Background
James Card, a Hubbard County deputy sheriff, applied for and received approval from the Public Employees Retirement Association of Minnesota for duty-disability benefits and continued health-insurance coverage under Minn. Stat. § 299A.465 (2024). PERA notified Hubbard County, Card’s employer, that it could petition for review by requesting a contested-case hearing within 60 days. The county did so in October 2024.
After the legislature amended the statute in 2025 to prohibit employers from challenging the continuation and payment of health coverage, Card sought summary disposition. An administrative-law judge dismissed the county’s petition, concluding that the amendments applied retroactively and that the county was not a “person” authorized to challenge PERA’s determination under the 2024 statute. The county sought certiorari review.
The Court’s Holding
The Minnesota Court of Appeals reversed. It held that the 2025 amendments did not apply retroactively because the legislature did not clearly and manifestly express such an intent. The amendments became effective May 24, 2025, contained no language applying them to pending petitions, and made substantive changes rather than merely clarifying existing law.
The court also held that an employer qualified as a “person” permitted to petition for review under the 2024 version of the statute. That version required notice to both the employee and employer, referred broadly to “the person” and “any person” when describing review rights, and expressly gave employers standing to participate in judicial review. Because Hubbard County timely petitioned in October 2024, the court remanded for a contested-case hearing.
Key Takeaways
- The 2025 prohibition on employer challenges under Minn. Stat. § 299A.465 applies prospectively, not to petitions filed before its effective date.
- Under the 2024 statute, an employer was a “person” entitled to seek contested-case review of a PERA duty-disability determination.
- Hubbard County’s October 2024 petition was timely and must proceed to a contested-case hearing.
Why It Matters
The decision preserves employer review rights for PERA duty-disability disputes initiated under the pre-amendment statute. It also reinforces Minnesota’s strong presumption against retroactive legislation: describing statutory revisions as “administrative and conforming” does not, without clearer evidence, make substantive changes retroactive.
The court did not decide whether Card was entitled to duty-disability benefits or continued health coverage. It decided only that the county may challenge PERA’s determination through the contested-case process available under the 2024 law.