Minnesota Legislature v. Dayton
 | |
| Minnesota Legislature v. Dayton | |
| Important Dates | |
| Filed: June 13, 2017 Temporary injunction granted: June 26, 2017 Declaratory judgment issued: July 19, 2017 Appeal granted: July 26, 2017 Minnesota Supreme Court Order: September 8, 2017 | |
| Outcome | |
| Minnesota Supreme Court upheld Dayton's vetoes and refused to reinstate legislative funding. | |
| Vote | |
| 5-1 | |
Minnesota Legislature v. Dayton was filed on June 13, 2017, with the Ramsey County District Court. The Minnesota State Legislature filed the case following Gov. Mark Dayton’s (D) line-item vetoes of the legislature's 2018 and 2019 operating budget appropriations. The legislature argued that Dayton’s vetoes of legislative funding “violated the separation of powers clause of the Minnesota Constitution … [and] impermissibly control, coerce, and restrain the action of the legislature in the exercise of its official and constitutional powers.”[1] In response, Dayton claimed that as governor he had “explicit and unqualified authority under the Minnesota Constitution to veto any line item of appropriation.”[2]
On June 26, the parties jointly asked the district court to issue an injunction providing for temporary continued funding of the legislature.[3][4] The district court agreed, issuing a temporary injunction to maintain the legislature's funding for a short time.[5] The parties said they would request accelerated review of the case by the Minnesota Supreme Court. Then, on July 19, 2017, the district court issued a declaratory judgment in favor of the legislature, holding that Dayton's vetoes were unconstitutional.[6] On July 24, 2017, Dayton notified the court that he would appeal the judgment.[7] The Minnesota Supreme Court heard the appeal on August 28, 2017.[8]
On September 8, 2017, the supreme court ordered Dayton and the legislature into mediation. On September 22, 2017, the parties ended mediation without reaching a deal. The legislature stated that Dayton had ended the talks. Dayton stated that the legislature had access to additional funding sources it had not originally disclosed.[9] On September 29, the Minnesota Supreme Court ordered both parties to file reports on the Legislature's financial situation.[10]
On October 25, 2017, the legislature asked the state district court to enforce its July 2017 judgment in the legislature's favor, despite the pending supreme court appeal.[11]
On November 16, 2017, the Minnesota Supreme Court ruled that Dayton's line-item vetoes were constitutional and that the Minnesota Legislature had enough funding to continue to operate through the beginning of the next legislative session in February 2018.[12]
| Question presented: Did the governor’s line-item vetoes of the legislative budgets violate the Minnesota Constitution? |
Background
Heading into the 2016 elections, the Minnesota State Legislature was divided – Democrats controlled the state Senate and Republicans controlled the state House. In the 2016 elections, Republicans gained control of the state Senate, giving them full control of the legislature during the 2017 session. Gov. Mark Dayton is a Democrat. During the 2017 session, the legislature passed several bills and policy items Dayton opposed. Those included a $650 million tax bill, which the legislature linked to funding for the Minnesota Department of Revenue. Speaker Kurt Daudt (R) called the bill an insurance policy to ensure that Dayton signed the bill.[13] Dayton signed the bills to prevent a government shutdown.[13] When the regular session ended in May 2017, the legislature had not agreed on a budget. After a special session, both chambers passed a budget bill and sent it to the governor for his signature. The legislature then adjourned. Dayton signed the budget into law, but used his line item veto authority to veto the legislature's funding. Dayton said that he would reinstate the funding if the legislature agreed to reconsider the tax bill and some other policy changes Dayton had opposed.[13] The legislature refused and filed suit, arguing that Dayton’s veto of its budget was unconstitutional and stating that it would run out of funding before the next legislative sesssion began.
In a separate lawsuit, Association for Government Accountability v. Frans, a watchdog group petitioned to force the state to pay legislators in accordance with a Minnesota constitutional amendment voters approved in 2016.[14] Although that case involves many of the same parties, it is not related to Minnesota Legislature v. Dayton.[15]
The legislature's challenge
In its suit, the legislature sought 1) a declaration from the court that Dayton’s line-item vetoes violated the Separation of Powers clause of the Minnesota Constitution; and 2) either a temporary injunction or a writ of mandamus requiring allotment of the funds appropriated to the legislature in the budget bill.[16]
Without additional appropriations, the legislature said, the legislature would be forced to suspend operations before the start of the next legislative session. Those suspensions would have meant furloughing legislative staff and defaulting on the Senate Building's lease payments. The legislature emphasized that defaulting on its lease payments could negatively impact Minnesota’s credit rating. Moreover, suspending operations would prevent elected officials from communicating with their constituents and working on legislation for the next term.[16]
Citing a Minnesota Supreme Court case, the legislature argued that the governor’s constitutional veto power is “an exception to the legislature’s authority” and should be “narrowly construed.” Moreover, the legislature claimed that the governor’s veto power may only be used if the governor objects to the actual line item he vetoes. In this case, Dayton had no objection to the particular appropriations he vetoed. Instead, the legislature claimed, the vetoes were designed to coerce the legislature into repealing parts of already-enacted legislation to which Dayton objected. The legislature argued that the coercive character of Dayton’s vetoes rendered them “unconstitutional, null, and void.”[16]
The governor's claims
Dayton rejected all of the legislature’s arguments. He argued that the Minnesota Constitution gives the governor broad line-item veto authority “without any qualification as to the Governor’s subjective intent or purpose.” This veto power, he said, functioned as the executive branch’s check on the legislature’s power. Citing a different Minnesota Supreme Court case, Dayton argued that the governor’s motive for vetoing a particular appropriation “is not legally relevant to a veto’s validity.”[2]
Dayton also rejected the notion that his vetoes had defunded the legislature, noting that the legislature had carry-over funds from 2017 and pointing out that he had not vetoed appropriations for the Legislative Coordinating Commission, which he claimed could support the core functions of the legislature while political negotiations continued. He argued that declaring his line-item vetoes unconstitutional would undercut the governor’s constitutional powers and give the legislature unchecked control of its budget.[2]
Stipulation and temporary injunction
Following the legislature's legal filing, negotiations between the parties were not successful. With the possibility of legislative staff furloughs and default on the Senate's lease payments looming, the parties jointly filed a stipulation asking the court to issue a temporary injunction that would provide for continued funding of the legislature while the case was litigated. The parties stipulated that the continued funding would end either on October 1, 2017, or when appellate review of the case concluded, whichever came first. The parties also agreed that they would immediately seek review from the Minnesota Supreme Court to resolve the case. The stipulation specifically provided that the Senate would use the continued funding to make its lease payments, thus protecting Minnesota's credit rating.[3]
The Ramsey County District Court agreed. On June 26, 2017, the court issued a temporary injunction that required continued funding of the legislature.[5]
Declaratory Judgment
On July 19, 2017, the district court issued an order granting declaratory judgment to the legislature on one of its claims. The district court held that "under the unique and limited circumstances of this case, the Governor's line-item veto of the legislature's appropriations offended the Separation of Powers clause of the Minnesota Constitution. They are null and void."[6]
On July 24, 2017, Dayton notified the court that he would appeal the judgment.[7] The Minnesota Supreme Court heard the appeal on August 28, 2017.[8]
Minnesota Supreme Court ruling
On September 8, 2017, the Minnesota Supreme Court issued an order, though not a final ruling. The court held that "the Governor's exercise of his line-item veto power over the appropriation for the Legislature's biennial budget was constitutional." However, the court emphasized that its conclusion did not resolve the parties' dispute, since the legislature still lacked funding to operate. The court expressed doubt as to whether the judiciary branch had the authority to order funding. The court ordered the parties to attend mediation in an attempt to resolve their dispute. It also ordered additional briefing from the parties over whether the judicial branch has authority to order legislative funding when the political process has broken down.[17]
On September 22, 2017, the parties ended mediation without reaching a deal. The legislature stated that Dayton had ended the talks. Dayton stated that the legislature had access to additional funding sources it had not originally disclosed.[18] Dayton then filed an amended statement with the Minnesota Supreme Court in which he claimed that, contrary to the Legislature's previous assertions, "the funds available to the Minnesota State Senate and the Minnesota House of Representatives would not be exhausted until after the start of the next legislative session on February 20, 2018."[19] The court issued a new order requiring the parties to file new reports "that identify all funds the Legislature may use to fund its operations in the absence of an appropriation for the FY2018-2019."[19]
District Court Judge
Second Judicial District Judge John H. Guthmann presided over the case in Ramsey District Court.
See also
External links
Footnotes
- ↑ Ramsey County District Court, Minnesota Legislature v. Dayton Complaint, filed June 13, 2017
- ↑ 2.0 2.1 2.2 Ramsey County District Court, Minnesota Legislature v. Dayton Memorandum in Response to Order to Show Cause and in Support of Defendant’s Motion for Judgment on the Pleadings, filed June 22, 2017
- ↑ 3.0 3.1 Ramsey County District Court, Minnesota Legislature v. Dayton Stipulation, filed June 23, 2017
- ↑ The Commissioner of Management and Budget was also a named defendant in the legislature's suit because the commissioner is in charge of releasing appropriated funds. The legislature did not suggest that the commissioner was in any way connected to Dayton's veto.
- ↑ 5.0 5.1 Ramsey County District Court, Minnesota Legislature v. Dayton Findings of Fact, Conclusions of Law, and Order Granting Temporary Injunctive Relief, filed June 26, 2017
- ↑ 6.0 6.1 Ramsey County District Court, Minnesota Legislature v. Dayton Order Granting Declaratory Judgment, filed July 19, 2017
- ↑ 7.0 7.1 Ramsey County District Court, "Defendants' Notice of Appeal to the Court of Appeals," July 24, 2017
- ↑ 8.0 8.1 Minnesota Supreme Court, "Order," July 26, 2017
- ↑ MPR News, "Dayton, GOP fail to reach deal to fund Minnesota Legislature," September 22, 2017
- ↑ StarTribune, "Supreme Court orders Legislature to disclose all funds in lawsuit with Gov. Mark Dayton," September 29, 2017
- ↑ Star Tribune, "Minnesota Legislature asks Ramsey County judge to restore funding," October 25, 2017
- ↑ Star Tribune, "Minnesota Supreme Court upholds Gov. Mark Dayton's veto of House, Senate budget," November 16, 2017
- ↑ 13.0 13.1 13.2 Star Tribune, "State lawmakers sue Dayton over funding for Legislature," June 14, 2017
- ↑ Ramsey County District Court, Association for Government Accountability v. Frans Petition for a Writ of Mandamus, filed June 5, 2017
- ↑ Minnesota Public Radio, "Lawsuit seeks MN lawmaker pay raises amid funding feud," June 5, 2017
- ↑ 16.0 16.1 16.2 Ramsey County District Court, Minnesota Legislature v. Dayton Plaintiffs’ Memorandum in Response to Order to Show Cause, filed June 22, 2017, 2017
- ↑ Minnesota Supreme Court, Minnesota Legislature v. Dayton Opinion, filed September 8, 2017
- ↑ MPR News, "Dayton, GOP fail to reach deal to fund Minnesota Legislature," September 22, 2017
- ↑ 19.0 19.1 Minnesota Supreme Court, Minnesota Legislature v. Dayton Order for Supplemental Briefing, filed September 28, 2017
Federal courts:
Eighth Circuit Court of Appeals • U.S. District Court: District of Minnesota • U.S. Bankruptcy Court: District of Minnesota
State courts:
Minnesota Supreme Court • Minnesota Court of Appeals • Minnesota District Courts • Minnesota Problem-Solving Courts • Minnesota Tax Court • Minnesota Workers' Compensation Court of Appeals
State resources:
Courts in Minnesota • Minnesota judicial elections • Judicial selection in Minnesota
