Brayton v. Pawlenty

PAGE, Justice

(concurring).

I concur in the opinion of the court that the exercise of unallotment authority at issue in this case was not authorized by *369the unallotment statute, Minn.Stat. § 16A.152, subd. 4 (2008). I write separately to highlight my concern that the unallotment statute confers on the executive branch such broad and uncircum-scribed authority to rewrite legislative spending decisions that it may constitute an unlawful delegation of legislative authority in violation of the separation of powers principle in our constitution.

Separation of powers is a core feature of our governmental structure, included in our state constitution based on the model of the United States Constitution.1 The principle originates from the concern “that if all power were concentrated in one branch of government, tyranny would be the natural and probable result.” Wulff v. Tax Court of Appeals, 288 N.W.2d 221, 222-23 (Minn.1979). Despite the fundamental nature of the separation of powers principle, we have recognized that “there has never been an absolute division of governmental functions in this country, nor was such even intended.” Id. at 223 (footnote omitted).

Although separation of powers does not require absolute separation of legislative and executive functions, we have long held that the separation of powers principle prohibits legislative delegation of pure legislative power, that is, the power to make the law. For example, in State v. Great Northern Railway Co., 100 Minn. 445, 111 N.W. 289 (1907), we struck down, on separation of powers grounds, a statute that authorized the Railroad and Warehouse Commission to approve capital stock increases for railroad corporations. Id. at 470-71, 111 N.W. at 290. We examined at length the necessary separation of powers distinction between permissible delegation of the power to ■ administer a law and impermissible delegation of the power to make the law. Id. at 475-81, 111 N.W. at 292-94. We stated that “ ‘[t]he true distinction is between the delegation of power to make the law, which necessarily involves a discretion as to what-it shall be, and the conferring of authority or'discretion to be exercised under and in pursuance of the law.’ ” Id. at 477, 111 N.W. at 293 (quoting State v. Chicago, Milwaukee & St. Paul Ry. Co., 38 Minn. 281, 300, 37 N.W. 782, 787-88 (1888), rev’d on other grounds, 134 U.S. 418, 10 S.Ct. 462, 33 L.Ed. 970 (1890)). We found the statute at issue constitutionally deficient because it committed “the whole subject of the increase of capital stock by railway corporations to the judgment and discretion of the commission.” Id. at 479, 111 N.W. at 294.

We reiterated this separation of powers principle in Lee v. Delmont, 228 Minn. 101, 36 N.W.2d 530 (1949). We explained that the separation of powers doctrine precludes the Legislature from delegating purely legislative power. Id. at 112, 36 N.W.2d at 538. We described “pure legislative power” as “the authority to make a complete law — complete as to the time it shall take effect and as to whom it shall apply — and to determine the expediency of its enactment.” Id. at 113, 36 N.W.2d at 538.

Under our definition of pure legislative power, the sweeping discretion granted by section 16A.152, subdivision 4, to modify and negate legislative spending decisions raises serious separation of powers concerns. The lack of direction in the Minne*370sota statute about how unallotment authority may be exercised once it is triggered leaves the executive branch with virtually unfettered discretion to decide which funds to cut entirely, which to reduce in some measure, and which to leave fully funded. Such decisions inevitably change the legislative priorities established in the properly enacted appropriations laws, and the grant in subdivision 4 of section 16A.152 to the executive branch of broad and uncircum-scribed authority to make such changes may run afoul of the separation of powers principle. Although we need not decide that issue today, the legislative and executive branches should be aware of that potential problem.

ANDERSON, PAUL H„ Justice (concurring).

I join in the concurrence of Justice Page.

. Article III, Section 1, of the Minnesota Constitution provides:

The powers of government shall be divided into three distinct departments: legislative, executive and judicial. No person or persons belonging to or constituting one of these departments shall exercise any of the powers properly belonging to either of the others except in the instances expressly provided in this constitution.