Justia Government & Administrative Law Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeals concluding that the Minnesota Public Utilities Commission erred by approving affiliated-interest agreements under Minn. Stat. 216B.48, subdivision 3 without first considering whether environmental review was necessary, holding that the Commission was not required to conduct review under Minn. Stat. Ch. 116D before approving affiliated-interest agreements that govern construction and operation of a Wisconsin power plant by a Minnesota utility.At issue was whether chapter 116D - the Minnesota Environmental Protection Act (MEPA) - requires the Commission to conduct an environmental review before deciding to approve affiliated-interest agreements that will govern the construction and operation of a power plant in a neighboring state. The Commission in this case that its jurisdiction was limited to power plants proposed to be built in Minnesota, and therefore, the power plant in this case was not subject to Minnesota's permitting and environmental review regulations. The court of appeals reversed. The Supreme Court reversed, holding that MEPA did not apply. View "In re Minnesota Power's Petition for Approval of the EnergyForward Resource Package" on Justia Law

The Supreme Court reversed the conclusion of the court of appeals that this appeal was moot but affirmed the court's decision dismissing the appeal, holding that Appellant, a Level III predatory offender serving the conditional release term of his sentence, was not entitled to a writ of habeas corpus.Before the time that Appellant filed this habeas petition, his conditional release had been revoked on five separate occasions. An order was later entered preventing the Department from using Appellant's inability to maintain an agent-approved placement due to his epilepsy as a basis for future revocations of his conditional release. In his habeas corpus petition, Appellant argued that his epilepsy was the sole reason for the revocation of his conditional release and continued incarceration. During the appeal from the denial of relief the Department released Appellant from prison. The court of appeals determined that Appellant's release from prison rendered his appeal moot. The Supreme Court affirmed in part and reversed in part, holding (1) the mootness exception applied in this case; and (2) The Department did not violate Appellant's substantive due process rights or the rule of law set forth in State ex rel. Marlowe v. Fabian, 755 N.W.2d 792 (Minn. App. 2008). View "State, ex rel. Young v. Schnell" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that the factual findings of the Minnesota Pollution Control Agency were "insufficient to facilitate judicial review" of a permitting decision, holding that the Agency is not required under the Clean Air Act, 42 U.S.C. 7401-7671q, and its applicable regulations to investigate allegations of "sham" permitting when a source first applies for a synthetic minor source permit.At issue was whether the Agency was required to investigate allegations of sham permitting when consider whether to approve the air-emissions permit of PolyMet Mining, Inc. for a proposed mine. Respondents challenged the Agency's decision to issue the synthetic minor source permit, asserting that the Agency failed to conduct an adequate investigation into whether PolyMet intended to operate within the limits of the permit or whether it was instead seeking a sham permit. The court of appeals concluded that the Agency's short response to the concerns of Respondents was not the "hard look" required under the Minnesota Administrative Procedure Act, Minn. Stat. 14.69. The Supreme Court reversed, holding that the applicable federal regulations and guidance contemplate retrospective enforcement after the applicant has obtained a synthetic minor source permit and do not mandate prospective investigation. View "In re Issuance of Air Emissions Permit No. 13700345-101 for PolyMet Mining, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the determination of the district court that the Freeborn County Board of Commissioners acted arbitrarily when it set the 2019 salary of the Freeborn County Sheriff at $97,020, holding that the district court did not clearly err.In the salary appeal, the district court concluded that the Board acted arbitrarily and without sufficiently taking into account the responsibilities and duties of the sheriff's office because the testifying commissioners did not explain why they decided on a salary of $97,020. The court of appeals reversed, concluding that the district court's findings and conclusions were clearly erroneous. The Supreme Court reversed, holding that the district court did not clearly err in setting aside the Board's salary decision because there was reasonable support in the record for the court's determination that the Board's salary decision was arbitrary. View "In re Year 2019 Salary of Freeborn County Sheriff" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court holding that the adoption of a comprehensive plan is not a proper subject of a claim under the Minnesota Environmental Rights Act (MERA), Minn. Stat. 116B.01-.13, holding that adoption of a comprehensive plan can be the subject of a MERA claim and that Appellants' allegations were sufficient to state a claim under MERA.This appeal centered a claim challenging the City of Minneapolis's 2040 Comprehensive Plan, alleging that the City's adoption of the Plan violated the state's environmental law. The district court dismissed the complaint, concluding that because comprehensive plans are specifically exempt from environmental review under Minn. R. 4410.4600, comprehensive plans are also exempt from judicial review under MERA. The court of appeals affirmed. The Supreme Court reversed, holding (1) rule 4410.4600 does not exempt comprehensive plans from environmental review under MERA; and (2) the facts alleged in the complaint, if true, state a claim upon which relief can be granted. View "State by Smart Growth Minneapolis v. City of Minneapolis" on Justia Law

The Supreme Court held that groundwater is a Class 1 water under Minnesota law and therefore subject to secondary drinking water standards promulgated by the United States Environmental Protection Agency (EPA).In 2018, the Minnesota Pollution Control Agency (MPCA) issued a National Pollutant Discharge Elimination System/State Disposal System permit to United States Steel Corporation (U.S. Steel) governing U.S. Steel's Minntac Tailings Basin Area in Mountain Iron and setting a groundwater sulfate limit of 250 mg/L at the facility's boundary that U.S. Steel must meet by 2025. On appeal, U.S. Steel argued that the MPCA did not have the authority to impose the sulfate standard in the permit because the EPA's secondary drinking water standards apply only to bodies of water classified as Class 1 waters and that groundwater is not classified as Class 1. The court of appeals agreed and reversed the MPCA's decision. The Supreme Court reversed, holding (1) groundwater is a Class 1 water under Minnesota law; and (2) therefore, the MPCA correctly exercised its authority by applying the Class 1 secondary drinking water standards to the permit. View "In re Reissuance of NPDES/SDS Permit to United States Steel Corp." on Justia Law

The Supreme Court affirmed the order of the tax court dismissing Relator's appeal of an tax order sent by the Department of Revenue by regular mail, holding that sending a tax order by regular mail provides constitutionally sufficient notice.The Department sent Relator a tax order assessing sales and use taxes covering a three-year period. The order was sent by regular mail, as authorized by Minn. Stat. 270C.33, subd. 8. Relator appealed, asserting that he only became aware of the tax liability when his bank account was levied on by the Commissioner. The tax court granted the Commissioner's motion to dismiss. The Supreme Court affirmed, holding that Relator's notice was constitutionally sufficient. View "Olson v. Commissioner of Revenue" on Justia Law

The Supreme Court reversed the opinion of the court of appeals affirming the judgment of the district court denying Appellant's petition for a writ of mandamus to order the Dakota County Sheriff to issue Defendant a permit to carry a firearm, holding that Appellant satisfied all the requirements for a writ of mandamus.In 1998, Appellant was adjudicated delinquent for theft of a motor vehicle. In 2014, the Legislature removed that offense from the definition of "crime of violence" in Minn. Stat. 624.712, subd. 5. In 2017, Appellant applied to the Dakota County Sheriff's Office for a permit to carry a firearm. The Sheriff issued Appellant a permit. When the Sheriff learned of Appellant's 1998 juvenile adjudication, however, he voided Appellant's permit. Appellant petitioned for a writ of mandamus directing the sheriff to issue a permit. The district court denied the petition. The court of appeals affirmed. The Supreme Court reversed and issued a writ of prohibition, holding that the 2014 amendment applied to Defendant, and therefore, Defendant was entitled to a permit. View "Tapia v. Leslie" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court that non-homestead life estates should not be included in Marvin Schmalz's assets, holding that the term "individual" in Minn. Stat. 256B.056, subd. 4a applies only to the applicant for medical assistance.Esther Schmalz was living at a long-term-care facility when she submitted an application for medical assistance for long-term-care benefits. As part of the assessment of her husband Marvin's assets, Renville County Human Services (RCHS) included Marvin's portion of several non-homestead life estate interests that he and Esther owned. Esther appealed, arguing that the life estates should not be included in the total amount of assets that Marvin may retain. The human services judge concluded that RCHS properly denied Esther's application for medical assistance based on the inclusion of the life estate assets owned by Marvin. The Commissioner of Minnesota Department of Human Services adopted the human services judge's recommendation. The district court concluded that the non-homestead life estates should not be included in Marvin's assets, ruling that the term "individual" in section 256B.056, subd. 4a included Marvin. The Supreme Court reversed, holding that an "individual" in the statute refers to the medical assistance applicant and not a community spouse. View "In re Schmalz" on Justia Law