812 N.W.2d 826
Minn.2012Background
- Dispute over which county bears financial responsibility for S.M.'s out-of-home placement costs after Oct. 1, 2008.
- MDHS order dated Apr. 20, 2010 held Nobles County responsible.
- Nobles County district court reversed MDHS, concluding Brown County followed from the legislative history of Minn.Stat. § 256G.10.
- Court of Appeals affirmed the district court in In re S.M., 806 N.W.2d 79 (Minn.App.2011).
- Brown County petitioned for review, and the supreme court held the statute unambiguous and Nobles County responsible based on May 16, 2008 eligibility and the mother’s residence in Nobles County.
- (Date of eligibility for services was May 16, 2008; S.M. last resided with his mother in Brown County in March 2008, but the mother resided in Nobles County when eligibility occurred.)
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Minn.Stat. § 256G.10 ambiguous? | Brown County argues §256G.10 is unambiguous. | Nobles County argues ambiguity exists requiring interpretation favors last-resided county. | §256G.10 is unambiguous. |
| How is the residence for financial responsibility determined? | Residency determined by where parent and child last lived together in nonexcluded time. | Residency determined by the county where the parent resided when the child last lived with the parent. | Residence determined by the parent’s residence on the date of eligibility; Nobles County resident on May 16, 2008 governs. |
Key Cases Cited
- Swanson v. Brewster, 784 N.W.2d 264 (Minn.2010) (statutory ambiguity assessment and interpretive approach)
- Frank’s Nursery Sales, Inc. v. City of Roseville, 295 N.W.2d 604 (Minn.1980) (plain meaning controls when language is clear)
- Am. Family Ins. Grp. v. Schroedl, 616 N.W.2d 273 (Minn.2000) (statutory interpretation principles; whole-text construction)
- State v. Engle, 743 N.W.2d 592 (Minn.2008) (de novo review of statutory interpretation)
- State v. Mauer, 741 N.W.2d 107 (Minn.2007) (statutory interpretation and application to facts)
- State v. Al-Naseer, 734 N.W.2d 679 (Minn.2007) (interpretation of statutory provisions)