Ninetieth Minnesota State Senate v. Dayton
The Ninetieth Minnesota State Senate v. Dayton, (903 N.W.2d 609), was a 2017 Minnesota Supreme Court case where the Court ruled that Governor Mark Dayton's line item vetoes of appropriations for the Minnesota Senate and Minnesota House of Representatives were a lawful exercise of his authority granted by the Minnesota Constitution. The Court also ruled that since the state legislature had access to other funding to continue operating as a fully functioning and independent branch of government, the governor's vetoes did not effectively abolish the legislature and thereby violate Article III of the state constitution. The Court also ruled that the judicial branch did not have the constitutional authority to order funding without a corresponding budgetary appropriation. The Supreme Court's ruling overturned an earlier ruling by a Ramsey County District Court judge. The case marked the first time in which the Minnesota Supreme Court was asked to resolve a lawsuit brought by one branch of government against another. Background The Minnesota Legislature adjourned its regular session in 2017 on May 22 with a significant amount of unfinished business; it had failed to pass any omnibus spending bills establishing the state's budget for the next two years. Legislative leaders came to an agreement with Governor Mark Dayton to call a special session immediately following the adjournment of the regular session to address this unfinished business. Just before the conclusion of the special session, the legislature passed a series of appropriations bills for the state's budget. After the four-day special session had adjourned on May 26, Dayton allowed the bills to become law, but vetoed line item appropriations funding the legislature. Dayton issued a letter explaining his vetoes; he sought to avoid a government shutdown while convincing legislative leaders to renegotiate provisions of the budgetary bills. This conflict represented one instance of a lengthy dispute between Dayton, of the Democratic–Farmer–Labor Party (DFL), and the Republican-led Legislature over the scope of the state government. Among the budgetary bills was a bill containing a package of tax cuts totaling $650 million that Dayton opposed. However, the bill was worded in such a way that if Dayton had vetoed it, the Minnesota Department of Revenue would have been defunded—a situation that he wished to avoid. Legislative leaders refused to negotiate and sued Dayton, arguing that his vetoes had the unconstitutional effect of abolishing the legislature. Lower court ruling In late June, prior to making a final ruling on the case, Ramsey County District Court Chief Judge John Guthmann issued a temporary order that the Legislature continue to be funded at previous levels through October 1. (The Legislature's funding had been set to expire on June 30 with the end of the state's fiscal year.) On July 19, Chief Judge Guthmann ruled that Dayton's vetoes were unconstitutional in that they violated the Minnesota Constitution's Separation of Powers clause by effectively abolishing the legislature. Guthmann indicated that a main reason that Dayton's vetoes were problematic was that he did not actually object to the appropriations themselves; the