Justia Government & Administrative Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
by
The Supreme Court held that Claimant was not entitled to workers' compensation benefits after the date on which he no longer had a diagnosis of post-traumatic stress disorder (PTSD) by a licensed professional using the most recent edition of the Diagnostic and statistical Manual of Mental Disorders (DSM-5).From 2007 to 2020 Claimant was employed as a Mower County Deputy Sheriff. From September 25, 2019 to March 30, 2021, Claimant had a diagnosis of PTSD by a licensed professional, making him eligible for workers' compensation benefits. In this action, Claimant argued that he was entitled to benefits after March 30, 2021, the date that he no longer had a diagnosis of PTSD, because he remained disabled from a mental illness. The compensation court awarded benefits from April 1, 2020 into the present. The court of appeals reversed in part, concluding that Claimant was not entitled to benefits after March 30, 2021. The Supreme Court affirmed, holding that Claimant was not entitled to workers' compensation benefits after March 30, 2021. View "Chrz v. Mower County" on Justia Law

by
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the rulings of the compensation judge finding that C. Jeremy Lagasse was entitled to contingent fees under Minn. Stat. 176.081, subd. 1(c) and that Larry Horton was entitled to partial reimbursement of fees under Minn. Stat. 176.081, subd. 7, holding that the WCCA incorrectly applied subdivision 1(c) in its standard of review.Horton, who was injured during his employment with Aspen Waste Systems and sought permanent partial disability (PPD) benefits through Aspen's insurer (Insurer), retained Lagasse to represent him in the matter. The compensation judge determined that Lagasse was entitled to contingent fees and that Horton was entitled to partial reimbursement of fees. The WCCA reversed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the WCCA incorrectly applied subdivision 1(c); and (2) the compensation judge and the WCCA incorrectly applied subdivision 7. View "Lagasse v. Horton" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals affirming in part and reversing and remanding in part the judgment of the district court denying Energy Policy Advocates' motion to compel and dismissing its civil action against seeking production of certain documents under the Data Practices Act, holding that this Court formally recognizes the common-interest doctrine in Minnesota.Energy Policy submitted document requests under the Data Practices Act, Minn. Stat. 130.01 through 13.90, related to climate-change litigation to the Office of the Attorney General. At issue on appeal was the existence and scope of the applicability of the attorney-client privilege to internal communication among attorneys in public law agencies, the common-interest doctrine, and the section of the Data Practices Act governing Attorney General data. The Supreme Court held (1) the common-interest doctrine is formally recognized in Minnesota; (2) the attorney-client privilege may apply to protect the confidentiality of internal communications among attorneys in public law agencies; and (3) the Legislature's classification of Attorney General data under Minn. Stat. 13.65, subdivision 1 as "private data on individuals" even when the data do not pertain to "individuals" is upheld. View "Energy Policy Advocates v. Ellison" on Justia Law

by
The Supreme Court affirmed in part and reversed and remanded in part the decision of the court of appeals reversing the district court's issuance of an alternative writ of mandamus to compel the Minneapolis Mayor and the Minneapolis City Council to comply and fund a minimum number of police officers, holding that the City Council was meeting its uncontested clear legal duty to fund at least 731 sworn police officers.A group of north Minneapolis residents sought a writ of mandamus to compel the Mayor and City Council to employ and fund at least 0.0017 sworn police officers per resident. The district court concluded that the Minneapolis City Charter created a clear legal duty to employ and fund 0.0017 officers per resident and that Defendants had failed to meet this duty. The court of appeals reversed, holding (1) the Mayor did not have a clear legal duty to employ a minimum number of officers, and (2) the City Council was satisfying its clear legal duty to fund 0.0017 officers per resident. The Supreme Court reversed and remanded in part, holding (1) the Mayor had a clear legal duty to employ 0.0017 sworn police officers per Minneapolis resident; and (2) the City Council was meeting its clear legal duty in this case. View "Spann v. Minneapolis City Council" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals holding that decisions made under Minn. Stat. 43A.33 are quasi-judicial administrative decisions subject to certiorari review by the court but reversed its holding that the Bureau of Mediation Services was a proper party to the appeal, holding that the Bureau was not a proper party to the certiorari appeal.When the Minnesota Department of Corrections sought certiorari review of an arbitrator's decision granting Appellant's appeal from the discharge of his employment at the Minnesota Department of Corrections, Appellant challenged the court of appeals' jurisdiction to hear the appeal, arguing that review must be undertaken by the district court. The court of appeals upheld the arbitrator's decision. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant and the Department were not parties to an arbitration agreement that invoked the judicial review procedures of the Uniform Arbitration Act; (2) the decision of an arbitrator appointed according to section 43A.33 is a quasi-judicial determination of an inferior tribunal reviewable via writ of certiorari at the court of appeals; and (3) the Bureau was not a proper party to this appeal because it had no legal or equitable interest in the outcome. View "Minn. Department of Corrections v. Knutson" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing the petitions for writs of mandamus filed by Minnesota Voters Alliance, et al. (collectively, the Alliance), holding that the Alliance failed to show the violation of a duty clearly established by law.In the mandamus petitions, the Alliance alleged that Ramsey County, Olmsted County, and other entities violated their statutory obligations for appointing members to absentee ballot board during the 2020 general election. Specifically, Alliance argued that the statutory requirements for election judges also apply to deputy county auditors. The district court dismissed the petitions, and the court of appeals affirmed. The Supreme Court affirmed, holding that the district court properly dismissed the Alliance's mandamus petitions. View "Minnesota Voters Alliance v. County of Ramsey" on Justia Law

by
The Supreme Court affirmed the decision of the tax court concluding that three clinics - Perham Clinic, Ottertail Clinic, and New York Mills Clinic - were not subject to property tax because they clinics were exempt under Minn. Stat. 447.31, subd. 6, holding that there was no error.The exemption at issue is provided for hospital districts. At issue on appeal was whether to classify the three medical clinics that were owned and operated by Perham Hospital District as taxable or exempt. Otter Tail County classified the clinics as commercial and thus subject to property tax, concluding that the tax exemption at issue was available to hospitals and not to clinics. After a trial, the tax court concluded that the clinics were exempt from tax under Minn. Stat. 447.31, subd. 6. The Supreme Court affirmed, holding that the tax court did not clearly err in finding that the District used the clinics to improve and run Perham Hospital during the tax years at issue. View "Perham Hospital District v. County of Otter Tail" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals reversing the decision of the Commitment Appeal Panel (CAP) granting Appellant's petition for provisional discharge, holding that the record evidence reasonably supported the CAP's decision that the Commissioner for the Department of Human Services failed to prove by clear and convincing evidence that the provisional discharge was not appropriate for Appellant under Minn. Stat. 253D.30.Appellant was adjudicated delinquent of multiple sexual offenses against minors and was later convicted of first-degree criminal sexual conduct against a minor. Appellant was indeterminately committed to the Minnesota Sex Offender Program (MSOP) as a sexually dangerous person and was later transferred to MSOP's Community Preparation Services. Appellant later petitioned for a provisional discharge. The Special Review Board (SRB) recommended that Appellant's request for a provisional discharge be granted and the CAP granted the petition. The court of appeals reversed. The Supreme Court reversed, holding that the record as a whole reasonably supported the CAP's findings and that the CAP did not clearly err by granting Appellant's petition for provisional discharge. View "In re Civil Commitment of Kenney" on Justia Law

by
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals holding that the City of Waconia's ordinance was subject to the procedural requirements of Minn. Stat. 462.357 for municipal zoning, including notice and a public hearing.After Appellants began building a dock extending from their lakeshore property into the lake the City adopted an ordinance that prohibited the construction of the dock. When the construction was nearly complete the City filed a complaint seeking a permanent injunction under the new ordinance to halt further construction and require the dock's removal. The district court granted summary judgment for the City. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Appellants' appeal was timely; (2) the City's ordinance was subject to the procedural requirements of section 462.357; and (3) because the City failed to comply with the procedural requirements of section 462.357, the ordinance was void, and the permanent injunction against Appellants was also void. View "City of Waconia v. Dock" on Justia Law

by
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) vacating factual findings made by the workers' compensation judge regarding the reasonableness and necessity of an employee's medical treatment for work-related injuries, holding that the WCCA erred.Respondent received a Gillette-style injury to her neck and upper spine. Respondent was later notified by her former employer, Appellant, that it would no longer approve reimbursement for certain injections. A compensation judge determined that the injections were neither necessary nor reasonable. The WCCA reversed, concluding that the decision of the compensation judge was not supported by substantial evidence in the record. The Supreme Court reversed, holding that the WCCA erred in (1) vacating the workers' compensation judge's factual findings; and (2) directing the compensation judge to consider whether Respondent's case presented rare circumstances warranting an exception from the treatment parameters. View "Leuthard v. Independent School District 912" on Justia Law