Justia Government & Administrative Law Opinion Summaries

In 1984 and 1985, James Stevens injured both shoulders while working for S.T. Services and CNA Insurance Companies (collectively, S.T. Services). In 1994, Stevens and S.T. Services entered into a stipulation for settlement under which the parties agreed that Stevens was permanently totally disabled and would receive ongoing permanent total disability benefits. A compensation judge entered an award on the stipulation, and Stevens received benefits until 2011. Stevens began working as a plumbing specialist in 2008 and disclosed his job to S.T. Stevens but continued to receive workers’ compensation benefits. In 2011, S.T. Services filed a petition with the Workers Compensation Court of Appeals (WCCA) to discontinue paying benefits on the grounds that Stevens was no longer permanently totally disabled. A compensation judge granted S.T. Services’ petition to discontinue, and the WCCA affirmed. The Supreme Court reversed, holding that S.T. Services was not allowed by statute to file a petition to discontinue benefits under the circumstances of this case. View "Stevens v. S.T. Servs." on Justia Law

Employee filed an amended complaint seeking indemnity benefits and medical benefits from compensable injuries to his spine. Employee, however, decided not to pursue his indemnity claims at the compensation hearing. The compensation judge found that Respondent had sustained a Gillette injury to his spine and awarded him medical benefits. Employee subsequently sought reimbursement from Employer for attorney fees under Minn. Stat. 176.081. The compensation judge concluded that Employee was entitled to attorney fees under the statute. Employer appealed, arguing that to be eligible for attorney fees, section 176.081 requires an employee to address all related issues at the same time, and so when Employee pursued only a claim for medical benefits, he forfeited his statutory right to all attorney fees. The Supreme Court affirmed, holding that the compensation judge in this case followed the appropriate legal framework in determining the attorney fee award and did not abuse his discretion in the amount awarded. View "Braatz v. Parsons Elec. Co." on Justia Law

The Commissioner of Revenue notified JME of Monticello (JME), a waste management service provider, that it intended to audit JME’s waste management returns for a certain period. After the audit, JME was assessed approximately $87,000 in additional solid waste management taxes and interest. The Commissioner reached this determination after concluding that JME improperly calculated its waste management tax based on JME’s incorrect interpretation of Minn. Stat. 297H.04. JME appealed and brought a motion for summary judgment. The tax court upheld the Commissioner’s tax order. The Supreme Court affirmed, holding that the Commissioner correctly interpreted section 297H.04 and had correctly calculated the tax. View "JME of Monticello, Inc. v. Comm'r of Revenue" on Justia Law

After she was arrested for driving while impaired, Driver took a urine test, which revealed an alcohol concentration of twice the legal limit. Pursuant to the state’s implied consent law, Driver’s license was revoked. Driver sought judicial review, arguing that her license should not have been revoked because she acted out of necessity to protect herself from her violent husband. After an implied consent hearing, the district court upheld the revocation, concluding that necessity is not an affirmative defense that drivers may raise to challenge a civil license revocation. The Supreme Court affirmed, holding that the plain language of Minn. Stat. 169A.53(3) does not permit a driver to raise the affirmative defense of necessity at an implied consent hearing. View "Axelberg v. Comm'r of Pub. Safety" on Justia Law

Interstate Traffic Signs, Inc. (“Interstate”) rented traffic control equipment to contractors working on road construction projects. Prior to April 2010, Interstate charged sales tax on the equipment rental charge but did not charge tax on its delivery and “pick-up” charges, which included costs associated with retrieving and returning the rental equipment to Interstate. Beginning in April 2010, Interstate charged sales tax on the delivery charges but did not charge tax on pick-up charges. After an audit, the Commissioner of Revenue assessed an additional $37,838 in sales and use tax, determining that Interstate should have been charging sales tax on its pick-up charges. The tax court upheld the Commissioner’s assessment, concluding that the pick-up charge was subject to sales tax pursuant to Minn. Stat. 297A.62(1). The Supreme Court affirmed, holding that pick-up charges fall within the definition of “sales price” under section Minn. Stat. 297A.61(7), making those charges subject to sales tax under section 297A.62(1). View "Interstate Traffic Signs, Inc. v. Comm'r of Revenue" on Justia Law

After Scott Schuette, who was working as a police officer at the time, responded to an accident at the local high school he began experiencing mental health problems. Schuette was later diagnosed with post-traumatic stress disorder (PTSD). Schuette filed a claim petition seeking workers’ compensation benefits for PTSD. A compensation judge denied Schuette’s claim, finding that Schuette’s PTSD lacked a physical component and was thus not a compensable injury under Minnesota law. The Workers’ Compensation Court of Appeals (WCCA) affirmed, determining (1) to be compensable under Lockwood v. Independent School District No. 877, an injury must include a physical component; and (2) the compensation judge’s findings that Schuette’s PTSD did not result in a physical brain injury had substantial evidentiary support. The Supreme Court affirmed, holding (1) the compensation judge’s findings were not manifestly contrary to the evidence; and (2) applying the doctrine of stare decisis, Schuette’s request to overrule Lockwood was declined. View "Schuette v. City of Hutchinson" on Justia Law

The Commissioner of Revenue informed Sharon Soyka by a notice that it would file a tax return on her behalf for the 2008 tax year and asserting that Soyka owed $2,201 in income taxes, interest, and penalties. Exactly sixty-one days after the Commissioner mailed the notice, Soyka mailed her notice of appeal to the Minnesota Tax Court. The tax court dismissed Soyka’s appeal, concluding that it was untimely under Minn. Stat. 271.06(2), which generally requires a notice of appeal to be filed within sixty days after notice of an order by the Commissioner. At issue before the Supreme Court was whether, when the Commissioner serves notice of an order by United States mail, Minn. R. Civ. P. 6.05 extends the sixty-day statutory deadline for filing an appeal with the tax court. The Supreme Court reversed and directed the tax court to reinstate Soyka’s appeal, holding that Rule 6.05 applies and extends the statutory filing deadline by three days when the Commissioner serves the notice by United States mail. View "Soyka v. Comm'r of Revenue" on Justia Law

Appellant pleaded guilty to first-degree driving while impaired (DWI). After receiving a notice advising him of the County’s intent to forfeit his vehicle pursuant to Minn. Stat. 169A.63, Appellant sought a judicial determination of the forfeiture, arguing that he was entitled to a portion of the value of the forfeited vehicle under the motor vehicle exemption, Minn. Stat. 550.37(12)(a). The district court granted summary judgment for the County on behalf of respondent vehicle, holding that the motor vehicle exemption does not apply when a vehicle is forfeited pursuant to section 169A.63. The Supreme Court affirmed, holding that neither the motor vehicle exemption nor Minn. Const. art I, 12 applies to DWI forfeiture pursuant to section 169A.63. View "Nielsen v. 2003 Honda Accord" on Justia Law

Relator was injured while attending a required training session at the general office of her employer. A workers’ compensation judge denied Relator’s claim for benefits, finding that Relator’s injury did not arise out of and in the course of her employment. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that Relator’s injury arose out of the course of her employment, and therefore, her injury was compensable. The Supreme Court reversed and reinstated the decision of the compensation judge, holding that Relator did not meet her burden to prove her injury arose out of her employment, as required by statute. View "Dykhoff v. Xcel Energy" on Justia Law

After completing an audit of Taxpayers' joint income tax returns, the Commissioner of Revenue issued an order assessing additional taxes. That day, a revenue tax specialist sent Taxpayers an e-mail informing them of the existence of the order. The order was attached to the e-mail. Taxpayers claimed to have been unable to open the attachment containing the letter until sixty-six days after receiving the e-mail. The specialist claimed that he also sent the order by regular mail to Taxpayers' home address, but Taxpayers contended that a mailed copy of the order never arrived. Fifty-three days after Taxpayers opened the e-mail attachment and 119 days after they received the e-mail, Taxpayers filed an appeal with the tax court. The tax court dismissed the appeal as untimely, as it was filed after the sixty-day statutory deadline. The Supreme Court affirmed, holding (1) the tax court's findings that sending the order to Taxpayers electronically and by regular mail was sufficient were not clearly erroneous; and (2) the methods by which the Commissioner sent the order did not violate Taxpayers' due process rights. View "Turner v. Comm'r of Revenue" on Justia Law