Supreme Court Digest: Jan. 22, 2020.

Byline: Minnesota Lawyer

Civil

Municipalities

Preemption

The question presented in this case was whether state law preempts a municipal ordinance. The Minnesota Fair Labor Standards Act establishes the minimum wage Minnesota employers must pay their employees. Respondent City of Minneapolis enacted an ordinance that requires employers to pay minimum-wage rates that are higher than the rates set forth in the MFLSA. At issue here was whether the MFLSA preempted the City's ordinance. The District Court and the Court of Appeals concluded that the MFLSA did not preempt the city's ordinance. The District Court reasoned that the MFLSA sets a floor, not a ceiling, for minimum-wage rates, thus leaving room for municipal regulation. A divided Court of Appeals panel agreed.

The Supreme Court held that (1) a municipal ordinance conflicts with a state statute when the ordinance and statute are irreconcilable. Because employers can comply with both the City's ordinance governing minimum-wages rates and the MFLSA, the ordinance and statute are reconcilable and therefore do not conflict; and (2) a because the Legislature did not intend to occupy the field of minimum-wage rates, the MFLSA does not preempt the city's ordinance governing minimum-wage rates. Affirmed.

A18-0593 Graco, Inc. v. City of Minneapolis (Court of Appeals)

Names Changes

Children

This case requires an interpretation of the notice provision found in Minn. Stat. 259.10, relating to name-change applications on behalf of minors. Appellant was the only parent listed on her children's birth certificates, and no one has been adjudicated as their father. The District Court and the Court of Appeals concluded that she nonetheless had to notify the children's...