Justia Government & Administrative Law Opinion Summaries

Appellant submitted several requests for public government data from Hennepin County and the Hennepin County Sheriff’s Office (collectively, Respondents) under the Minnesota Government Data Practices Act. Respondents responded to all of Appellant’s requests except for a request asking that Respondents perform a computer-aided search of their stored e-emails using twenty separate search terms. Appellant filed a complaint alleging that Hennepin County had violated the Data Practices Act by failing to promptly and substantively respond to his data requests. An administrative law judge (ALJ) concluded that Hennepin County had violated the Data Practices Act and ordered it to produce all requested data. Respondents appealed the decision and obtained a stay from the ALJ pending appeal. Thereafter, Appellant filed a motion to lift the stay. The court of appeals denied the motion. The Supreme Court affirmed, holding that the ALJ’s decision to issue a stay pending appeal was not an abuse of discretion. View "Webster v. Hennepin County" on Justia Law

Respondent received a head injury during the course of her employment. Respondent filed a request with the workers’ compensation division seeking coverage for various treatments she was receiving for her injuries, including treatment for emotional and psychological conditions that allegedly developed from her injury. The compensation judge denied Respondent’s request for coverage of emotional and psychological conditions, finding that Respondent had not suffered a concussion and post-concussive syndrome. The compensation judge relied heavily on the opinion of a certain psychologist. The WCCA reversed and vacated the denial of coverage of the emotional and psychological conditions, concluding that there was not an adequate factual foundation for the psychologist’s opinion. The Supreme Court reversed, holding (1) the WCCA erred when it raised and ruled on the forfeited issue of whether a psychologist was competent to provide an expert opinion; (2) the WCCA erred when it reversed the compensation judge’s decision based primarily on the psychologist’s report; and (3) the WCCA erred when it reversed the compensation judge’s finding that Respondent did not suffer a concussion and post-concussive syndrome. View "Gianotti v. Independent School District 152" on Justia Law

The Mandels owned a home that, in 2011, was damaged by rainwater. Based on an post-casualty appraisal, the Mandels deducted $82,247 from their income reflected on their 2011 federal tax return. This deduction also affected the Mandels’ Minnesota taxable income. Following an audit, the Commissioner of Revenue disallowed much of the Mandels’ casualty-loss deduction by reducing the allowable tax deduction to the amount of the cost of the repairs the Mandels actually made to their home. The Mandels appealed. The tax court granted summary judgment in favor of the Commissioner. The Supreme Court affirmed, holding that the tax court did not err in determining that the Mandels’ post-casualty appraisal was not “competent” and did not err in granting the Commissioner’s motion for summary judgment. View "Mandel v. Commissioner of Revenue" on Justia Law

Minnesota Energy Resources Corporation (MERC) challenged the Commissioner of Revenue’s 2008 to 2012 valuation of its natural-gas pipeline distribution system. After a trial, the Commissioner determined (1) for each of the years from 2008 to 2011, the market value of MERC’s property was lower than the Commissioner’s valuation; and (2) for 2012, the Commissioner undervalued MERC’s pipeline distribution system. Both MERC and the Commissioner appealed. The Supreme Court reversed in part, holding (1) the tax court’s explanation of the beta factors it used to calculate MERC’s cost of equity was insufficient; and (2) the tax court evaluated MERC’s evidence of external obsolescence under the wrong legal standard. Remanded. View "Minnesota Energy Resources Corp. v. Commissioner of Revenue" on Justia Law

Dahmes Stainless, Inc. challenged the additional use taxes and interest assessed by the Commissioner of Revenue on components that Dahmes purchased to manufacture its products. In making the assessment, the Commissioner determined that Dahmes’s products constituted improvements to real property because they were common law fixtures. The tax court disagreed, concluding that Dahmes’s products were tangible personal property rather than improvements to real property, and therefore, the Commissioner erred by assessing use taxes. Dahmes subsequently filed a Minnesota Equal Access to Justice Act (MEAJA) application for attorney fees. The tax court awarded fees, concluding that the Commissioner’s position was not “substantially justified” by a “reasonable basis in law and fact” under Minn. Stat. 15.472(a). The Supreme Court affirmed, holding (1) Dahmes’s MEAJA application for attorney fees was timely filed; and (2) the tax court did not abuse its discretion by awarding attorney fees. View "Comm’r of Revenue v. Dahmes Stainless, Inc." on Justia Law

The Commissioner of Revenue disallowed certain charitable-contribution deductions claimed on an income tax return filed by Respondents. The tax court reversed and granted summary judgment in favor of Respondents. In doing so, the court excluded evidence offered by the Commissioner of Revenue regarding a computational error made in calculating Respondents’ tax liability and thus failed to correct Respondents’ tax liability to account for the Commissioner’s computational error. The Supreme Court affirmed, holding that (1) the tax court did not abuse its discretion in excluding the Commissioner’s evidence of a computational error; and (2) the tax court’s finding regarding Respondents’ tax liability was supported by the record. View "Antonello v. Comm’r of Revenue" on Justia Law

Robert Burks, a Metro Transit passenger, requested access to a recording of an exchange he had with a Metro Transit bus driver. Metro Transit, a division of Metropolitan Council, denied the request. Burks subsequently filed a complaint in district court requesting that the court require Metro Transit to release the video recording to him. The district court granted relief to Burks, determining that the recording was public data under the Minnesota Government Data Practices Act. The court of appeals affirmed. The Supreme Court affirmed, holding that Burks satisfied the prerequisites for access to the video recording because he was an “individual subject of the data.” View "Burks v. Metropolitan Council" on Justia Law

KSTP-TV (KSTP) requested videos that contained recordings of two incidents on Metro Transit buses. Metro Transit, a division of Metropolitan Council, had evaluated the conduct of the drivers of both buses but did not discipline either of them. Metro Transit refused KSTP’s requests, concluding that the videos contained private personnel data on the bus drivers, and therefore, the videos were exempt from disclosure. KSTP filed a complaint under the Minnesota Government Data Practices Act with the Office of Administrative Hearings. An administrative law judge concluded that the recordings were public data and, accordingly, that KSTP was entitled to the video data. The court of appeals affirmed. The Supreme Court reversed, holding (1) video data from public buses is personnel data under the Data Practices Act only if it is maintained exclusively because an individual subject of the data is a government employee; and (2) to determine whether particular data is personnel data under the Act, a government entity must classify the data at the time a request for access to the data is made. Remanded to the Office of Administrative Hearings for further proceedings. View "KSTP-TV v. Metropolitan Council" on Justia Law

The Minnesota Department of Human Services (DHS) assessed surcharges against seven hospitals and hospital systems (collectively, the Hospitals) on their net patient revenue under Minn. Stat. 256.957(2). The Hospitals appealed their surcharge assessments for various months, alleging that federal law preempted the surcharge to the extent it required them to pay a surcharge on revenues obtained from insurance carriers that participated in the Federal Employee Health Benefits Program and the TRICARE program. The Commissioner of DHS denied the claim. The court of appeals affirmed. The Supreme Court affirmed, holding that the surcharge was not preempted by federal law. View "In re Consolidated Hosp. Surcharge Appeals of Gillette Children’s Specialty Healthcare" on Justia Law

A School District expelled Student for six weeks after finding a pocketknife in a purse in her locker. The Commissioner of the Department of Education affirmed. The court of appeals reversed, concluding (1) Student did not willfully violate the District’s weapons policy when she unintentionally carried the pocketknife to school, and (2) the pocketknife’s presence in Student’s locker did not bring Student or others into danger. The Supreme Court affirmed, holding (1) the record did not support the conclusion that Student deliberately and intentionally violated the District’s weapons policy; and (2) the record did not contain substantial evidence that Student exposed anyone to actual or even probable harm. View "In re Expulsion of A.D. from United S. Central Pub. Schs." on Justia Law