SF3316

SF3316 (Legislative Session 94 (2025-2026))

Administrative Procedure Act requirements addition to emphasize statutory authorization for rules and governor's statutory authority to authorize rules in an emergency rescindment provision

Related bill: HF3113

AI Generated Summary

Purpose of the Bill

The bill aims to update the Administrative Procedure Act by introducing new requirements that emphasize the need for clear statutory authorization when creating state government rules. It also limits the governor's power during emergencies concerning rule authorization and restricts how courts interpret agency rules.

Main Provisions

Statutory Authorization for Rules: Agencies must have explicit statutory authority when adopting new rules. This change is intended to ensure that any new rule is firmly based on existing law.
Emergency Powers: The bill removes the governor's ability to authorize new rules during emergencies, suggesting that such powers should have stricter checks.
Court Interpretation: Courts will not defer to an agency's interpretation of its rules. This means that courts will independently assess what the rules mean instead of primarily relying on the agency's explanation.

Significant Changes to Existing Law

The bill amends several sections of the Minnesota Statutes related to administrative procedures and emergency powers.
It clarifies that agency guidance documents are not considered rules unless they go through the formal rule adoption process, providing more transparency and accountability.

Relevant Terms

Administrative Procedure Act
Statutory Authorization
Emergency Powers
Agency Rule Interpretation
Court Deference

Bill text versions

Introduction PDF file

Actions

Date	Chamber	Where	Type	Name	Committee Name
April 06, 2025	Senate	Floor	Action	Introduction and first reading
April 06, 2025	Senate	Floor	Action	Referred to	State and Local Government

Citations

[
  {
    "analysis": {
      "added": [],
      "removed": [
        "Rescinds governor's authority to authorize rules in an emergency."
      ],
      "summary": "This bill modifies the governor's statutory authority to authorize emergency rules under section 12.21, subdivision 3.",
      "modified": []
    },
    "citation": "12.21",
    "subdivision": "subdivision 3"
  },
  {
    "analysis": {
      "added": [
        "Clarifies that agency guidance documents are not considered rules unless formal adoption procedures are followed."
      ],
      "removed": [],
      "summary": "This bill amends the definition of 'rule' in the context of agency statements under section 14.02, subdivision 4.",
      "modified": [
        "Specifies applicability and enforcement details for agency rules."
      ]
    },
    "citation": "14.02",
    "subdivision": "subdivision 4"
  },
  {
    "analysis": {
      "added": [
        "Emphasizes necessity for statutory authorization in rulemaking."
      ],
      "removed": [],
      "summary": "This bill updates procedures related to rulemaking authority under section 14.05, subdivision 1.",
      "modified": []
    },
    "citation": "14.05",
    "subdivision": "subdivision 1"
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "This section is modified to adjust the analysis procedures required for rule implementation.",
      "modified": [
        "Adjusts the requirements for analysis of rules' impact and necessity."
      ]
    },
    "citation": "14.131",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "This section is revised to reflect changes in the timing and process of rule publication.",
      "modified": [
        "Modifies how and when rules are published and take effect."
      ]
    },
    "citation": "14.365",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [
        "Enhances public participation requirements in rulemaking procedures."
      ],
      "removed": [],
      "summary": "Amends the requirements for public participation in the rulemaking process.",
      "modified": []
    },
    "citation": "14.366",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [
        "Adds new subdivision outlining rule review procedures."
      ],
      "removed": [],
      "summary": "Implements additional subdivisions related to requirements for rule review.",
      "modified": []
    },
    "citation": "14.37",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "This section addresses the court's role in reviewing agency rules.",
      "modified": [
        "Specifies that courts should not defer to agency interpretation of rules."
      ]
    },
    "citation": "14.44",
    "subdivision": ""
  },
  {
    "analysis": {
      "added": [],
      "removed": [],
      "summary": "Section modified to clarify judicial review standards for agency rules.",
      "modified": [
        "Details standards and criteria for judicial review of agency rules."
      ]
    },
    "citation": "14.69",
    "subdivision": ""
  }
]