Inter Faculty Organization v. Carlson

478 N.W.2d 192, 1991 Minn. LEXIS 311, 1991 WL 270018
CourtSupreme Court of Minnesota
DecidedDecember 20, 1991
DocketC4-91-1471
StatusPublished
Cited by9 cases

This text of 478 N.W.2d 192 (Inter Faculty Organization v. Carlson) 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
Inter Faculty Organization v. Carlson, 478 N.W.2d 192, 1991 Minn. LEXIS 311, 1991 WL 270018 (Mich. 1991).

Opinion

OPINION

KEITH, Chief Justice.

We accelerated review of an appeal by Governor Arne Carlson, et al. from an order of the district court granting the petition of Inter Faculty Organization, et al. and issuing a writ of mandamus declaring attempted gubernatorial vetoes to be null and void and without legal effect and compelling the respondents below, in their capacity as constitutional and statutory officials, to perform their various official duties as to legislation without regard to those attempted vetoes. We modify the decision of the district court and affirm.

We first address the procedural posture in which this action arose and was decided. In The Seventy-Seventh Minnesota State Senate v. Carlson, 472 N.W.2d 99 (Minn.1991), we defined the procedural avenue by which a challenge to the exercise of the veto power might be asserted. In establishing a uniform procedure applicable to proceedings of this nature, we directed the parties in an unrelated matter to petition the district court for a judicial declaration as to the validity or invalidity of attempted vetoes in accordance with Minnesota Statute chapter 555, the Uniform Declaratory Judgments Act. Inexplicably, this matter nevertheless proceeded on petition for a writ of mandamus. 1 While that petition and the relief it requests are procedurally inappropriate, we nevertheless decline to remand this matter for further proceedings in accordance with Minn.Stat. ch. 555 because of the untoward delay which would result. Instead, we modify the trial court’s decision, recasting it as a judicial declaration that the vetoes were invalid for the reasons set forth in that decision and proceed with our appellate review.

The parties have stipulated to the operative facts. On May 20, 1991, the legislature approved the Higher Education Appropriations Act, Act of June 4, 1991, ch. 356. art. I, 1991 Minn. Laws, (“Act”) and presented it to the governor on May 31, 1991. After vetoing nine provisions contained in the Act, only three of which are challenged in these proceedings, Governor Carlson signed the Act on June 4,1991. In accordance with the constitutional mandate, Minn. Const, art. 4, § 23, the governor appended his veto message explaining among other matters the basis for the subject three vetoes in pertinent part as follows:

The Higher Education line-item vetoes are difficult ones, and, because of the complicated appropriations process employed by the Legislature, the changes cannot be equitably allocated among the individual systems. Nevertheless, the changes are necessary in order to bring the higher education budget closer to my original recommendation.

Veto Message, 1991 Minn. Laws chs. 233, 254, 265, 292, 345, and 356, various items.

The four petitioners are organizations of faculty members of the state university system, the community college system and technical college system, and students attending college in the community college system. The faculty organizations collectively claim injury if the vetoes are upheld, asserting that budget cuts will negatively impact existing educational programs and their ongoing salary negotiations, while the student organization focuses on what it assumes will be the inevitable reduction in educational services with a corresponding increase in tuition costs. They challenge the validity of the purported vetoes, asserting that the governor acted outside the bounds of his constitutional authority, lim *194 ited to a veto of “items of appropriation of money.” Minn. Const. Art. 4, § 23.

Minn. Const. Art. 4, § 23 provides:

If a bill presented to the governor contains several items of appropriations of money, [the governor] may veto one or more of the items while approving the bill. At the time [the governor] signs the bill the governor shall append to it a statement of the items [the governor] vetoes and the vetoed items shall not take effect. 2

When interpreting a constitutional provision, we, of course, look first to the specific language of that provision. State ex. rel. Gardner v. Holm, 241 Minn. 125, 62 N.W.2d 52 (Minn.1954). In doing so with regard to this item veto authority, two observations are necessary. First, the power is located in Article 4, the Legislative Department Article, demonstrating that the authority is not an executive function in the traditional or affirmative sense, but rather an exception to the authority granted the legislature. As an exception, the power must be narrowly construed to prevent an unwarranted usurpation by the executive of powers granted the legislature in the first instance.

Second, the language of the provision itself limits the authority to the veto of “items of appropriations,” not of a part or parts of an item. We therefore view that power as a negative authority, not a creative one — in its exercise the power is one to strike, not to add to or even to modify the legislative strategy.

As a practical matter, the parties do not differ significantly in the definitions of the term “item of appropriation” they ask the court to adopt. The petitioners faculty and students suggest that the term connotes a “specific sum of money which is dedicated to a specific purpose,” while the governor proffers the following definition: “provisions in an appropriation bill which are separate and distinct from other provisions in the same bill, insofar as the subject, purpose, or amount of the appropriation is concerned * * *.” State ex rel. Brown v. Ferguson, 32 Ohio St.2d 245, 252, 291 N.E.2d 434, 438 (1972). We, in Minnesota, find ourselves without a specific definition of the term having a general legislative instruction of a definition as contained in Minn.Stat. § 16A.011, subd. 5 (1990) which defines an “appropriation” as an “authorization by law to expend or encumber an amount in the treasury.” Other jurisdictions offer limited guidance in the presentation of definitions similar to those offered by the parties. See, e.g., Henry v. Edwards, 346 So.2d 153, 157 (La.1977) (“[T]he word “item” signifies a sum of money dedicated to a specific purpose, a separate fiscal unit.”); People ex rel. State Board of Agriculture v. Brady, 277 Ill. 124, 131, 115 N.E. 204, 207 (1917) (“The word “item” is in common use and well understood as a separate entry in an account or a schedule, or a separate particular in an enumeration *195 of a total which is separate and distinct from the other particulars * * * ”).

It is our responsibility then to define the phrase “item of appropriation” by reference to, and within the context of the Higher Education Appropriations Act, Act of June 4, 1991, ch. 356, art. I, 1991 Minn. Laws. An “item of appropriation of money” is a separate and identifiable sum of money appropriated from the general fund dedicated to a specific purpose.

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Cite This Page — Counsel Stack

Bluebook (online)
478 N.W.2d 192, 1991 Minn. LEXIS 311, 1991 WL 270018, Counsel Stack Legal Research, https://law.counselstack.com/opinion/inter-faculty-organization-v-carlson-minn-1991.