Ninetieth Minnesota State Senate v. Dayton

Ninetieth Minnesota State Senate v. Dayton
Court	Minnesota Supreme Court
Full case name	The Ninetieth Minnesota State Senate, The Ninetieth Minnesota State House of Representatives v. Mark B. Dayton, In his official capacity as Governor of the State of Minnesota, Myron Frans, In his official capacity as Commissioner of the Minnesota Department of Management and Budget
Decided	November 16, 2017 (2017-11-16)
Case history
Appealed from	Ramsey County District Court
Court membership
Judges sitting	Chief Justice Lorie Skjerven Gildea, Barry Anderson, David Lillehaug, Natalie Hudson, Margaret Chutich, Anne McKeig
Case opinions
Decision by	Lorie Skjerven Gildea
Dissent	Barry Anderson

The Ninetieth Minnesota State Senate, et al., v. Mark B. Dayton, in his official capacity as Governor of the State of Minnesota, et al., 62-CV-17-3601, was a Minnesota Supreme Court case in which the Court ruled that governor Mark Dayton's line item vetoes of appropriations for the Minnesota Senate and Minnesota House of Representatives were a lawful exercise of his authority granted by Article IV, Section 23 of the Minnesota Constitution. The Court also ruled that since the state legislature had access to other funding in order to continue operating as a fully functioning and independent branch of government, the governor's vetoes did not effectively abolish the legislature and thereby violate Article III of the state constitution. Additionally, the Court ruled that the judicial branch did not have the constitutional authority to order funding without a corresponding budgetary appropriation. The Supreme Court's ruling overturned an earlier ruling by a Ramsey County court judge. The case marked the first time in which the Minnesota Supreme Court was asked to resolve a lawsuit brought by one branch of government against another.

Background

The Minnesota Legislature adjourned its regular session in 2017 on May 22^[1] with significant amounts of unfinished business; it had failed to pass any omnibus spending bills establishing the state's budget for the next two years.^[2] Legislative leaders came to an agreement with Governor Mark Dayton to call a special session immediately following the adjournment of the regular session to address this unfinished business.^[2] Just before the conclusion of the special session, the legislature passed a series of appropriations bills for the state's budget.^[2] After the four-day special session had adjourned on May 26,^[3] Dayton allowed the bills to become law, but line item vetoed appropriations funding the legislature.^[2] Dayton issued a letter explaining his vetoes; he sought to avoid a government shutdown while convincing legislative leaders to renegotiate provisions of the budgetary bills.^[2] Legislative leaders refused to negotiate and sued Dayton, arguing that his vetoes had the effect of abolishing the legislature.^[2]

Lower court ruling

On July 19, Ramsey County court Chief Judge John Guthmann ruled the Governor Dayton's vetoes were unconstitutional by violating the Minnesota Constitution's Separation of Powers clause by effectively abolishing the legislature.^[4] Guthmann indicated that a main reason that Dayton's vetoes were problematic was that Dayton's did not actually object to the appropriations themselves; the purpose of the vetoes was to convince legislators to renegotiate other appropriations and policies unrelated to the legislature's funding.^[4] Upon news of the ruling, Dayton immediately indicated his intent to appeal the decision.^[4]

Ruling of the Supreme Court

In a majority opinion, Chief Justice Lorie Skjerven Gildea stated that Dayton's actions were within his constitutional authority as governor.

On September 9, the Minnesota Supreme Court made a preliminary ruling that when Gov. Dayton vetoed appropriations for the legislature, he did not violate his constitutional authority to make line item vetoes for budgetary appropriations.^[5] The Court also ordered the parties into talks with a mediator.^[5] Additionally, the Court strongly encouraged the parties to find a political solution to resolve this dispute.^[5] The Court did not remand the case back to the lower Ramsey County court, thereby giving the Court the ability to make a further ruling if the attempts at mediation were unsuccessful.^[5]

The two parties met with mediator Rick Solum over the course of two days (September 21 and 22), but Solum determined that the legislative leaders and Governor Dayton had irreconcilable differences and that their impasse could not be overcome without a further ruling by the Court.^[6] Following the impasse, Dayton claimed that legislative leaders had "lied to" Minnesotans and the Supreme Court about the legislature's ability to finance its operations until the beginning of the upcoming legislative session to begin in February 2018.^[6] One week later, the Supreme Court ordered legislative leaders to submit a full report of their current financial situation regarding funding on hand and their ability to continue to function.^[7]

On November 16, the Court issued its final ruling and upheld Governor Dayton's vetoes.^[8] The Court also stated that the Legislature had access to sufficient funding to continue to exist until the beginning of the next legislative session; consequently, Dayton's actions remained within his constitutional authority.^[8] The Court's ruling was issued by a 5–1 majority; Justice Barry Anderson dissented, and Justice David Stras recused himself from the case.^[8] Additionally, in the Court's ruling, Chief Justice Lorie Skjerven Gildea stated that the judicial branch had no authority to appropriate funding without a legislative counterpart.^[8] The Court declined to take a stance on the matter of whether Dayton's veto of the legislative funding was coercive; the legislature would be able to continue to operate until the next legislative session when a political solution to this dispute can be reached.^[8] In the majority ruling for the Court, Chief Justice Gildea acknowledged the unprecedented nature of the case saying, "For the first time in Minnesota history, we are asked to resolve a lawsuit brought by one of our coordinate branches of government—the Legislative Branch—against our other coordinate branch of government—the Executive Branch."^[9]

Reactions to the ruling

Minnesota Governor Mark Dayton

Governor Mark Dayton applauded the Supreme Court's ruling and cast blame on Republican legislative leaders for initiating the lengthy and expensive legal dispute.^[8] The final costs of legal fees are expected to be several hundred thousand dollars and be borne by Minnesota taxpayers.^[10] Republican Speaker of the House Kurt Daudt disputed suggestions that the Court’s ruling was a winning proposition for Governor Dayton; he saw the matter as unsettled.^[8] Paul Gazelka, the Senate Majority Leader, expressed dismay at the news of the Court’s ruling, saying that the Legislature would be forced to take extreme measures to keep itself funded, and suggested that this put the Legislature and the State of Minnesota in a precarious situation.^[8] Daudt said that this unprecedented financial situation put the Senate at risk of defaulting on scheduled debt payments for the Senate’s office building.^[8] After the Legislature reconvened its regular session in 2018, the Legislature voted to restore the funding which Dayton had vetoed.^[11] On February 26, Dayton signed the bill into law.^[12]

References