Hennepin County District Court File No. PI02010663
Considered and decided by Wright, Presiding Judge, Lansing, Judge, and
The rational-basis test is the proper constitutional standard to apply to an equal-protection challenge to Minn. Stat. § 466.12, subd. 3a (2002), which provides a school district immunity from tort liability if it is unable to obtain insurance in accordance with the statutory guidelines.
The opinion of the court was delivered by: Wright, Judge
Affirmed in part, reversed in part, and remanded
Appellants David and Marlyss Granville and Jacqueline Johnson (appellants collectively) are parents of African-American students who were injured in a physical education class at Loring Elementary School in Minneapolis. Appellants filed a lawsuit against respondent Minneapolis Public Schools, Special School District No. 1 (the school district), which moved to dismiss all claims pursuant to Minn. R. Civ. P. 12.02(e) based on immunity granted by operation of Minn. Stat. § 466.12, subd. 3a (2002). After appellants challenged the constitutionality of the provision, the district court dismissed the claims, ruling that section 466.12, subdivision 3a, is constitutional and protects the school district from tort liability. Appellants contend that the district court erred when it dismissed appellants' claims because the statute violates the Equal Protection Clauses of the United States and Minnesota Constitutions. We affirm in part, reverse in part, and remand.
On November 1, 2001, Loring Elementary School students Shanel Andrews and Kailynn Granville, who are African American, were injured while participating in a game of "flashlight tag" during physical education class. The parents of both children sued the school district to recover for personal injuries. The school district moved to dismiss the suit pursuant to Minn. R. Civ. P. 12.02(e), asserting that it is immune from tort liability under Minn. Stat. § 466.12, subd. 3a (2002), which provides immunity for school districts that are unable to obtain insurance for an average rate of $1.50 or less per pupil. Appellants countered that Minn. Stat. § 466.12, subd. 3a, violates the Equal Protection Clauses of the United States and Minnesota Constitutions. The district court granted respondent's motion to dismiss. These consolidated appeals followed.
Did the district court err when it ruled that, as applied to appellants, Minn. Stat. § 466.12, subd. 3a (2002), is constitutional?
When reviewing a dismissal for failure to state a claim on which relief can be granted pursuant to Rule 12.02(e), we determine whether the complaint sets forth a legally sufficient claim for relief. Bodah v. Lakeville Motor Express, Inc., 663 N.W.2d 550, 553 (Minn. 2003); Elzie v. Comm'r of Pub. Safety, 298 N.W.2d 29, 32 (Minn. 1980). We, therefore, apply a de novo standard of review. Bodah, 663 N.W.2d at 553. "[I]t is immaterial whether or not the plaintiff can prove the facts alleged, and [an appellate court] will not uphold a Rule 12.02(e) dismissal if it is possible on any evidence which might be produced, consistent with the pleader's theory, to grant the relief demanded[.]" Martens v. Minn. Min. & Mfg. Co., 616 N.W.2d 732, 739-40 (Minn. 2000) (quotation and citations omitted). We consider only the facts alleged in the complaint, accept those facts as true, and construe all reasonable inferences in favor of the nonmoving party. Bodah, 663 N.W.2d at 553.
We must determine whether the district court erred when it ruled that, as applied to appellants, Minn. Stat. §á466.12, subd. 3a (2002), does not violate the Equal Protection Clause of either the United States Constitution or the Minnesota Constitution. "Evaluating a statute's constitutionality is a question of law." Hamilton v. Comm'r of Pub. Safety, 600 N.W.2d 720, 722 (Minn. 1999). Accordingly, we are not bound by the district court's conclusions. In re Blilie, 494 N.W.2d 877, 881 (Minn. 1993) (quoting Sherek v. Indep. Sch. Dist. No. 699, Gilbert, 449 N.W.2d 434, 436 (Minn. 1990)). Minnesota statutes enjoy a presumption of constitutionality, and ...