Ninetieth Minnesota State Senate v. Dayton
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| Ninetieth Minnesota State Senate v. Dayton | |
|---|---|
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| 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 |
| 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.
Background
The Minnesota Legislature adjourned its regular session with significant amounts of unfinished business; it had failed to pass any omnibus spending bills establishing the state's budget for the the next two years.[1] 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.[1] Just before the conclusion of the special session, the legislature passed a series of appropriations bills for the state's budget.[1] After the special session had adjourned, Dayton allowed the bills to become law, but line item vetoed appropriations funding for the legislature.[1] Dayton wrote a letter explaining his vetoes; he sought to avoid a government shutdown while convincing legislative leaders to renegotiate provisions of the budgetary bills.[1] Instead of acquiescing to the Governor's offer of negotiations, legislative leaders sued Dayton.[1]
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 having the effect of abolishing the legislature.[2] 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 appropriation and policies unrelated to the legislature's funding.[2] Upon news of the ruling, Dayton immediately indicated his intent to appeal the decision.[2]
Ruling of the Supreme Court
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 appropiations.[3] The Court also ordered the parties into talks with a mediator.[3] Additionally, the Court strongly encouraged the parties to find a political solution to resolve this dispute.[3] 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.[3]
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.[4] 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.[4] One week later, the Supreme Court ordered legislative leaders to submit a full report of their current financial situtation regarding funding on hand and their ability to continue to function.[5]
On November 16, the Court issued its final ruling and upheld Governor Dayton's vetoes.[6] The Court also stated that the Legislature had access to sufficient funding to continue to exist until the beginning of the next legislative sesssion; consequently, Dayton's actions remained within his constitutional authority.[6] The Court's ruling was issued by a 5-1 majority; Justice Barry Anderson dissented, and Justice David Stras recused himself from the case.[6] 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.[6] The Court declined to take a stance on the matter of whether Dayton's veto of the legislature was coercive; the legislature will continue to operate until the next legislative session when a political solution to this dispute can be reached.[6]
Reactions to the ruling
Governor Mark Dayton applauded the Supreme Court's ruling and cast blame on Republican legislative leaders for initiating the lenghty and expensive legal dispute.[6] The final costs of legal fees are expected to be several hundred thousand dollars and be borne by Minnesota taxpayers.[7] 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.[6] 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.[6] Daudt said that this unprecedented financial situation put the Senate at risk of defaulting on scheduled debt payments for the Senate’s office building.[6] When the legislature reconvenes in 2018 for its next regular session, it is expected that the body will pass legislation appropriating the funds that were vetoed.[6]
References
- ^ a b c d e f Bierschbach, Briana (September 25, 2017). "Where the standoff between the governor and Republican legislative leaders goes from here". MinnPost. Retrieved November 29, 2017.
- ^ a b c Golden, Erin (July 19, 2017). "Judge strikes down Gov. Mark Dayton's veto of Legislature's budget; Dayton plans appeal". Star Tribune. Retrieved November 24, 2017.
- ^ a b c d Stassen-Berger, Rachel E. (September 13, 2017). "MN Supreme Court says Mark Dayton's veto of legislative budget was constitutional". Pioneer Press. Retrieved November 24, 2017.
- ^ a b Bakst, Brian; Pugmire, Tim (September 22, 2017). "Dayton, GOP fail to reach deal to fund Minnesota Legislature". Minnesota Public Radio. St. Paul, MN. Retrieved November 24, 2017.
- ^ Coolican, Patrick (September 29, 2017). "Supreme Court orders Legislature to disclose all funds in lawsuit with Gov. Mark Dayton". Star Tribune. Retrieved November 24, 2017.
- ^ a b c d e f g h i j Golden, Erin (November 17, 2017). "Minnesota Supreme Court upholds Gov. Mark Dayton's veto of House, Senate budget". Star Tribune. Retrieved November 22, 2017.
- ^ Coolican, J. Patrick (September 29, 2017). "Supreme Court orders Legislature to disclose all funds in lawsuit with Gov. Mark Dayton". Star Tribune. Retrieved November 23, 2017.