Justia Government & Administrative Law Opinion Summaries

At issue in this case was whether the workers' compensation courts had the authority to hear a petition filed by Insured to determine whether Insurer had a duty to defend and indemnify Insured under a policy for workers' compensation insurance. Insurer moved to dismiss Insured's petition, arguing that the compensation judge did not have subject matter jurisdiction to hear the petition because it asserted a breach of contract claim rather than one arising under the workers' compensation laws. The compensation judge disagreed and denied Insurer's motion to dismiss. The workers' compensation court of appeals (WCCA) affirmed, concluding that Insured was seeking a declaration that its insurance coverage with Insurer was still "in effect," a question within the compensation judge's authority to decide. The Supreme Court affirmed, holding that the workers' compensation courts had jurisdiction to decide the issues presented in Insured's petition for declaration of insurance coverage, as the real nature of the claim was whether Insured's insurance coverage was in effect, a question that was within the authority of the compensation judge to answer. View "Giersdorf v. A & M Constr., Inc." on Justia Law

A compensation judge found Respondent was barred from receiving workers' compensation benefits because his written notice of injury, given nearly two years after his last day of work, was not timely and because Respondent's employer did not have actual knowledge that Respondent's back problems were work-related. The workers' compensation court of appeals (WCCA) reversed, concluding that a reasonable person in Respondent's position would not have known his injury was compensable until Respondent's doctors provided written reports to Respondent's attorney establishing a relationship between Respondent's back problems and his job duties. The Supreme Court reversed the WCCA and affirmed the denial of benefits, holding (1) the WCCA erred in overturning the compensation judge's finding that Respondent failed to give timely notice to his employer of his work-related injury; and (2) the compensation judge did not err in finding that the employer did not have actual knowledge of such an injury. View "Anderson v. Frontier Commc'ns" on Justia Law

County filed a claim for reimbursement with City, alleging that City had overcharged County for sewer and water services. Following consideration at a city council meeting, City denied County's claim. County subsequently sued City in district court. City moved for summary judgment, asserting that review of its decision was limited to certiorari review under Minn. Stat. 606 and that County's failure to bring a timely certiorari petition deprived the district court of subject matter jurisdiction. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) City's decision to deny the refund was a quasi-judicial decision, and therefore, the exclusive method for reviewing City's decision was through a writ of certiorari under chapter 606; and (2) accordingly, the district court lacked subject matter jurisdiction to hear County's claim.

Following a trial, the Minnesota tax court affirmed an order of the Commissioner of Revenue calculating the value of the estate of Ruth Singer and assessing the estate the sum of $69,679 in taxes and interest. The Supreme Court affirmed, holding (1) the tax court had jurisdiction; (2) Minn. Stat. 291.215, which provides that any elections made in valuing the federal gross estate shall be applicable in valuing the Minnesota gross estate, is constitutional, even if it is not uniform or its application results in a regressive tax; (2) the tax court did not err in affirming the Commissioner's assessment; (3) the federal estate tax law does not preempt Minnesota's estate tax law; and (4) the tax court properly determined that the value of Singer's home should be included in her gross estate.

When Appellant Amanda Tatro was a junior in the mortuary science program at the University of Minnesota, she posted statements on Facebook which she described as "satirical commentary and violent fantasy about her school experience." Following a hearing, the Campus Committee on Student Behavior (CCSB) found Tatro had violated the student conduct code and academic program rules governing the privilege of access to human cadavers, which prohibited "blogging" about cadaver dissection. CCSB imposed sanctions, including a failing grade for an anatomy laboratory course. The University Provost affirmed the sanctions. Tatro appealed, arguing that the University violated her constitutional rights to free speech. The court of appeals upheld the disciplinary sanctions. The Supreme Court affirmed, holding that the University did not violate the free speech rights of Tatro by imposing sanctions for her Facebook posts that violated academic program rules where the academic program rules were narrowly tailored and directly related to established professional conduct standards.

Relator 78th Street OwnerCo, LLC, the owner and landlord of a hotel, filed petitions contesting Hennepin County's assessments of its property for property taxes payable in 2008 and 2009, along with the taxes due in 2008 and 2009. The tax court dismissed both petitions for failure to comply with the statutory sixty-day rule, which states that failure to submit required documentation within sixty days results in automatic dismissal of the petition, because each petition did not include a copy of 78th Street's lease and a calculation of percentage rent paid, and the 2008 petition did not include a rent roll/tenant list. The Supreme Court affirmed, holding (1) 78th Street's argument that the information it did not submit was not relevant to the calculation of property tax for its hotel property was unavailing because a taxpayer is not permitted to evaluate relevancy under the sixty-day rule, and neither the relevancy standard nor the unavailability exception excuses a taxpayer from providing required information that is available to the taxpayer; and (2) neither version of the sixty-day rule was unconstitutionally vague as applied to 78th Street.

Relator Minh Nguyen was injured after falling from a ladder while employed by Audio Communications. Nguyen filed an amended petition to seek benefits for permanent total disability, but his petition did not seek to establish the date of onset of permanent disability. After a compensation judge awarded Nguyen benefits from March 4, 2008, for permanent total disability, Audio Communications petitioned the compensation judge for determination of the date of onset. The judge found that Nguyen became permanently and totally disabled as of March 1, 2007. Nguyen then petitioned to require Audio Communications to pay the attorney fees he incurred in partially succeeding in opposing Audio Communications' petition for determination of the date of onset of permanent total disability. The compensation judge denied the claim for attorney fees, and the WCCA affirmed. The Supreme Court affirmed, holding that an employer is not liable for the attorney fees incurred by an injured employee in successfully defending against the employer's petition to offset social security disability benefits paid to the employee against benefits paid by the employer for permanent total disability, where the employee's attorney fees can be paid from ongoing workers' compensation benefits paid to the employee.

Appellant was employed by School District for three school years as the activities director and for one school year as interim middle school principal. Subsequently, School District terminated Appellant's employment. Appellant filed a grievance on the ground that he was a continuing-contract employee and entitled to continuing contract rights under Minn. Stat. 122A.40. School District denied the grievance. The court of appeals affirmed. At issue on appeal was whether Appellant's employment by the school district as an activities director fell within the definition of a "teacher" under section 122A.40, which would determine whether he was entitled to continuing-contract rights under the statute. The Supreme Court affirmed, holding that Appellant was not a professional employee required to hold a license from the state department and therefore was not a "teacher" within the meaning of the continuing-contract statute.

Relators, two businesses, sought certiorari review of the Minnesota Tax Court's determination of the fair market value on the 2007, 2008, and 2009 assessment dates for an office building located in Ramsey County. At trial, the tax court heard expert testimony from Relators' appraiser and Ramsey County's appraiser. After trial, the County submitted a post-trial brief that argued for higher property valuations than the market values assigned to the property by either appraiser. The court then adopted, verbatim, the County's proposed market valuations on the three assessment dates. The Supreme Court reversed the tax court's decision, holding that the court's findings and conclusions failed to meet the standard articulated in Eden Prairie Mall, LLC v. County of Hennepin, which states that when the tax court rejects the testimony of both appraisers, the court must give a basis for its calculations and provide an adequate explanation and factual support in the record for its conclusions.

The City of Red Wing enacted an ordinance requiring inspections of rental property before landlords could obtain operating licenses and allowing the City to conduct inspections by application for and judicial approval of an administrative warrant in the absence of landlord or tenant consent. Appellants in this case were nine landlords and two tenants who refused to consent to inspections of their properties and successfully challenged three separate applications for administrative warrants. At the same time Appellants opposed the City's application, they filed a separate declaratory judgment action seeking to have the rental inspection ordinance declared unconstitutional. The court of appeals affirmed the district court's dismissal of the declaratory judgment action for lack of standing, concluding that Appellants had not alleged an injury that was actual or imminent. The Supreme Court reversed, concluding that the challenge to the constitutionality of the rental inspection ordinance presented a justiciable controversy. Remanded.