Legal Memorandum: Rules for Statutory Interpretation in MN

Issue: Under Minnesota laws, what rules guide statutory interpretation?

Minnesota Supreme Court has long recognized that, “[w]e must, if possible, avoid an interpretation which renders a complete sentence of the statute surplusage and so in effect amends the law by striking out that sentence.”  Cohen v. Gould, 225 N.W. 435, 438 (Minn. 1928).

Where sentences are deemed to be in conflict, “the more specific provision controls over the more general.”  AFSCME Council No. 14 v. Washington County Bd. Of Comm’rs, 527 N.W.2d 127, 132-33 (Minn. Ct. App. 1995).  “When a general provision in a law is in conflict with a special provision in the same or another law, the two shall be construed, if possible, so that effect may be given to both.  If the conflict between the two provisions be irreconcilable, the special provision shall prevail and shall be construed as an exception to the general provision.”  Minn. Stat. § 645.26, subd. 1.

“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. […]