Legal Memorandum: Deference to Agency Interpretation in MN

Issue: Under Minnesota law, when statutory language is unclear, is a court permitted to defer to the meaning of the law as interpreted by an affected agency?

Area of Law: Administrative Law, Administrative Law & Regulation (Federal and State), Litigation & Procedure
Keywords: Deference; Agency interpretation; Statutory language
Jurisdiction: Minnesota
Cited Cases: 555 N.W.2d 552
Cited Statutes: None
Date: 07/01/2014

When the statutory language is clear and unambiguous no deference is permitted.  “When a decision turns on the meaning of words in a statute or regulation, a legal question is presented.  In considering such questions of law, reviewing courts are not bound by the decision of the agency and need not defer to agency expertise.”  St. Otto’s Home v. Minn. Dep’t of Human Servs., 437 N.W.2d 35, 39-40 (Minn. 1989).

Even in the limited situations where deference to agency interpretation may be made, it is only appropriate where (1) the statutory language is technical in nature, and (2) the agency’s interpretation is one of long-standing application.  Arvig Tel. Co. v. Northwestern Bell Tel. Co., 270 N.W.2d 111, 114 (Minn. 1978); In re Clarification of an Appropriate Unit, 555 N.W.2d 552, 553 (Minn. Ct. App. 1996). 


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