Patrick H. Horan, Relator v. Department of Employment and Economic Development, A16-675

Horan received Social Security early-retirement benefits in April 2013; those were converted to disability benefits in Sept. 2013 when he began working.
From Sept. 2013 to March 2015 Horan received disability benefits; upon turning 66 in March 2015 his disability benefits were terminated and he began receiving old-age (retirement) benefits.
Horan worked as a bus driver through Dec. 2014 and was terminated in Jan. 2015; he applied for Minnesota unemployment benefits during the relevant base period (Oct. 1, 2014–Sept. 30, 2015).
The Department reduced Horan’s weekly unemployment benefits by 50% of the weekly equivalent of his Social Security old-age benefit under Minn. Stat. § 268.085 because he did not earn all his wage credits while receiving old-age benefits (and did not meet the disability-exemption requirements).
The ULJ affirmed; this court previously reversed a related ULJ misconduct denial and here affirms the benefit reduction on certiorari review.

Issue	Horan's Argument	Department's Argument	Held
Whether § 268.085 requires a 50% deduction when claimant received both disability and old-age benefits during the base period	Statute is ambiguous and should cover claimants who received both benefits; he should get full benefits	Plain text requires deduction unless claimant earned all wage credits while on old-age benefits or SSA approved disability collection for each employed month	The statute’s plain language applies; 50% deduction required because Horan did not meet either exemption
Whether omission of an exemption for mixed-benefit claimants renders the statute ambiguous	Legislative silence creates ambiguity that should favor relief	Omission is a deliberate bright-line rule; courts cannot rewrite statute	Not ambiguous; court will not supply omitted exemption
Whether applying § 268.085 to Horan violates equal protection	He is similarly situated to claimants who earned most or all wage credits while on benefits and thus faces arbitrary discrimination	Horan is not similarly situated to exempt groups because he earned fewer months of credits while on old-age/disability benefits	Horan fails the similarly situated threshold; equal-protection challenge fails
Standard of review for statutory construction and constitutionality	N/A (argues for favorable construction)	Statutory construction and constitutionality reviewed de novo; statutes presumed constitutional	De novo review applied; statute upheld as rational and constitutional

Emerson v. School Bd. of Indep. Sch. Dist. 199, 809 N.W.2d 679 (Minn. 2012) (statutory-construction standard)
Bolter v. Wagner Greenhouses, 754 N.W.2d 665 (Minn. 2008) (court must not supply legislative omissions)
State Farm Mut. Auto. Ins. Co. v. Lennartson, 872 N.W.2d 524 (Minn. 2015) (silence requires ambiguity to look beyond text)
Rohmiller v. Hart, 811 N.W.2d 585 (Minn. 2012) (courts may not supply what legislature omitted)
Haugen v. Superior Dev., Inc., 819 N.W.2d 715 (Minn. App. 2012) (constitutional-review standard)
State v. Barker, 705 N.W.2d 768 (Minn. 2005) (presumption of statutory constitutionality)
State v. Johnson, 813 N.W.2d 1 (Minn. 2012) (equal-protection principles and similarly situated requirement)
State v. Garcia, 683 N.W.2d 294 (Minn. 2004) (invidious discrimination standard for equal protection)