• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
mitchell hamline school of law

Minnesota Administrative Procedure

  • Home
  • Expanded Table of Contents
  • Contact
  • Search Help

Primary Sidebar

Contents

  • Preface
  • About the Editors

Part 1. Introduction to Administrative Procedure

  • 1. The Development of Administrative Law
  • 2. Researching Administrative Law

Part 2. Contested Case Procedure

  • 3. Agency Investigations
  • 4. Introduction to Contested Cases and the Office of Administrative Hearings
  • 5. Notice of Hearings
  • 6. Parties
  • 7. Prehearing Practice
  • 8. Discovery
  • 9. Discovery Limitations
  • 10. Evidence
  • 11. The Contested Case Hearing
  • 12. Collateral Estoppel, Res Judicata, Stare Decisis, and the Equitable Defenses
  • 13. The Minnesota Government Data Practices Act and Contested Case Hearings
  • 14. The Agency Decision
  • 15. Judicial Review of Contested Cases

Part 3. Rulemaking Procedure

  • 16. Introduction to Rulemaking
  • 17. The Initial Stages of the Rulemaking Process
  • 18. Drafting Rules and the Revisor of Statutes
  • 19. Rulemaking Without a Hearing
  • 20. Rulemaking With a Hearing
  • 21. Exempt and Expedited Rules
  • 22. Need and Reasonableness and Substantial Difference
  • 23. Review of Rules for Legality
  • 24. Judicial Review of Rules
  • 25. Legislative Review of Administrative Rules

Chapter 2. Researching Administrative Law

Original Author: Susan A. Kiefer

Revised in February 2015 by Neal Axton

Revised in October 2026 by Lisa Heidenreich

Download a PDF of Chapter 2

Chapter Contents

  • 2.1 Introduction
  • 2.2 Agencies
  • 2.3 Minnesota Rules
  • 2.4 Federal Regulations
  • 2.5 Decisions and Orders of Administrative Agencies
  • 2.6 Opinions of the Attorney General
  • 2.7 Legislative Research
  • 2.8 Secondary Sources in Administrative Law
  • Footnotes

2.1 Introduction

Research in administrative law requires a command of many different legal resources. In addition to rules, agency decisions, executive orders, and opinions of the attorney general, the researcher often must find statutes that grant authority to an agency and cases that review agency action. Secondary sources such as treatises, legal periodicals, and continuing education materials provide background, interpretation, and analysis for the primary sources. This chapter will outline the techniques for finding Minnesota administrative law.

2.2 Agencies

Research in administrative law may begin with a search for information about the agency or agencies involved. Minnesota.gov is the official government portal for the State and provides up-to-date information about state administrative agencies, boards and commissions.[1] It contains information about executive branch agencies as well as multi-member boards and other commissions whose members are citizens appointed by the governor.

The Minnesota Legislative Manual,[2] also known as “the Blue Book” is now available online. It contains more concise information about all branches and levels of Minnesota government, including state agencies and local political subdivisions. It also contains an explanation of how the legislature functions, as well as a listing of all legislators and their committee assignments.

Many agencies also have self-published material available which describes their organization and duties. State agencies’ websites are hosted on Minnesota.gov[3] and often provide useful information. The Minnesota Pollution Control Agency’s website[4] for example, provides a list of agency leadership,[5] information on its strategic plan, history, and operations,[6] legislative recommendations and reports,[7] its proposed and existing rules,[8] its news releases,[9] information on the air[10] and water[11] permit application review process, as well as detailed sections on trending topics and interacting with the agency.

There are several resources that provide information about agencies and their officers in all fifty states. The Administrative Rules section[12] of the Administrative Codes & Registers’ website and USAGov’s State Governments page [13]are excellent starting points.

Research in Minnesota administrative law often leads to federal laws and agencies, since a number of federal and state programs intertwine. Several sources provide information about the United States government. The United States Government Manual[14] is the official compilation of information about federal administrative agencies. The federal government’s online portal USAGov[15] is another helpful resource for searching federal and state websites. Additional resources are discussed in Section 2.4 on Federal Regulations.

2.3 Minnesota Rules

The essential resources of state administrative law are the rules adopted by state agencies. Although many citizens are unaware of these rules, they have the force and effect of law.

2.3.1 Adoption and Publication

The text of proposed rules and amendments to rules, notice of comment periods and hearing dates, and final adoption of rules and amendments must be published in the Minnesota State Register. The State Register began weekly publication in 1976 and ceased publication in print in 2004. It is now available online. The State Register is the official organ for notifying the public about actions of state government, including rulemaking. It is published by the Minnesota Department of Administration[16] and is available on the Minnesota Revisor of Statutes website as well.[17]

Rules, including rules specifically exempted from the Minnesota Administrative Procedure Act (APA),[18] must be published in the State Register to be effective. The State Register is divided into sections. The sections related to rule-making address proposed rules, adopted rules, and a list of Minnesota Rules amendments and additions that is compiled in various issues throughout the year.[19]

The State Register also contains the Governor’s Executive Orders, Exempt Rules, Revenue Notices, Commissioner’s Orders and notices related to state bids, grants and loans.

Publication in the State Register is only part of the rulemaking process in Minnesota. Many rules must be heard before the Office of Administrative Hearings as well as being published in the State Register. See section 2.5 of this chapter regarding Decisions and Orders of Administrative Law Agencies for more information on the role of the Office of Administrative Hearings (OAH) in the Minnesota rulemaking process.

After final adoption by the agency, agency rules are codified into Minnesota Rules (referred to as the Minnesota Administrative Rules on the Revisor of Statutes website to disambiguate them from the Court Rules) published by the Revisor of Statutes. Agency rules are compiled by issuing agency and arranged according to a uniform decimal numbering scheme. Minnesota Administrative Rules is available online[20] and as a multi-volume softbound set, published biennially in odd numbered years and updated by supplement in even-numbered years. The final volume in the set contains historical information, a User’s Guide, an index and several useful tables.

To locate a current rule, consult the comprehensive index in the current edition of Minnesota Rules, on the Revisor of Statutes website[21] or in hard copy. To ensure that the rule has not been amended or repealed, refer next to the State Register. The most recent cumulative list of Minnesota Rules amendments and additions should be checked to see if there is a listing for the chapter and section in question, and this process should be repeated in subsequent issues as necessary. The issues in which the list is cumulated are listed inside the front cover of each issue.[22]

In 2014 the revisor’s office began “beta testing” and providing public access to a prototype of what it calls “a public administrative rule status system.”[23] The system permits users to both access historical documents related to completed rulemakings and to follow developments of present-day rulemaking proceedings.

As of mid-2026, the rule status system afforded access to historical rule information, documents and notices for rules adopted since 1980. The system also made available full-text word search of every volume of the State Register, and review access to more than 2,100 agency SONARs (statements of need and reasonableness) and nearly 1,500 rule-related records from the Office of Administrative Hearings.

The linchpin of the system is the fact that each of the legislative and executive branch agencies involved in the state rulemaking process is now using the Revisor Number as a unique and common identifier for rulemaking documents. In this way, notwithstanding the fact that many different agencies and stakeholders develop materials as part of a particular rulemaking proceeding, the shared Revisor Number permits those items to be electronically tagged and brought to a single online storage and status system.

2.3.2 Historical Research

Between 1970 and 1983, there were several compilations of Minnesota’s rules that can be used with varying degrees of success to trace the history of any given rule. Before 1970, compilations did not exist or were published separately by the individual agency. Because the completeness of the compilations is both questionable and variable, tracing the changes in a rule requires a check of previous editions of rules held by the agency in question, and the files of the secretary of state with whom most (but not all) rules were required to be filed.

From 1970 to 1978, the commissioner of administration issued the Minnesota State Regulations, a set of eleven loose-leaf volumes. This set collected rules previously published by individual agencies and contained no general index. In 1978, the title changed to Manual of State Agency Rules, but no other changes were made.

From 1978 to 1982, the commissioner of administration published the Minnesota Code of Agency Rules (MCAR). This set of fifteen green loose-leaf binders still provided no general index but did have a table of contents by agency. MCAR attempted the first uniform numbering scheme, but agencies retained control over the printing of their rules, and many rules were never renumbered. In addition, agencies controlled the sending of updates of compiled rules to subscribers to MCAR, and chaos resulted, with many inconsistencies between sets in different locations.

The legislature mandated sweeping changes in the publication of rules in chapter 615 of the 1980 Minnesota Laws. The authority of the commissioner of administration to publish MCAR was terminated as of July 1, 1982. Responsibility for publishing the new compilation, Minnesota Rules, was transferred to the Revisor of Statutes with the goal of making rules as accessible as statutes. The revisor was empowered to require that rules be submitted for publication in a standardized format prescribed by the revisor. As of January 1985, agencies otherwise exempt from the APA were also required to submit their rules to the revisor for publication in Minnesota Rules.

In 1982, the revisor issued the MCAR reprint in seventy paperbound pamphlets arranged by agency to fill the gap until the completion of Minnesota Rules. The MCAR reprint contains all rules in effect on September 15, 1982. The revisor’s office kept the old numbering scheme but attempted to correct filing errors; hence, the reprint contains rules not previously compiled.

The first edition of Minnesota Rules was published in 1983 in seven hardbound volumes. All rules are renumbered according to the new decimal scheme, and tables provide cross-references between old and new numbers. A new comprehensive index provides access to the entire set.

2.3.3 Rulemaking Aids

There are a number of publications that are of assistance to a person interested in participating in the rulemaking process. The Office of the Revisor of Statutes publishes Rulemaking in Minnesota: A Guide, written by Paul M. Marinac.[24] This publication sets out the steps in the rulemaking process for rules with a hearing, rules without a hearing, and exempt rules. Included are the relevant statutory and rule cites. The revisor also publishes the Minnesota Rules Drafting Manual with Styles and Forms.[25] The Manual contains guidelines on clear drafting, how to draft amendments, forms of citation and a style guide. It is helpful to a rulemaking participant who wishes to submit a proposed amendment or replacement to the agency. A detailed explanation of how to adopt rules is provided in the Minnesota Rulemaking Manual, authored by David Orren and Patricia Winget.[26] This helpful publication provides step-by-step instructions for agency rulewriters including help with such topics as rule development, developing the statement of need and reasonableness, and giving notice of the rulemaking. It includes checklists and forms.

2.4 Federal Regulations

Publication of federal administrative rules is an example of informal or “notice and comment” rulemaking. Unlike in Minnesota, there are typically no administrative hearings for rulemaking in the federal rulemaking process. Proposed and final rules as well as notices are initially published in the Federal Register[27], a daily publication since 1936.[28]

Final rules are then compiled into the Code of Federal Regulations (CFR), which is divided into fifty titles that correspond roughly with the titles of the United States Code. Each title of CFR is recompiled annually. The eCFR is an official version of the CFR that is frequently updated with Federal Register changes.[29] The date of the most recent update is prominently displayed on the eCFR’s homepage. The CFR (in print and the digital equivalent of the CFR[30]) is updated quarterly in stages, which requires updating with the List of CFR Sections Affected.[31]

Regulations.Gov[32] is a site that compiles proposed and final rules and allows the public to submit and track public comments, agency notices and supporting materials.

2.5 Decisions and Orders of Administrative Agencies

Administrative agency hearings may occur either during the rulemaking process[33] or in the context of contested cases. The contested case or trial-type hearings generally result in a decision or a final order being issued by the agency rather than the administrative law judge.

In 1975, the Minnesota Legislature created the Office of Administrative Hearings (renamed by statute in 2025 to the Court of Administrative Hearings (CAH)) to preside over hearings required by the Minnesota APA. The CAH has rulemaking authority, and its rules, which govern the conduct of rulemaking and contested case hearings, appear in Minnesota Rules chapter 1400. After a contested case hearing, the administrative law judge’s report containing findings of fact, conclusions, and a recommendation is filed with the agency, which then makes a final decision.

Some administrative law judge (ALJ) decisions are final rather than advisory. These final decisions and recommended decisions are often available at the CAH website.[34]

Older opinions are on file at the CAH[35], the Legislative Reference Library and the law library of Mitchell Hamline School of Law. Administrative Law Reports , also available at the Mitchell Hamline law library, summarizes ALJ decisions and related developments.[36] Some ALJ decisions are summarized in Finance and Commerce. Lexis, Westlaw, Bloomberg Law and vLex Fastcase all contain selected Minnesota ALJ decisions.

Agency decisions are not generally published for distribution but are usually available from the issuing agency, and sometimes from the Court of Administrative Hearings. Each administrative agency is responsible for maintaining the record of a contested case proceeding, including pleadings, exhibits, briefs, a transcript if one was prepared, and the recommended and final decisions. If no transcript has been prepared, the tapes of the hearing are retained at the Court of Administrative Hearings for five years.[37] Opinions of the State Ethical Practices Board and the Department of Human Rights were published in the State Register in 1976 and 1977. From 1977 to 2008, it contained only summaries of the opinions of the State Ethical Practices Board.[38] Some agencies include selected opinions or summaries of opinions in their annual reports (e.g., the Minnesota State Claims Commission Report and early reports of the Minnesota Railroad and Warehouse Commission). Beginning in 1993, the Commissioner of Administration began issuing opinions interpreting the Minnesota Government Data Practices Act.[39] These opinions are available from the Department of Administration,[40]which also maintains a topical index of Data Practices Act advisory opinions.[41]

Minnesota has two administrative courts that function in the executive, rather than the judicial, branch of government. The Tax Court[42] (formerly the Board of Tax Appeals) hears appeals by taxpayers from determinations by the commissioner of revenue with regard to taxes, fees, and assessments. Rules of the tax court are found on the Tax Court’s website and in Minnesota Rules chapters 8600 and 8610. Decisions of the tax court are published on the Tax Court’s website, on Bloomberg Law, Lexis and Westlaw. They may also appear in commercially published legal newspapers. Tax court decisions also appear in the Minnesota coverage of the Wolters Kluwer VitalLaw Tax Law product and Thomson Reuters Checkpoint.[43]

The workers’ compensation court of appeals is an independent appellate tribunal and hears appeals from decisions of compensation judges in the office of administrative hearings. The court’s rules appear in Minnesota Rules chapter 9800. Written opinions from 1999 to the present are available online in the Workers’ Compensation Decisions archive, which is available on the Minnesota Worker’s Compensation Court of Appeals website.[44] Mitchell Hamline School of Law in St. Paul, Minnesota has a complete historical collection of Minnesota Workers’ Compensation Decisions and full indexes.

For practitioners, Minnesota Continuing Legal Education (CLE) publishes a Minnesota Workers’ Compensation Deskbook[45] and regularly holds CLE seminars related to workers’ compensation topics.

The federal APA governs hearings in most federal agencies. Notices of hearings on proposed rules are published in the Federal Register. Decisions and orders of federal agencies in contested cases are published much more widely than are Minnesota agency decisions. In addition to their own websites, many federal agencies publish reports of their decisions on GovInfo.[46] These decisions are also frequently included in commercial research databases such as Lexis, Westlaw and Bloomberg Law.

2.6 Opinions of the Attorney General

The Minnesota attorney general issues opinions on state law to state agencies, public pension funds and local subdivisions of government. These opinions are advisory, except that in all school matters and some issues relating to the commissioner of revenue, opinions are binding until overturned by the courts. Since 1968, opinions of the Minnesota attorney general have been published monthly in the Minnesota Legal Register. Selected opinions or summaries also appear in other legal newspapers, such as Finance and Commerce. Attorney general opinions issued since 1970 are available on Lexis; opinions issued since 1977 are available on Westlaw. Opinions issued since 1993 are available on the Attorney General’s website.[47]

From 1894 to 1968, selected opinions were included in the attorney general’s biennial report. Compilations of selected opinions were published from 1858 to 1865, 1858 to 1885, and 1960 to 1968. These opinions were arranged by topic and numbered consecutively. Since 1934, the attorney general’s office has assigned classification numbers reflecting the topic of the opinion. A complete set of opinions from 1858 to date on microfiche is available from the Minnesota Attorney General’s Library.[48] These opinions are arranged both chronologically and by subject classification number. The library at Mitchell Hamline School of Law has a complete print collection of Attorney General opinions as well as the Minnesota Legal Register.

Due to the complexity of locating Minnesota Attorney General Opinions, it is recommended to consult with a law librarian or the Attorney General Library’s staff.[49]

There is no comprehensive index to attorney generals’ opinions. The attorney general’s office maintains the only complete list of the subject classifications by which opinions are numbered, although these classifications have been somewhat inconsistent. The Numerical Index to the Selected Opinions of the Minnesota Attorney General 1933-1969, compiled in 1976 by Barbara Golden, who went on to become State Law Librarian, provides a useful cross-reference from the subject classification numbers to the numbers assigned in the biennial reports, the 1960 to 1968 compilation, and volumes 1 and 2 of the Minnesota Legal Register. This allows the researcher with only the subject classification number to locate the opinion if it appears in one of the listed sources. There is a subject index covering 1894 to 1902 prepared by the public examiner, and one from 1910 to 1938 prepared by the Minnesota County Attorneys’ Association. There are also individual subject indexes in the biennial reports and annual volumes of the Minnesota Legal Register.

Minnesota Statutes Annotated includes references to attorney generals’ opinions in its annotations to statutory sections that have been the subject of an opinion. The opinions are cited by the year, number, and page in the biennial report. Shepard’s Minnesota Citations lists attorney generals’ opinions as citing references to cases but lists selected opinions in the biennial reports from 1902 to 1960 as cited references.

Selected Opinions of the Attorney General of the United States are published by the Office of Legal Counsel via their electronic reading room.[50] Official Opinions of the Attorneys General of the United States was the official print reporter of federal attorney generals’ opinions. It was replaced by Opinions of the Office of Legal Counsel. Official Opinions of the Attorneys General back to 1791 and Opinions of the Office of Legal Counsel 1977 to current are available on Westlaw, Lexis and HeinOnline.

2.7 Legislative Research

In many contested cases, as well as in judicial review of rules and contested cases, the parties are required to ascertain the legislative intent in the enactment of a statute. The rules of statutory construction provide that the legislative history is one factor to consider in ascertaining the intention of the legislature.[51] The Minnesota Supreme Court has recognized that where statutory language is not explicit, legislative history, such as committee reports, journal entries, and tape recordings of committee meetings or floor sessions may be probative.[52] While the court stated that statements made by legislators in committee or on the floor are to be treated with caution, it does accord some weight to statements made by the sponsor of a bill or amendment, as to its purpose or effect.[53]

The research materials available to track legislative action include the bills themselves, the daily Journals of the House and Senate, committee minute books, floor session logs, audiotapes of older committee hearings and video recordings for newer committee hearings as well as recorded floor sessions. The process of tracking down these materials is time-consuming and begins with a check of the history notes of the statute in question, which are printed in the statutes after each section. A researcher can then proceed from the session laws to the bill numbers, to the Journals, to the Committee minute books. An excellent step-by-step guide to this process is available on the Minnesota Legislative Reference Library website.[54]

Research into an agency’s intent in adopting a rule will usually lead to the Statement of Need and Reasonableness (SONAR) prepared by the agency in its rulemaking proceeding. Minnesota courts look to the SONAR in determining intent.[55] The SONAR is available at the agency with the rest of the rulemaking record. If a hearing was held the record may also contain a transcript if one was prepared. If no transcript was prepared the tapes of the hearing are maintained at the Court of Administrative Hearings for a period of five years. The rule record will also contain the written public comments on the rule and the report or order of the administrative law judge.

2.8 Secondary Sources in Administrative Law

In addition to primary administrative materials, secondary sources provide analysis and interpretation of administrative law principles. There are several sources that are commonly used references in the area of federal administrative law. Kenneth Culp Davis was one of the foremost administrative law scholars. His Administrative Law Treatise[56] is perhaps the most scholarly current work in the area. The Treatise is now in its seventh edition and is co-authored by Professors Kristin E. Hickman and Richard J. Pierce, Jr. Although the primary focus of the Treatise is federal law, a number of the topics are also relevant to state administrative law, such as investigations, evidence, estoppel, and res judicata to name a few. Another well-organized work whose focus is primarily federal law is Professor Charles H. Koch, Jr.’s Administrative Law and Practice.[57] Schwartz’s Administrative Law[58] is a single volume treatment of administrative law and procedure. It includes discussion of both federal and state law. In addition, there are myriad law review articles that delve into specific areas of administrative law. Two prominent journals with useful articles are the Administrative Law Review published by the Section of Administrative Law & Regulatory Practice of the American Bar Association through the Washington College of Law at American University and the Journal of the National Association of Administrative Law Judiciary published at the Pepperdine University Caruso School of Law.

Frank Cooper’s two-volume State Administrative Law[59] is a comprehensive treatment of the state perspective. Although it has not been updated since 1965, it remains a useful resource since it is organized by topics common to state administrative law.

Such comprehensive works have been widely replaced by state-specific treatises. A summary of Minnesota statutory and case law can be found in Dunnell Minnesota Digest.[60] A concise introduction to the topic of Minnesota administrative procedure can be found in Keppel and Gilbert’s Minnesota Administrative Practice and Procedure.[61] A more detailed treatment is found in Administrative Practice and Procedure[62] authored by William J. Keppel and published as a part of Westlaw’s Minnesota Practice Series. Particularly helpful to readers of this treatise are Professor Keppel’s sections on data practices (§ 4.04), the open meeting law (§ 4.05) and the availability of and timing of judicial review (chapters 12 and 13). A variety of continuing education publications provide additional guidance on the Minnesota law. Bench + Bar, Hennepin Lawyer, and Mitchell Hamline Law Journal of Public Policy and Practice are periodicals that provide coverage of the trends and changes in Minnesota administrative law. Bench + Bar’s Notes + Trends feature tracks new developments in Minnesota and federal case law, administrative law, and legislation across multiple practice areas.

The sole treatise dealing with state agency rulemaking is State Administrative Rule Making by Professor Arthur E. Bonfield.[63] The treatise is organized along the lines of the 1981 Model State Administrative Procedure Act[64] of which Professor Bonfield was the draftsman. However, the author has collected a wealth of state administrative law dealing with rulemaking, both in the original volume as well as the supplements.

Footnotes

  1. State Agencies, Boards, Commissions, Mn.gov, https://mn.gov/portal/government/state/agencies-boards-commissions/(last visited Aug. 5, 2026). ↑
  2. Minnesota Legislative Manual, Minnesota Secretary of State, https://www.sos.mn.gov/about-minnesota/get-a-blue-book/ (last visited Aug. 6, 2026). ↑
  3. Mn.gov, https://mn.gov/portal/government/state/agencies-boards-commissions/(last visited Aug. 5, 2026). ↑
  4. Minnesota Pollution Control Agency, https://www.pca.state.mn.us/ (last visited Oct. 8, 2026). ↑
  5. Commissioner’s Office, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/about-mpca/commissioners-office (last visited Aug. 6, 2026). ↑
  6. About us, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/about-mpca/about-us (last visited Aug. 6, 2026). ↑
  7. Legislative recommendations, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/about-mpca/legislative-recommendations (last visited Aug. 7, 2026). ↑
  8. Proposed rules, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/get-engaged/proposed-rules (last visited Aug. 7, 2026). ↑
  9. News and stories, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/news-and-stories (last visited Aug. 7, 2026). ↑
  10. Air permits, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/business-with-us/air-permits (last visited Aug. 7, 2026). ↑
  11. Water permits and regulations, Minnesota Pollution Control Agency, https://www.pca.state.mn.us/business-with-us/water-permits-and-regulations (last visited Aug. 7, 2026). ↑
  12. Administrative rules by state, ACR, https://administrativerules.org/administrative-rules/ (last visited Aug. 7, 2026). ↑
  13. State governments, usa.gov, https://www.usa.gov/state-governments (last visited Aug. 7, 2026). ↑
  14. United States Government Manual, https://www.usgovernmentmanual.gov/ (last visited Aug. 7, 2026). ↑
  15. USA.gov, https://www.usa.gov/ (last visited Aug. 7, 2026). ↑
  16. Minnesota State Register, Minnesota Department of Administration, https://mn.gov/admin/bookstore/register.jsp (last visited Aug. 10, 2026). ↑
  17. State Register, Office of the Revisor of Statutes, https://www.revisor.mn.gov/state_register/ (last visited Aug. 10, 2026). ↑
  18. See Minn. Stat. §§ 14.001–.69 (2025). ↑
  19. To see an example of the cumulative list of rules amended or repealed, see 39 Minn. Reg. 413, 416-17 (Sept. 29, 2014). ↑
  20. Minnesota Administrative Rules, Office of the Revisor of Statutes, https://www.revisor.mn.gov/rules/ (last visited Aug. 10, 2026). ↑
  21. Id. ↑
  22. See, e.g., 39 Minn. Reg. 413, 416-17 (Sept. 29, 2014). ↑
  23. Minnesota Rules Status, Office of the Revisor of Statutes, https://www.revisor.mn.gov/rules/rule_search.php (last visited Aug. 10, 2026) (“[The] beta version of a public administrative rule status system will allow you to follow many of the actions taken by state departments and agencies when they adopt administrative rules. It also provides access to historical rule information, documents and notices for rules adopted since 1980. This system will give you access to the entire State Register in searchable electronic form, over 2176 agency SONARs (statement of need and reasonableness), and over 1405 documents from the Office of Administrative Hearings…”). ↑
  24. Paul M. Marinac, Rulemaking in Minnesota: A Guide (2018), available at https://www.revisor.mn.gov/static/office/pubs/2018_all_rulemaking_guide.491681155472.pdf. ↑
  25. Office of the Revisor of Statutes, Minnesota Rules Drafting Manual with Styles and Forms (1997), https://www.revisor.mn.gov/static/office/1997_RuleDraftManual.a285c37112da.pdf. ↑
  26. Minnesota Rulemaking Manual (Andrea Barker, et al. eds., 2026) https://www.health.state.mn.us/data/rules/manual/docs/manual.pdf. ↑
  27. Federal Register, GovInfo, https://www.govinfo.gov/app/collection/FR/ (last visited Aug. 11, 2026). ↑
  28. HeinOnline’s Code of Federal Regulations database provides a comprehensive list of the Federal Register and Code of Federal Regulations (CFR) in PDF format. CFR coverage includes every annual issue from 1938 to current. List of CFR Sections Affected coverage includes 1958 to current. ↑
  29. Electronic Code of Federal Regulations (eCFR), https://www.ecfr.gov/ (last visited Aug. 11, 2026). ↑
  30. Code of Federal Regulation (Annual Edition), GovInfo, https://www.govinfo.gov/app/collection/cfr/ (last visited Aug. 11, 2026). ↑
  31. About the List of CFR Sections Affected, GovInfo, https://www.govinfo.gov/help/lsa (last visited Aug. 11, 2026). ↑
  32. About the eRulemaking Initiative, Regulations.Gov, https://www.regulations.gov/about (last visited Aug. 11, 2026). ↑
  33. Minn. Stat. §§ 14.14, 14.25 (2025) both require a hearing if more than twenty-five (25) comments are received on a proposed rule. ↑
  34. Administrative Law Archives, Court of Administrative Hearings, https://mn.gov/cah/media/opinion-archive.jsp (last visited Aug. 25, 2026). ↑
  35. See id. for instructions on requesting older decisions. ↑
  36. Administrative Law Reports, a monthly newsletter published from 1984 through August, 2026, summarizes reports and decisions of the office of administrative hearings. Its editor and publisher was Mary K. Martin, a St. Paul attorney. ↑
  37. Minn. R. 1400.7400 (2025). ↑
  38. In 1997, the State Ethics Commission was succeeded by the Campaign Finance and Public Disclosure Board. Reports are available via the Board’s website. ↑
  39. Minn. Stat. § 13.072, subd. 1 (2025). ↑
  40. Advisory Opinions, Minnesota Department of Administration, https://mn.gov/admin/data-practices/opinions/(last visited Sep. 23, 2026). ↑
  41. Topics Index, Minnesota Department of Administration, https://mn.gov/admin/data-practices/opinions/library/topics.jsp (last visited Sep. 23, 2026). ↑
  42. Minnesota Tax Court, https://mn.gov/tax-court/ (last visited Sep. 24, 2026). ↑
  43. These databases are available by subscription or through a local law library. ↑
  44. Minnesota Workers’ Compensation Court of Appeals, https://mn.gov/workcomp/ (last visited Sep. 24, 2026). ↑
  45. MN Workers’ Compensation Deskbook with eForms, Minnesota Continuing Legal Education, https://www.minncle.org/publication/50090726 (last visited Sep. 29, 2026). ↑
  46. GovInfo, https://www.govinfo.gov/ (last visited Oct. 1, 2026). ↑
  47. Attorney General Opinions, The Office of the Minnesota Attorney General, https://www.ag.state.mn.us/office/Opinions/Default.asp (last visited Oct. 1, 2026). ↑
  48. Id. ↑
  49. Complete information about the Minnesota Attorney General library can be found at Minnesota Attorney General Library, CALCO, https://www.mncapitollibraries.org/home/calco-libraries/attorney-general-library (last visited Oct. 1, 2026). ↑
  50. Opinions, U.S. Department of Justice: Office of Legal Counsel, https://www.justice.gov/olc/opinions-main (last visited Oct. 2, 2026). ↑
  51. Minn. Stat. § 645.16 (2025). ↑
  52. Handle with Care v. Dep’t of Human Servs., 406 N.W.2d 518, 522 (Minn. 1987) ↑
  53. Id. ↑
  54. A detailed guide to Minnesota legislative research can be found at Minnesota Legislative Reference Library, https://www.lrl.mn.gov/leg/history/histstep (last visited Oct. 2, 2026). ↑
  55. Boedingheimer v. Lake Country Transp., 485 N.W.2d 917, 920 (Minn. 1992); Ebenezer Soc’y v. Minn. Dep’t of Human Servs., 433 N.W.2d 436, 440 (Minn. Ct. App. 1988). ↑
  56. Kristin E. Hickman & Richard J. Pierce, Jr., Administrative Law Treatise (7th ed. 2024). ↑
  57. Charles H. Koch & Richard Murphy, Administrative Law and Practice (3d ed. 2010). ↑
  58. Bernard Schwartz et.al., Administrative Law: A Casebook (11th ed. 2026). ↑
  59. Frank E. Cooper, State Administrative Law (1965); see also Cheryl Rae Nyberg, State Administrative Law Bibliography: Print and Electronic Media Sources (2000). ↑
  60. 1 Dunnell Minn. Digest, Administrative Law §§ 1.00-app (7th ed. 2023). ↑
  61. William J. Keppel & Dayton Gilbert, Minnesota Administrative Practice and Procedure (1982). ↑
  62. William J. Keppel, Minnesota Practice Series: Administrative Practice and Procedure (2d ed., 2007). ↑
  63. Arthur Earl Bonfield, State Administrative Rule Making (1986 & Supp. 1993). ↑
  64. The Model State Administrative Procedure Act was revised and approved in 2010. Minnesota has not adopted it. ↑
← Chapter 3. Agency Investigations
Chapter 1. The Development of Administrative Procedure →


©2014-2026. Mitchell Hamline School of Law