Limmer v. Swanson, 806 N.W.2d 838

Petitioners filed a petition for writ of quo warranto on July 8, 2011 challenging the Ramsey County District Court's authority to authorize executive expenditures without legislative appropriations.
On July 19, 2011 the Legislature passed appropriations for all state agencies (except Agriculture) and the Governor signed them on July 20, 2011.
The appropriations were retroactive to July 1, 2011 and superseded funding authorized by the district court.
The court granted an order to show cause, responses were filed, and the Governor did not submit a substantive response.
The court dismissed the petition as moot because funding is now provided retroactively and no further district court funding proceedings are possible.
The court acknowledged possible mootness exceptions but declined to apply them, stating resolution of budget issues is preferable through political processes rather than advisory constitutional rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case is moot and must be dismissed.	petitioners contend ongoing issues remain.	Swanson argues appropriations render relief impossible.	Dismissed as moot.
Whether mootness exceptions apply to allow consideration of the constitutional questions.	petitioners claim statewide significance warrants exception.	majority: exceptions not applicable here.	No mootness exception applied.
Whether the case presents fundamental separation-of-powers questions requiring judicial decision.	questions about judiciary vs legislative/executive powers are important and justiciable.	political resolution preferred; not necessary to decide now.	Court declines to decide constitutional questions due to mootness.
Whether the district court had authority to authorize expenditures in absence of appropriation post June 30, 2011.	challenges authority of district court to fund state functions without appropriation.	mootness and legislative-executive mechanisms preclude ruling.	Not reached; case dismissed as moot.

In re Schmidt, 443 N.W.2d 824 (Minn. 1989) (mootness and justiciability considerations in statewide issues)
State v. Rud, 359 N.W.2d 573 (Minn. 1984) (statewide significance and separation of powers concepts)
Application of Minnegasco, 565 N.W.2d 706 (Minn. 1997) (situations where mootness exceptions may apply)
Fletcher v. Peck, 10 U.S. (6 Cranch) 87 (1810) (judicial restraint and limits of judicial review)
Marbury v. Madison, 5 U.S. (1 Cranch) 137 (1803) (judicial duty to say what the law is; limits of judicial action)
Republican Party of Minnesota v. White, 536 U.S. 765 (2002) (judicial independence and integrity as essential to the rule of law)