined in DHS's notices and spreadsheets, holding that the first report of the administrative law judge (ALJ) was the binding decision in this matter.Trinity Home Health Care, which provided nursing and personal care assistant services, received reimbursement from DHS for services that it provided to Medicaid-eligible people with disabilities. After an investigation, DHS sent Trinity notices of termination from the program and demanding return of overpayments and payment-withholding. Both before and after remand by the Commissioner, the ALJ found that terminating Trinity's participation in the Minnesota Health Care Programs was an inappropriate sanction for Trinity's failure to provide certain records. The Commissioner modified the report, concluding that Trinity had engaged in the abuse alleged by the DHS. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Commissioner did not have the authority to remand the case due to the DHS's general authority to administer and supervise Medicaid; and (2) the Commissioner did not have implied authority to remand the case to the ALJ under case law. View "In re Surveillance & Integrity Review Appeals by Trinity Home Health Care Services" on Justia Law

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The Supreme Court held that an action taken by the Minnesota Pollution Control Agency (MPCA) in issuing a National Pollutant Discharge Elimination System/State Disposal System permit was arbitrary and capricious and that the permit did not comply with a Minnesota rule addressing wastewater discharges to groundwater, Minn. R. 7060.0600, subp. 2.At issue was the MPCA's issuance of the permit for a Poly Met Mining, Inc. project. The court of appeals reversed in part, concluding that the MPCA failed properly to consider whether the federal Clean Water Act (CWA) applied to future discharges from Poly Met's facility to groundwater. The Supreme Court remanded the cause, holding (1) remand was required because there were suggestions that the MPCA did not properly consider whether the permit complies with the CWA and that the MPCA did not genuinely engage in reasoned decision-making; (2) remand was required for consideration of whether a variance was available to allow the planned discharge to the unsaturated zone within the containment system; and (3) the prohibition on injecting polluted water directly to the groundwater saturated zone for long-term storage did not apply in this case. View "In the Matter of the Denial of Contested Case Hearing Requests & Issuance of National Pollutant Discharge Elimination System" on Justia Law

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The Supreme Court reversed the decision of the court of appeals dismissing an administrative appeal for lack of appellate jurisdiction in the underlying case involving an air emissions permit issued by the Minnesota Pollution Control Agency for the NorthMet mining project in northern Minnesota, holding that the service and other steps taken by Appellants were effective to invoke appellate jurisdiction and that the appeal was timely-filed under the thirty-day service deadline set forth in Minn. Stat. 14.63.After the Agency issued the permit at issue to Poly Met Mining, Inc., Appellants filed a certiorari appeal. The court of appeals granted PolyMet's motion to dismiss the appeal for lack of jurisdiction on the ground that Appellants had failed to serve PolyMet's counsel within thirty days of receiving the decision. At issue before Supreme Court was whether the service requirements in the judicial review provisions of the Minnesota Administrative Procedure Act, Minn. Stat. 14.63-.69, require petitioners to serve appeal papers on a represented party's counsel. The Supreme Court reversed, holding that, when initiating judicial review where the parties were otherwise served directly, the Act's judicial review provisions do not require service on a represented party's attorney. View "In re Issuance of Air Emissions Permit No. 13700345-101 for PolyMet Mining Inc." on Justia Law

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The Supreme Court affirmed the judgment of the Minnesota Tax Court reducing the Commissioner of Revenue's valuations of CenterPoint Energy Minnegasco's natural gas distribution pipeline system for January 2, 2018 through January 2, 2019, holding that the Commissioner was not entitled to relief.The tax court reduced the Commissioner's valuations and ordered the Commissioner to recalculate Minnegasco's tax liability. The Commissioner appealed, challenging the tax court's income-equalization and cost approaches. The Supreme Court affirmed, holding that the tax court (1) did not err in the way that it used the Commissioner's initial assessments when evaluating the totality of the evidence and making its independent evaluations; (2) did not abuse its discretion in considering the conflicting expert opinions; and (3) did not clearly err in finding external obsolescence. View "Commissioner of Revenue v. CenterPoint Energy Resources Corp." on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that Minnesota Rule 8210.2450, subparts 2 and 3 (the rule) does not conflict with Minn. Stat. 203B.121 (the statute) and that the challenged rule was therefore invalid, holding that subpart 3 of the rule conflicted with subdivision 2(b)(3) of the statute.Appellants brought this declaratory judgment action seeking a prospective declaration that the administrative rule, which governed the acceptance of absentee ballots, was invalid because the rule subparts conflicted with the statute by infringing on discretion the legislature gave to ballot board members. The court of appeals determined that there was no conflict between the rule and the statute. The Supreme Court reversed in part, holding (1) Minn. R. 8210.2450, sub. 3, which authorized any ballot board member to review signatures in the event of an identification number mismatch, was invalid to the extent that the rule conflicted with Minn. Stat. 203B.121, subd.2(b)(3), which required that election judges conduct that review; and (2) the other challenged parts of the rule did not conflict with the statute. View "Minn. Voters Alliance v. Office of Minn. Secretary of State" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court declaring Appellant eligible to submit a petition seeking compensation based on exoneration under Minnesota's Incarceration and Exoneration Remedies Act, Minn. Stat. 611.362 to 611.368, holding that Appellant was not eligible for compensation based on exoneration.At issue was whether Appellant had established, by a fair preponderance of the evidence, that she was exonerated within the meaning of Minn. Stat. 590.11. The district court concluded that Appellant was eligible for compensation based on a finding of exoneration. The court of appeals agreed that Appellant was "exonerated" but remanded for the district court to determine a separate issue. The Supreme Court reversed, holding that Appellant was not eligible for compensation based on exoneration. View "Back v. State" on Justia Law