Legal Memorandum: Review of Administrative Actions in MN

Issue: What is the standard for reviewing administrative actions for abuse of discretion in Minnesota and elsewhere?

In Sanders v. Department of the Army, 981 F.2d 990 (8th Cir. 1992), the court applied an abuse-of-discretion standard when considering whether the federal district court had properly allowed an affirmative defense that had not been pled.  The Eighth Circuit held that the trial court did not abuse its discretion and properly allowed the defense.  “It was not necessary for the district court to require the meaningless formality of an amended answer because the government’s motion to dismiss, which expressly raised the limitations issue, provided Sanders with sufficient notice.”  Id. at 991.  See also Goodman v. Vanguard Ins. Co., 173 F.3d 428 (6th Cir. 1999) (“The district court’s interpretation of the pleadings to allow plaintiffs to introduce evidence should be reviewed for an abuse of discretion.”).

An abuse of discretion occurs when the district court rests its conclusion on clearly erroneous findings of fact or the decision relies on erroneous legal conclusions.  Rogers Group, Inc. v. City of Fayetteville, 629 F.3d 784 (8th Cir. 2010).  Abuse of discretion is the same as “arbitrary and capricious.”  Schatz v. Mut. of Omaha, 220 F.3d 944, 946-47 n.4 (8th Cir. 2000) (case addresses discretion of plan administrator under ERISA).  “An abuse of discretion occurs when (1) the trial court’s decision is clearly unreasonable, arbitrary, or fanciful, (2) [the] court’s decision is based on an erroneous construction of the law, (3) the court’s factual findings are clearly erroneous, or (4) the record contains no evidence upon […]