Summary
The Minnesota Supreme Court held that Minn. Stat. § 469.014, which makes housing and redevelopment authorities liable in contract and tort like private corporations, does not confer subject matter jurisdiction on a district court to hear a public employee's wrongful termination or employment-contract claim. The court concluded that certiorari is the exclusive method of judicial review when the claim is centered on a local executive body's termination decision, affirming dismissal for lack of subject matter jurisdiction. Two justices dissented, arguing that an action seeking contract damages should be heard in district court.
Topics
Practice areas
Questions Presented
- Whether Minn. Stat. § 469.014 creates an exception to the rule that a public employee's challenge to a quasi-judicial termination by a local executive body must be brought by writ of certiorari.
- Whether characterizing Tischer's claim as breach of contract for wages and benefits rather than wrongful termination permitted the district court to exercise subject matter jurisdiction.
Holdings
- Minn. Stat. § 469.014 establishes the scope of an HRA's liability but does not confer subject matter jurisdiction on the district court or create an alternative procedure for challenging an HRA employee's termination.
- When a public employee's breach-of-employment-contract claim is centered on the executive body's decision to discharge the employee, the claim is treated as a wrongful-employment-termination claim for jurisdictional purposes, and certiorari is the exclusive remedy absent statutory authorization for another process.
Key quotations
“Therefore, we reiterate the rule that when a public employee's claim of breach of an employment contract is inevitably centered on the executive body's decision to discharge her, it will be viewed as a wrongful employment termination claim for jurisdictional purposes and certiorari is the exclusive remedy for judicial review of that claim.” (at 432)
“We hold that the court of appeals correctly concluded that Minn.Stat. § 469.014 does not confer subject matter jurisdiction on the district court to hear a wrongful termination claim of a HRA employee.” (at 431)
Factual background
The Cambridge Housing and Redevelopment Authority hired Sandy Tischer as its executive director in 2000. After the Cambridge City Council transferred HRA functions to the city's Economic Development Authority, the HRA entered into a two-year employment agreement with Tischer, but later amended its bylaws, eliminated her position, and terminated her employment. Tischer did not seek certiorari review within the statutory sixty-day period; instead, she sued the HRA in district court for breach of contract and unpaid wages.
Procedural history
The district court concluded that the termination was quasi-judicial but held that Minn. Stat. § 469.014 conferred jurisdiction to hear Tischer's breach-of-contract claim and therefore denied the HRA's motion to dismiss. The court of appeals reversed, holding that § 469.014 addressed the HRA's substantive liability rather than creating a district-court procedure for reviewing a wrongful termination. The supreme court affirmed the court of appeals.