Articles Posted in Government & Administrative Law

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The Supreme Court reversed the decisions of the court of appeals and district court that Respondent’s due process rights were violated when he was read an inaccurate implied consent advisory after his arrest on suspicion of driving while impaired. Respondent refused to submit to either a urine or a blood test. Thereafter, the Commissioner of Public Safety revoked Respondent’s driver’s license for refusing to submit to a test. Relying on McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991), the district court rescinded the revocation after finding that the implied consent advisory violated Respondent’s due process rights because it incorrectly stated that refusal to submit to a urine test was a crime. The court of appeals affirmed on the basis that the threat of legally impossible criminal charges for refusal to submit to a urine test violated due process. The Supreme Court reversed, holding that because Respondent did not rely on the implied consent advisory to his detriment, and instead refused to submit to testing, no due process violation occurred under McDonnell. View "Johnson v. Commissioner of Public Safety" on Justia Law

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Appellant failed to establish that he was prejudiced by the implied consent advisory read to him after he was arrested on suspicion of driving while impaired, and therefore, Appellant was not entitled to a rescission of his license revocation under McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991). Appellant submitted to a blood test, and the test results showed an alcohol concentration above the legal limit. Appellant’s driver’s license was subsequently revoked. The district court sustained the revocation on the basis that Appellant voluntarily consented to the blood test. The Supreme Court affirmed, holding that Appellant was not entitled to a rescission of his license revocation under McDonnell because he did not even claim, much less establish, that he prejudicially relied on the implied consent advisory. View "Morehouse v. Commissioner of Public Safety" on Justia Law

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At issue was whether Hennepin County properly refused to comply with part of Appellant’s government-data request under the Minnesota Government Data Practices Act (the Data Practices Act). The Supreme Court held (1) there was substantial evidence in the record to support the Administrative Law Judge’s (ALJ) conclusion that Hennepin County’s established procedures do not “insure” appropriate and prompt responses to requests for government data under the Data Practices Act; (2) there was not substantial evidence in the record to support the ALJ’s conclusion that the County did not maintain records containing government data in an arrangement and condition making them easily accessible for convenient use in violation of the Data Practices Act; and (3) the Court did not have appellate jurisdiction to decide whether Appellant’s request was valid or whether the County may refuse to comply with a request that the County deems “unduly burdensome.” View "Webster v. Hennepin County" on Justia Law

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In this case regarding the determination of the tax court valuing Minnesota Energy Resources Corporation’s (MERC) natural gas pipeline distribution system for the years 2008 through 2012, the Supreme Court affirmed the decision of the tax court on remand, holding that the tax court followed the Court’s instructions on remand and properly applied the Court’s clarified standard to MERC’s claim of external obsolescence. On remand, the tax court found that MERC failed to demonstrate that external obsolescence affected the value of its property. The Supreme Court affirmed, holding (1) the tax court correctly evaluated whether MERC’s evidence of external obsolescence was credible, reliable, and relevant; and (2) the tax court’s decision was justified by the evidence and in conformity with law. View "Minnesota Energy Resources Corp. v. Commissioner of Revenue" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the order of the Commissioner of Human Services, which affirmed the determination by the Minnesota Department of Human Services that Yasmin Salim wrongfully obtained public assistance for Kind Heart Daycare, Inc. in violation of Minn. Stat. 256.98(1)(3). Kind Heart had submitted bills to Blue Earth County under the state’s Child Care Assistance Program (CCAP) representing that children from low-income families were present at Kind Heart when they were, in fact, absent or no longer enrolled in the daycare. The Department disqualified Salim from providing daycare services and revoked Kind Heart’s license. The Supreme Judicial Court held (1) the Commissioner erred in determining that Salim and Kind Heart were not entitled to CCAP payments; and (2) any errors on the part of the Department or the Commissioner were corrected, independently re-evaluated, or harmless. View "In re Appeal by Kind Heart Daycare, Inc." on Justia Law

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The Supreme Court affirmed the decision of the Saint Paul City Council upholding an abatement order issued by the City of Saint Paul requiring Appellant to comply with Minn. Stat. 168.10(1)(e), which requires collector vehicles to be “screened from ordinary public view.” Although Appellant covered his collector vehicles with tarps and constructed a portable fence across the front of the area where he parked the vehicles, the vehicles were still partially visible from public areas. The City Council concluded that the tarps and fence did not satisfy the screened-from-ordinary-public-view requirement. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Appellant violated the collector-vehicle-storage statute by failing to screen his collector vehicles and their outdoor storage areas from ordinary public view; and (2) the City Council’s decision to uphold the abatement order was not unreasonable, arbitrary, or capricious. View "Appeal of Krenik to a Vehicle Abatement Order" on Justia Law

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The Supreme Court affirmed the judgment of the Workers’ Compensation Court of Appeals (WCCA) in this workers’ compensation case, holding that the compensation judge applied the wrong legal standard in granting Employer’s petition to discontinue Employee’s rehabilitation services. Relying on the definition of “qualified employee” in an administrative rule, the compensation judge concluded that because Employee had obtained “suitable gainful employment” she was no longer eligible for rehabilitation benefits. The WCCA reversed, ruling that an employer must show “good cause” before terminating rehabilitation benefits. The Supreme Court agreed, holding that when an individual receiving rehabilitation benefits no longer meets the definition of a “qualified employee,” a compensation judge may not terminate benefits without first applying the good-cause standard. View "Halvorson v. B&F Fastener Supply" on Justia Law

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Minnesota’s water’s edge rule, Minn. Stat. 290.17(4)(f), does not prohibit the inclusion in “net income” the income of a foreign entity that elects under federal tax law to be disregarded as a separate entity. At issue in this appeal from the tax court was whether the consequences of an election made under federal tax law by a foreign entity owned by Ashland Inc., a domestic unitary business, must be recognized in determining Ashland’s Minnesota tax liability. The Commissioner of Revenue concluded that the income and apportionment factors of the foreign entity were improperly included in Ashland’s combined return and so excluded them in calculating Ashland’s Minnesota tax liability. The tax court granted Ashland’s motion for summary judgment, concluding that the consequences of the federal election were properly included in the determination of Ashland’s net income on its Minnesota tax returns. The Supreme Court affirmed, holding that the tax court did not err in its conclusion. View "Ashland Inc. & Affiliates v. Commissioner of Revenue" on Justia Law

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The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) to reverse the denial of Respondent's claim for ankle-fusion surgery. Respondent, who was injured during the course of her employment, filed a workers’ compensation claim petition for ankle-fusion surgery. The compensation judge denied Respondent’s claim for the ankle-fusion surgery. The WCCA reversed. Respondent’s employer appealed, arguing that the WCCA exceeded the scope of its review when it reversed the compensation judge’s decision to deny benefits to Respondent. The Supreme Court reversed, holding that the compensation judge’s finding was “supported by evidence that a reasonable mind might accept as adequate,” and therefore, the WCCA clearly and manifestly erred in rejecting this finding. View "Mattick v. Hy-Vee Foods Stores" on Justia Law

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The Workers’ Compensation Court of Appeals (WCCA) clearly and manifestly erred by rejecting the findings of the compensation judge and overturning the determination that Respondent failed to establish her claim for benefits by a preponderance of the evidence. Respondent filed a claim for workers’ compensation benefits after falling and injuring her shoulder while rushing up a staircase at the workplace of her employer. The compensation judge denied the claim. The WCCA reversed the compensation judge’s decision. The Supreme Court reversed the WCCA’s decision and reinstated the compensation judge’s decision, holding (1) the WCCA impermissibly substituted its own view of the evidence for that of the compensation judge; and (2) the findings of the compensation judge were supported by substantial evidence that a reasonable mind would accept as adequate. View "Kubis v. Community Memorial Hospital Ass’n" on Justia Law