Abrahamson v. St. Louis County School District

819 N.W.2d 129, 2012 WL 3236801, 2012 Minn. LEXIS 398
CourtSupreme Court of Minnesota
DecidedAugust 10, 2012
DocketNo. A10-2162
StatusPublished
Cited by13 cases

This text of 819 N.W.2d 129 (Abrahamson v. St. Louis County School District) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abrahamson v. St. Louis County School District, 819 N.W.2d 129, 2012 WL 3236801, 2012 Minn. LEXIS 398 (Mich. 2012).

Opinions

OPINION

PAGE, Justice.

This case requires that we interpret provisions of Minn. Stat. chs. 211A and 211B (2010). Specifically, we must determine whether a school district is subject to the campaign-finance reporting requirements found in chapter 211A and whether the complaint in this matter stated a claim under section 211B.06, which prohibits the dissemination of false campaign material. We hold that a school district is a “corporation” under section 211A.01, subdivision 4, and therefore can qualify as a “committee” subject to chapter 211A’s campaign-finance reporting requirements if it acts “to promote or defeat a ballot question.” Because appellants’ complaint, filed with the Office of Administrative Hearings (OAH), stated a prima facie claim that the school district here was a “committee” under section 211A.01, subdivision 4, that “promote[d] ... a ballot question,” the administrative law judge assigned to the matter erred in dismissing the complaint without an evidentiary hearing. We also hold that the complaint failed to state a prima facie violation of section 211B.06 with respect to two allegedly false statements. Therefore, we affirm in part, reverse in part, and remand to the OAH for further proceedings consistent with this opinion.

On December 8, 2009, the St. Louis County School District (District) held a special election on a referendum that sought voter authorization for the school district to issue building bonds. At the time the school district passed the resolution to hold the special election, the district included seven schools and approximately 2,000 enrolled students. According to a resolution adopting a long-range facilities plan and approved at the June 8, 2009, school board meeting, enrollment in the school district had declined over the previous ten years by about 800 students and was expected to decline by another 100 students by 2013. The purpose of the long-range plan was to address the enrollment declines and the budget problems accompanying the declines. The District’s long-range plan called for the closure of two schools and the construction of two new, more centrally-located, schools. On September 14, 2009, the school board approved the placement of a referendum on the ballot at a special election to be held on December 8, 2009.1 The ballot question was whether to authorize the school district to issue “school building bonds in an amount not to exceed $78,800,000.” Between September 14, 2009, and the special election, the board distributed newsletters and other publications that contained information about the ballot question.

On November 4, 2010, respondents Steven Abrahamson and Tom Kotzian filed a complaint with the OAH against the District and seven school board members. See Minn.Stat. § 211B.32, subd. 1 (2010) (requiring a complaint alleging a violation of chapter 211A or 211B to filed with the OAH). The complaint alleged that the District violated the campaign-finance reporting requirements of Minn. Stat. ch. 211A by not reporting expenditures incurred in promoting passage of the De[132]*132cember 8, 2009, ballot question. The complaint also alleged that the District violated Minn. Stat. § 211B.06 (2010) by disseminating false statements in connection with the ballot question. Specifically, it is alleged the school district contracted with a consulting company that, on its own or through subcontractors, “pro-vid[ed] reports or studies for the District” and “assist[ed] in the preparation of materials to promote the passage of the December ballot question.” The complaint also alleged that the District paid the cost of publication and postage for distributing the newsletters or similar publications with public funds. The District did not report its publication and distribution expenditures as allegedly required by chapter 211 A.

An administrative law judge (ALJ) dismissed respondents’ complaint, without an evidentiary hearing, for failure to state a prima facie case. See Minn.Stat. § 211B.33, subd. 2(a). The ALJ ruled that school districts are not subject to chapter 211A’s campaign-finance reporting requirements because they do not qualify as “committees” within the meaning of that term in chapter 211 A. Alternatively, the ALJ ruled that, even if school districts are “committees,” the specific expenses alleged in the complaint to have been unlawful fell within the exemption in the definition of “disbursement” under Minn.Stat. § 211A.01, subd. 6, for election-related expenditures.2 In reaching these conclusions, the ALJ relied on two previous OAH decisions, both of which held that a school district is not a committee within the meaning of Minn.Stat. § 211A.01, subd. 4, and is therefore not subject to chapter 211A’s reporting requirements. See Barry v. St. Anthony-New Brighton Indep. Sch. Dist. 282 (OAH) (May 21, 2009), aff'd on other grounds, 781 N.W.2d 898 (Minn.App.2010); Wigley v. Orono Pub. Sch. (OAH) (May 1, 2008). Finally, the ALJ held that none of the four allegedly false statements recited in the complaint were false.

By writ of certiorari, respondents Abra-hamson and Kotzian sought review in the court of appeals of the ALJ’s holdings that school districts are not subject to chapter 211A and that the complaint did not state a prima facie violation of section 211B.06 with respect to three of the four statements alleged in the complaint to have been false. The court of appeals affirmed in part, reversed in part, and remanded. Abrahamson v. St Louis Cnty. Sch. Dist., 802 N.W.2d 393, 406 (Minn.App.2011). The court reversed the ALJ’s holding that a school district does not qualify as a committee under chapter 211 A, and held that school districts are subject to the campaign-finance reporting requirements of that chapter. Id. at 399. The court also reversed the ALJ’s holding that the expenditures alleged in the complaint were not “disbursements,” concluding that the District’s expenditures were neither required nor authorized by law. Id. at 403. Finally, the court reversed the ALJ’s dismissal of the section 211B.06 claims with respect to two of the statements, but affirmed with respect to another of the statements. Id. at 404-06. Abrahamson and Kotzian did not challenge the ALJ’s conclusion regarding a fourth statement. Id. at 404.

We granted the District’s petition for further review. The questions in this case are: (1) whether the St. Louis County [133]*133School District is a “committee” within the meaning of that term in chapter 211 A, and therefore subject to campaign-finance reporting requirements; and (2) whether the complaint stated a prima facie case for violation of the prohibition under Minn. Stat. § 211B.06 against making false statements to promote or defeat a ballot question.

Our review is governed by Minn.Stat. § 14.69 (2010). We may affirm the agency’s decision or remand for further proceedings. Id. Or, we may reverse or modify the decision “if the substantial rights of the petitioners may have been prejudiced because the administrative finding, inferences, conclusion, or decisions are: (a) in violation of constitutional provisions; or (b) in excess of the statutory authority or jurisdiction of the agency; or (c) made upon unlawful procedure; or (d) affected by other error of law; or (e) unsupported by substantial evidence in view of the entire record as submitted; or (f) arbitrary or capricious.” Id. The posture of this case is similar to a motion to dismiss under Minn.

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Cite This Page — Counsel Stack

Bluebook (online)
819 N.W.2d 129, 2012 WL 3236801, 2012 Minn. LEXIS 398, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abrahamson-v-st-louis-county-school-district-minn-2012.