Meath v. Harmful Substance Compensation Board

550 N.W.2d 275, 1996 Minn. LEXIS 389, 1996 WL 336034
CourtSupreme Court of Minnesota
DecidedJune 20, 1996
DocketC6-94-76
StatusPublished
Cited by28 cases

This text of 550 N.W.2d 275 (Meath v. Harmful Substance Compensation Board) 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
Meath v. Harmful Substance Compensation Board, 550 N.W.2d 275, 1996 Minn. LEXIS 389, 1996 WL 336034 (Mich. 1996).

Opinions

OPINION

COYNE, Justice.

The Harmful Substance Compensation Board denied respondent Marlene Meath’s claim for compensation from the harmful substance compensation account established pursuant to Minn.Stat. §§ 115B.20 and 115B.26, subd. 1 (1992). Meath then petitioned for certiorari to the court of appeals. In response to the Board’s contention that, pursuant to MinmStat. § 115B.35, subd. 8 (1992), the court lacked jurisdiction to review the Board’s decision, the court of appeals held that availability of judicial review of an administrative agency’s quasi-judicial decisions is constitutionally mandated (citing Minn. Const, art. Ill, § 1). Because a decision of the Harmful Substance Compensation Board either to grant or deny compensation is not a quasi-judicial act, we conclude that neither the court of appeals nor this court has jurisdiction to review the Board’s decision and we reverse.

A decision by either a judicial or quasi-judicial body denotes binding effect on whatever party or parties are before it — unless, of course, the decision is later overturned by a higher ranking judicial or quasi-judicial authority. In such eases the rights of the parties are irrevocably fixed by the final decision. Conversely, a decision by the Harmful Substance Compensation Board binds no one except a claimant who has received and accepted an award. Only a claimant who has pocketed money from the harmful substance compensation account is [276]*276precluded from bringing an action in court for the same injury. Minn.Stat. § 115B.31, subd. 1(b) (1994).

The Environmental Response and Liability Act provides that a person who has settled an injury claim or procured a judgment against a responsible person may not file a claim for compensation from the account unless the judgment cannot be satisfied. Minn. Stat. § 115B.31, subd. 1(a) (1994). A person may not file a claim with the board while an action is pending before a court, and a claimant may not commence an action while his or her claim is pending before the board. Minn.Stat. § 115B.31, subd. 4 (1994). Inasmuch as the statute also provides that the statute of limitations for any civil action is suspended during the period of time that a claimant is precluded by the statute from commencing an action, id., it seems apparent that the legislature has simply afforded claimants an alternative procedure for procuring compensation. Failure of that procedure to produce the desired result does not, however, prejudice the claimant. Because the statute prohibits both judicial review of the board’s denial of the claim and the filing of a new claim with the board for the same injury, the board’s denial is final and it must be conceded, we think, the claim is no longer pending before the board. Therefore, the claimant is no longer precluded from commencing a civil action against the responsible party or parties.

Not only does the statute repose absolute discretion in the board, whose decision whether to award compensation and, if so, how much, is not subject to judicial review, but the statute also provides the claimant with a durable option either to proceed at common law against the responsible persons or to file a claim for compensation from the Harmful Substance Compensation Board or its successor. The durability of the option has been forged by the statutory provisions which permit a claimant to file a claim with the board or its successor if the claimant is unable to secure satisfaction from the responsible parties of a judgment already procured in a civil action.

Inasmuch as the statute only precludes commencement of a civil action while a “claim is pending before the board” (section 115B.31, subdivision 4), the implication of the statutory language is, as we have previously explained, that the bar to commencement of a civil action against responsible parties falls when the board denies the claim. Somewhat less obvious is the inference that because section 115B.31, subdivision 1(b) provides:

A person who has filed a claim with the board for an eligible injury or damage, and who has received and accepted an award from the board, is precluded from bringing an action in court for the same eligible injury or damage,

the preclusion from commencing a civil action disappears when the claimant rejects the board’s award.1

If the bar to a civil action drops when the claimant refuses to accept the board’s award, it becomes even more apparent that a decision by the Harmful Substance Compensation Board to award compensation is not a decision at all. That the board expresses its willingness to award a sum of money to the claimant from the harmful substance compensation account does not resolve the claim; the board’s “decision” is nothing more than an offer which the claimant may reject.

Furthermore, whenever the injured person brings a civil action against persons alleged to be responsible for the release of a harmful substance, the “findings and decision” of the board are inadmissible in that action. Minn. Stat. § 115B.31, subd. 2 (1994). Although, if the claimant attempted to bring an action as the real party in interest, the fact that the claimant received and accepted an award from the board would no doubt be admissible to prove that the claimant was precluded from bringing that action, that the board denied the claim altogether or awarded compensation which the claimant rejected could [277]*277not be admitted in the civil action for any purpose.2

The board may investigate a claim filed with it and decide whether it wishes to award the claimant compensation, but in so doing it is not acting quasi-judicially. It is true, as the concurrence indicates, that the term “quasi-judicial” has sometimes been applied to distinguish executive decisions from legislative decisions. E.g., Oakman v. City of Eveleth, 163 Minn. 100, 109, 203 N.W. 514, 517-18 (1925). If, however, every administrative decision which is based on evidentiary facts developed through investigation can for that very reason be characterized as “quasi-judicial,” then almost every administrative decision is “quasi-judicial” even though few such decisions adjudicate any right or obligation of contending parties. For example, the highway department may investigate traffic flow at an intersection when considering which of two recommendations contained in the manual is applicable: that directing installation of a semaphore or that calling for the installation of two- or, perhaps, four-way stop signs. Although it depends on some investigation and the development of certain facts, the decision that a semaphore is required hardly constitutes a “judicial act performed by one not a judge,” and to even suggest that judicial review of that decision is constitutionally required would be ludicrous.

Because the denial of compensation from the harmful substance compensation account is not a quasi-judicial decision, we see no reason to mention In re Haymes, 444 N.W.2d 257 (Minn.1989), much less to engage in an attack on dictum contained there. Haymes involved a disciplinary proceeding before the Minnesota Racing Commission. After a contested case hearing before an administrative law judge, the judge ruled that Haymes’ employer, who had agreed to pay his legal expenses, could recover from the racing commission the cost of Haymes’ successful defense.

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Bluebook (online)
550 N.W.2d 275, 1996 Minn. LEXIS 389, 1996 WL 336034, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meath-v-harmful-substance-compensation-board-minn-1996.