Justia Government & Administrative Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Save Lake Calhoun v. Strommen
The Supreme Court held that the Commissioner of the Department of Natural Resources had the statutory authority to change the official name of a well-known Minneapolis lake from Lake Calhoun to Bde Maka Ska because the forty-year limitation on lake name changes in Minn. Stat. 83A.05, subd. 1 applies only to county boards, not to the Commissioner. In 2018, the Commissioner invoked his authority under Minn. Stat. 83A.02(1), (3) to change the name of Lake Calhoun to Bde Maka Ska. Respondent argued that section 83A.05's provision prohibiting changing a body of water's name "which has existed for 40 years" applied to the Commissioner's statutory authority to change the lake's name. Respondent petitioned for a writ of quo warranto challenging the Commissioner's authority. The district court denied the petition, concluding that ongoing action was necessary to obtain the writ and that there was no such action here. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) a writ of quo warranto was an appropriate method to challenge the Commissioner's authority in this case; but (2) the Commissioner's authority under section 83A.02(1), (3) to change the name of a lake is not limited by section 83A.05, subd. 1. View "Save Lake Calhoun v. Strommen" on Justia Law
In re Application of Otter Tail Power Company for Authority to Increase Rates for Electric Service in Minnesota
The Supreme Court held that the Minnesota Public Utilities Commission (MPUC) lacks the authority to require Otter Tail Power Company to amend an existing transmission cost-recovery rider (TCRR) approved under Minn. Stat. 216B.16, subd. 7b(b) to include the costs and revenues associated with two high-voltage interstate transmission lines, known as the Big Stone Access Transmission Lines (Big Stone Lines). In 2013, the MPUC approved Otter Tail's request for a TCRR for three transmission projects. In 2016, Otter Tail filed this general rate case with the MPUC seeking an annual-rate increase on its retail electricity sales to help offset company-wide investment costs and asserted that the costs and revenues associated with the Big Stone Lines should not be considered when setting the retail rates. The MPUC directed Otter Tail to amend the TCRR approved in 2013 to include the costs and revenues of the Big Stone Lines. The court of appeals reversed. The Supreme Court affirmed, holding that the MPUC does not have statutory authority to compel Otter Tail to include the Big Stone Lines in the TCRR. View "In re Application of Otter Tail Power Company for Authority to Increase Rates for Electric Service in Minnesota" on Justia Law
Bergman v. Caulk
The Supreme Court reversed the judgment of the court of appeals ruling that James Bergman was not disqualified from receiving a permit to carry a firearm, holding that the sealing of judicial records under a court's inherent authority does not satisfy the federal requirement of expungement. In 2007, a Minnesota district court issued an expungement order under its inherent authority sealing the judicial records of Bergman's prior conviction of domestic assault. Thereafter, Bergman applied for a permit to carry a firearm. Bergman was granted the permit. In 2017, the Isanti County Sheriff denied Bergman's permit-to-carry application because of his prior domestic assault conviction. The district court denied Bergman's petition for a writ of mandamus. The court of appeals reversed. The Supreme Court reversed, holding that the sealing of judicial records under a district court's inherent authority is not sufficient under federal law to expunge a previous conviction and thereby reinstate an applicant's right to carry a firearm in Minnesota. View "Bergman v. Caulk" on Justia Law
In re Midway Pro Bowl Relocation Benefits Claim
The Supreme Court affirmed the decision of the court of appeals denying the City of Saint Paul's motion to discharge Respondent's petition for a writ of certiorari on the basis that Respondent failed to serve the petition on the agency, as required by Minn. Stat. 14.64, within the thirty-day deadline set forth in Minn. Stat. 14.63, holding that the thirty-day deadline in section 14.63 does not apply to the service requirement imposed by section 14.64. Respondent sought relocation benefits under the Minnesota Uniform Relocation Act after its lease of a bowling alley was prematurely terminated due to construction. The City denied the request, and an administrative law judge denied Respondent's claim. Respondent filed a petition for a writ of certiorari and served the petition on the City within thirty days of receiving the decision. The City sought to discharge the writ and dismiss the appeal based on untimely service. The court of appeals denied relief. The Supreme Court affirmed, holding that judicial review under the Administrative Procedure Act is invoked by compliance with the provisions of section 14.63, and the thirty-day deadline in section 14.63 does not apply to the service requirement imposed by section 14.64. View "In re Midway Pro Bowl Relocation Benefits Claim" on Justia Law
Ewing v. Print Craft, Inc.
The Supreme Court reversed the judgment of the Workers' Compensation Court of Appeals (WCCA) reversing the judgment of the compensation judge denying a qualified rehabilitation consultant's reimbursement claim for rehabilitation services provided during a period in which an employee was no longer suffering from a work-related injury, holding that the WCCA erred by imposing liability on the employer for rehabilitation services provided after the date that the employee's injury had resolved. In reversing the compensation judge, the WCCA concluded that the employer must pay for rehabilitation services until the employer filed a rehabilitation request for assistance. The Supreme Court reversed the WCCA's decision and reinstated the decision of the compensation judge, holding that the WCCA erred in concluding that the employer was required to show good cause to terminate the employee's rehabilitation services provided after the date that the employee's injury resolved. View "Ewing v. Print Craft, Inc." on Justia Law
Block v. Exterior Remodelers, Inc.
The Supreme Court affirmed the decision of the Workers' Compensation Court of Appeals (WCCA) ruling that Minn. Stat. 176.179 did not apply to Appellant's vacated workers' compensation award, holding that no mistaken compensation was paid, and thus, section 176.179 did not apply. Appellant injured his low back during the course of his employment and entered into a settlement agreement with his employer. The WCCA approved the settlement by an award. Appellant later petitioned to vacate the award, arguing that there was a mutual mistake of fact when the settlement was entered into and a substantial change in his medical condition that could not have been anticipated at the time of the award. The WCCA vacated the award based on the substantial change in Appellant's medical condition. When Appellant then filed a claim petition for additional benefits the parties disagreed as to whether Employer was entitled to a credit for the $40,000 already paid under the vacated award. The compensation judge ruled that section 176.179 did not apply and that Employer was entitled to full credit against Appellant's claim for benefits. The Supreme Court affirmed, holding because no mistake of fact or law occurred, no mistaken compensation was paid and that section 176.179 did not apply. View "Block v. Exterior Remodelers, Inc." on Justia Law
In re Minnesota Living Assistance, Inc.
The Supreme Court reversed the court of appeals' decision reversing the order of the Commissioner of the Department of Labor and Industry for Baywood Home Care to pay unpaid overtime wages and liquidated damages, holding that the court erred in determining that the Commissioner's conclusion that split-day plans are not permitted under the Minnesota Fair Labor Standards Act, Minn. Stat. 177.21-.35, was based on an unpromulgated rule. Baywood paid its employees using a split-day plan even after an employee had worked forty-eight hours in a workweek. The Commissioner issued compliance order ordering Baywood to cease and desist from failing to pay overtime. The court of appeals reversed. The Supreme Court reversed, holding (1) the Act requires employers to pay employees at least time-and-a-half wages for all hours worked in the first forty-eight hours of a given workweek, regardless of whether the employee received time-and-a-half compensation during the first forty-eight hours of employment in that workweek; (2) time-and-a-half payments for regularly scheduled work occurring before an employee has worked forty-eight hours in a workweek may not be excluded from an employee's remuneration to calculate the employee's regular rate; and (3) the Commissioner's failure to promulgate interpretive rules meant that the Department's interpretation did not receive deference, but the Court nevertheless adopted that interpretation. View "In re Minnesota Living Assistance, Inc." on Justia Law
Jackson v. Commissioner of Human Services
The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Commissioner of the Department of Human Services (DHS) determining that Appellant was permanently disqualified from working in a capacity where he may have contact with people who access services from a DHS-licensed program, holding that Appellant's claims on appeal failed. After DHS discovered a 2002 child-protection report that Appellant had sexually abused his son sometime around 1998, Appellant was disqualified from employment as a residence manager at a DHS-licensed substance abuse treatment program. The court of appeals affirmed DHS's decision. The Supreme Court affirmed, holding (1) Defendant's right to due process was not violated; (2) the Department of Human Services Background Studies Act, Minn. Stat. ch. 245C, does not create a permanent, irrebuttable presumption that DHS's decision was correct; and (3) Appellant was provided constitutionally sufficient notice of his rights under the Act. View "Jackson v. Commissioner of Human Services" on Justia Law
In re Maltreatment Determination of Amanda Restorff
The Supreme Court reversed the determination of the Commissioner of Human Services that Appellant committed maltreatment under the Maltreatment of Minors Act, Minn. Stat. 626.556, subd. 2(g), when a three-year-old child wandered away from Appellant's daycare, holding that the Commissioner misinterpreted the Act and failed to make necessary findings. After an investigation, Wright County determined that Appellant was responsible for maltreatment when the child was found .3 miles from the daycare facility unattended but uninjured. The Commissioner affirmed the determination. The court of appeals affirmed. The Supreme Court reversed, holding that the Commissioner erred by misinterpreting the statute and that the Commissioner failed to make a factual determination on the length of Appellant's absence as explicitly called for by the Act. View "In re Maltreatment Determination of Amanda Restorff" on Justia Law
Noga v. Minnesota Vikings Football Club
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) affirming a compensation judge's judgment finding that Alapati Noga, a former defensive lineman for the Minnesota Vikings, who now suffers from dementia, was entitled to permanent and total disability benefits, holding that Noga did not satisfy the statute of limitations under Minn. Stat. 176.151. Noga played as a defensive lineman for the Vikings from 1988 until 1992. While playing for the Vikings, Noga experienced head injuries and headaches. In 2015, Noga filed a claim petition for workers' compensation benefits. A compensation judge found that Noga sustained a Gillette injury of "head trauma, brain injury, and/or dementia" that culminated on or about December 1, 1992 and that the injury was a substantial contributing factor to Noga's permanent and total disability.The WCCA vacated certain findings and remanded several issues. On remand, the compensation judge resolved those issues in Noga's favor, determining, among other things, that the statute of limitations was satisfied under Minn. Stat. 176.151 because the Vikings provided Noga with medical care that constituted a "proceeding." The WCCA affirmed. The Supreme Court reversed, holding that the Vikings' provision of care for Noga's head injuries did not constitute a proceeding that prospectively satisfied the statute of limitations. View "Noga v. Minnesota Vikings Football Club" on Justia Law