Justia Government & Administrative Law Opinion Summaries

The case involves Joseph Rued, who reported a potential sexual abuse incident involving his son to Scott County Health and Human Services. The County investigated and concluded that no abuse had occurred. Rued requested reconsideration, but the County upheld its initial finding. Rued then appealed to the Minnesota Department of Human Services (DHS) for a fair hearing, which was denied by the Commissioner based on a recommendation from a human services judge.Rued subsequently appealed the Commissioner’s decision to the Scott County District Court. Under Minnesota Statutes section 256.045, subdivision 7, an appeal must be served on the Commissioner and any adverse party of record within 30 days. Rued served the notice on the Commissioner but failed to serve Scott County. Despite this, a Scott County attorney appeared at the initial hearing and argued that the district court lacked jurisdiction due to the failure to serve the County. The district court ruled that the County had waived any objection to personal jurisdiction by appearing at the hearing and denied Rued’s request for appeal on the merits.The Minnesota Court of Appeals vacated the district court’s decision, holding that the failure to serve the County deprived the district court of subject matter jurisdiction. The court did not address whether Rued was entitled to a hearing on the no-maltreatment determination.The Minnesota Supreme Court reviewed the case and held that the 30-day time limit for serving a notice of appeal under section 256.045, subdivision 7, is a waivable limitations period, not a requirement for subject matter jurisdiction. The Court also clarified that adequate service of the notice of appeal is necessary for personal jurisdiction. The case was reversed and remanded to the district court to allow the County to either waive its defense related to the limitations period or move for dismissal on that basis. View "Rued vs. Commissioner of Human Services" on Justia Law

A charter school was accused of manipulating attendance records to receive excess state aid. The Minnesota Department of Education (the Department) audited the school based on these allegations and found significant discrepancies, leading to a retroactive reduction in aid by over $1.3 million. The school appealed the audit results administratively, but the Department upheld its decision.The school then appealed to the Minnesota Court of Appeals, arguing that the Department should have investigated the allegations under a statute dealing with violations of law (Minn. Stat. § 127A.42) rather than the statute used for auditing aid distributions (Minn. Stat. § 127A.41). The Court of Appeals affirmed the Department's decision, stating that the Department had the authority to conduct the audit under the statute it used.The Minnesota Supreme Court reviewed the case to determine whether the Department was required to investigate under the statute related to violations of law. The court held that the Department had the statutory authority to audit the school under Minn. Stat. § 127A.41 and was not required to investigate under Minn. Stat. § 127A.42, even though the allegations involved potentially illegal activity. The court affirmed the decision of the Court of Appeals, concluding that the Department's actions were within its legal authority. View "Minnesota Internship Center vs. Minnesota Department of Education" on Justia Law

Kay “KT” Jacobs, a member of the Columbia Heights City Council, was the subject of a recall petition. The petition alleged that Jacobs used a fake name and made derogatory comments about a city council candidate's heritage during a phone call, lied during a city investigation, and was subsequently censured and stripped of her ability to serve on boards and commissions. Jacobs filed a petition to cancel the recall election, arguing that the recall petition did not meet the legal requirements for recall petitions and failed to allege malfeasance or nonfeasance, which are constitutional prerequisites for recalling an elected municipal official.The district court denied Jacobs' petition, finding that the recall petition met the procedural requirements of the city charter and that the allegations constituted malfeasance. Jacobs appealed, and the Minnesota Supreme Court granted her petition for accelerated review.The Minnesota Supreme Court reversed the district court's decision, concluding that the recall petition did not meet the legal definitions of malfeasance or nonfeasance. The court held that Jacobs' conduct, while inappropriate, did not violate a substantive legal standard established by law, rule, or case law, and that she was not acting in her official capacity during the phone call. Therefore, the recall petition failed to allege the necessary grounds for a recall election under the Minnesota Constitution. The court canceled the recall election scheduled for February 13, 2024. View "Jacobs v. City of Columbia Heights" on Justia Law

A state trooper brought his patrol vehicle to a car dealership for service, accompanied by his canine, Diesel. During the visit, Diesel attacked and injured an employee, Cristina Berrier, without provocation. Berrier suffered serious injuries and subsequently sued the Minnesota State Patrol, alleging negligence and later indicating her intention to pursue a claim under Minnesota’s strict liability dog-bite statute, Minn. Stat. § 347.22.The district court denied the State Patrol’s motion to dismiss, concluding that Berrier’s complaint sufficiently pleaded her statutory claim and that the dog-bite statute waived sovereign immunity. The State Patrol appealed, and the Minnesota Court of Appeals reversed, holding that the State Patrol was immune from suit under the doctrine of sovereign immunity. The appellate court did not address whether Berrier adequately pleaded her statutory dog-bite claim.The Minnesota Supreme Court reviewed the case to determine if the dog-bite statute waived sovereign immunity. The court concluded that the language of Minn. Stat. § 347.22, which imposes liability on the "owner" of a dog, was sufficiently plain, clear, and unmistakable to waive sovereign immunity. The court emphasized that the statute’s broad application to any dog owner, including state entities, served the public policy interest of protecting individuals from dog attacks and ensuring their full recovery. Consequently, the court reversed the appellate court’s decision and remanded the case for further proceedings. View "Hennesy vs. Minnesota State Patrol" on Justia Law

The case involves Nicholas Sterry, an inmate at the Moose Lake Correctional Facility, who filed a lawsuit against the Minnesota Department of Corrections (DOC) and Correctional Officer Ashley Youngberg. Sterry alleged that Youngberg sexually assaulted and harassed him while he was working in the prison kitchen. The DOC was aware of Youngberg's history of harassment but had not disciplined her prior to the incidents involving Sterry. Sterry's lawsuit included claims of battery, intentional and negligent infliction of emotional distress, and negligence under a theory of vicarious liability.The district court dismissed Sterry's claims, concluding that the DOC was immune from the suit under the Minnesota State Tort Claims Act because Youngberg was not acting within the scope of her employment when the alleged assault occurred. Sterry appealed this decision, and the court of appeals reversed the district court's ruling. The court of appeals found that Sterry's complaint alleged sufficient facts to survive the motion to dismiss, as it was consistent with common law principles of vicarious liability applicable to private employers.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court held that a state employer could be held vicariously liable for an employee’s intentional tort under the Minnesota State Tort Claims Act if the tort is related to the duties of the employee and occurs within work-related limits of time and place. The court also found that Sterry's complaint alleged sufficient facts to survive the DOC's motion to dismiss. The court concluded that Sterry's claim could allow a jury to find that Youngberg was acting within the scope of her employment when the alleged assault occurred, under circumstances where the DOC would be liable under common law for vicarious liability. View "Sterry v. Minnesota Department of Corrections" on Justia Law

The case revolves around the legality of the Emergency Management Act (the Act) in Minnesota, which allows the Governor to declare a peacetime emergency in response to a pandemic. The appellants, led by Drake Snell, challenged the Act, arguing that it did not authorize the Governor to declare a peacetime emergency in response to the COVID-19 pandemic and that it violated the nondelegation doctrine.Previously, the district court had dismissed Snell's case, concluding that the Act was a constitutional delegation of power to the Governor. The court of appeals affirmed this decision, stating that the Act granted the Governor the authority to declare a peacetime emergency in response to the COVID-19 pandemic. The court of appeals declined to consider Snell's argument that the Act violated the nondelegation doctrine, holding that it was not within the scope of remand.The Supreme Court of Minnesota affirmed the decision of the court of appeals. The court concluded that the Act does authorize a governor to declare a peacetime emergency in response to a public health crisis such as a pandemic. Furthermore, the court found that Governor Walz was authorized under the Act to declare a peacetime emergency in response to the COVID-19 pandemic. Lastly, the court rejected Snell's contention that the Act violates the nondelegation doctrine, stating that the Act does not represent an unconstitutional delegation of legislative authority. The court noted that the Act places durational limits on the powers and subjects them to termination by the Legislature, thus providing a check on the Governor's powers. View "Procaccini vs. Walz" on Justia Law

The case revolves around the interpretation of Minnesota Statutes section 171.177, subdivision 1, which requires law enforcement officers to inform individuals suspected of driving under the influence that refusal to submit to a blood or urine test is a crime. The respondent, Brian Matthew Nash, was pulled over for suspected impaired driving. After failing field sobriety tests, he was arrested and a state trooper obtained a search warrant for a blood or urine test. The trooper informed Nash that refusal to take a test is a crime, and Nash complied. His blood test revealed the presence of a controlled substance, leading to the revocation of his driving privileges.Nash sought judicial review of his license revocation, arguing that the trooper's advisory did not comply with the statutory requirement. The district court rejected Nash's arguments and sustained the revocation. On appeal, the court of appeals reversed, finding that the advisory given to Nash was misleading and an inaccurate statement of law.The Minnesota Supreme Court disagreed with the court of appeals' interpretation of the statute. The court held that the trooper's statement that "refusal to take a test is a crime" satisfied the advisory required by section 171.177, subdivision 1. The court reasoned that the statute does not require officers to inform drivers of all the elements and permutations of what is required before the state may take adverse action against them. The court reversed the decision of the court of appeals and remanded the case for consideration of the other issues raised by Nash in his appeal. View "Nash v. Commissioner of Public Safety" on Justia Law

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

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

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