equal protection clause in Minnesota

2025Minnesota courts “routinely reject[]” equal-protection claims when a party cannot make the threshold showing that they are “similarly situated to those whom they contend are being treated differently.” State v. Cox, 798 N.W.2d 517, 521 (Minn. 2011); see also Holloway, 916 N.W.2d at 347 (noting that, to establish an equal- protection claim, a claimant must show that they are “treated differently from others to whom the claimant is similarly situated in all relevant respects” (quotation omitted)).

2018A. "The threshold question in an equal protection claim is whether the claimant is treated differently from others to whom the claimant is similarly situated in all relevant respects." Johnson , 813 N.W.2d at 12 ; see also State v. Cox , 798 N.W.2d 517 , 521 (Minn. 2011) ("[T]he Equal Protection Clause ... keeps governmental decisionmakers from treating differently persons who are in all relevant respects alike." (citation omitted) (internal quotation marks omitted) ). "[T]he Equal Protection Clause does not require that the State treat persons who are differently situated as though they were

2023Redistricting Comm’n, 578 U.S. 253, 259 (2016) (holding that redistricting plans “with a maximum population deviation under 10%” do not raise an inference that the Fourteenth Amendment’s “one person, one vote” command has been violated) (citation omitted); Miller-El v. Dretke, 545 U.S. 231, 265–66 (2005) (comparing statistical disparities in voir dire questioning by prosecutors to analyze whether peremptory challenges were used to unconstitutionally exclude jurors on the basis of race); Castaneda v. Partida, 430 U.S. 482, 495–96 (1977) (comparing disparities between racial groups on a grand ju

2023Redistricting Comm’n, 578 U.S. 253, 259 (2016) (holding that redistricting plans “with a maximum population deviation under 10%” do not raise an inference that the Fourteenth Amendment’s “one person, one vote” command has been violated) (citation omitted); Miller-El v. Dretke, 545 U.S. 231 , 265–66 (2005) (comparing statistical disparities in voir dire questioning by prosecutors to analyze whether peremptory challenges were used to unconstitutionally exclude jurors on the basis of race); Castaneda v. Partida, 430 U.S. 482 , 495–96 (1977) (comparing disparities between racial groups on a grand

1984The Minnesota Supreme Court has set forth the standards which must be applied in determining whether a law denies a party equal protection of the law: This court has listed three factors in measuring a statutory classification against the equal protection requirement: “(1) The distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs; (2) the classification must be genuin

1981As we recently stated in Guilliams v. Commissioner of Revenue, 299 N.W.2d 138, 142 (Minn.1980), This court has listed three factors in measuring a statutory classification against the equal protection requirement: “(1) The distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs; (2) the classification must be genuine or relevant to the purpose of the law; that is, there

2019Distillers , 229 N.W.2d at 156 (denying an equal-protection challenge to a statute requiring all licensed distillers of liquor to offer their products for sale to all Minnesota wholesalers on an equal basis but not extending that requirement to include wines and malt beverages). "[O]nly invidious discrimination is deemed constitutionally offensive." Garcia , 683 N.W.2d at 298 (quotation omitted). *427 We review an equal-protection challenge under a rational-basis standard unless the challenge involves a suspect classification or a fundamental right.

2016We review an equal protection challenge to a statute “under a rational basis standard unless the challenge involves a suspect classification or a fundamental right.” State v. Garcia, 683 N.W.2d 294, 298 (Minn. 2004).

2011In State v. Witt, we stated that “[t]he sole limitation which the equal protection clause imposes upon the legislature in the exercise of this power is that criminal statutes must not prescribe different punishments for the same acts committed under the same circumstances by persons in like situation.” 310 Minn. 211, 215 , 245 N.W.2d 612, 616 (1976) (citation omitted) (internal quotation marks omitted).

2011In State v. Witt, we stated that “[t]he sole limitation which the equal protection clause imposes upon the legislature in the exercise of this power is that criminal statutes must not prescribe different punishments for the same acts committed under the same circumstances by persons in like situation.” 310 Minn. 211, 215 , 245 N.W.2d 612, 616 (1976) (citation omitted) (internal quotation marks omitted).

2002See State v. Merrill, 450 N.W.2d 318, 321 (Minn.1990) (“The equal protection clause of the Fourteenth Amendment requires that all persons similarly situated be treated alike under the law.”); In re Harhut, 385 N.W.2d 305, 310 (Minn.1986) (“The equal protection clauses of the federal and state constitutions require that all persons similarly situated be treated alike under the law.”).

2002See State v. Merrill, 450 N.W.2d 318, 321 (Minn.1990) ("The equal protection clause of the Fourteenth Amendment requires that all persons similarly situated be treated alike under the law."); In re Harhut, 385 N.W.2d 305, 310 (Minn.1986) ("The equal protection clauses of the federal and state constitutions require that all persons similarly situated be treated alike under the law.").

1981Following the holding in Hamm v. State, 225 Minn. 64 , 95 N.W.2d 649 (1959), this court recently concluded there must be a substantial disparity in assessment ratios before an equal protection violation is found.

1980In the leading case of Hamm v. State, 255 Minn. 64, 70 , 95 N.W.2d 649, 654-55 (1959), this court declared: “discrimination in the imposition of the tax burden, resulting from systematic, arbitrary, or intentional undervaluation of some property as compared to the valuation of other property in the same class, violates the uniformity clause of Minn.Const. art. 9, § 1, and the equal-protection clause of U.S.Const.

2014See State v. Frazier, 649 N.W.2d 828, 833-34 (Minn.2002) (explaining that to prevail on an equal-protection challenge where the challenged statute did not, on its face, classify on the basis of race, the challenger had to “demonstrate that the statute create[d] a racial classification in practice”); McCannel, 301 N.W.2d at 916 (stating that “the equal protection clause provides protection against arbitrary discrimination resulting from the express terms of a statute as well as from a statute’s improper execution”); State v. Stewart, 529 N.W.2d 493, 497 (Minn.App.1995) (holding that an ordinanc

2014See State v. Frazier, 649 N.W.2d 828, 833-34 (Minn.2002) (explaining that to prevail on an equal-protection challenge where the challenged statute did not, on its face, classify on the basis of race, the challenger had to “demonstrate that the statute create[d] a racial classification in practice”); McCannel, 301 N.W.2d at 916 (stating that “the equal protection clause provides protection against arbitrary discrimination resulting from the express terms of a statute as well as from a statute’s improper execution”); State v. Stewart, 529 N.W.2d 493, 497 (Minn.App.1995) (holding that an ordinanc

2016The “threshold question” in an equal-protection claim “is whether the claimant is treated differently from others who are similarly situated.” Odunlade v. City of Minneapolis, 823 N.W.2d 638, 647 (Minn. 2012). “[W]e routinely reject equal-protection claims when a party cannot establish that he or she is similarly situated to those whom they contend are being treated differently.” Id. (quotation omitted).

2016The “threshold question” in an equal-protection claim “is whether the claimant is treated differently from others who are similarly situated.” Odunlade v. City of Minneapolis, 823 N.W.2d 638, 647 (Minn. 2012). “[W]e routinely reject equal-protection claims when a party cannot establish that he or she is similarly situated to those whom they contend are being treated differently.” Id. (quotation omitted).

2014See State v. Frazier, 649 N.W.2d 828, 833-34 (Minn.2002) (explaining that to prevail on an equal-protection challenge where the challenged statute did not, on its face, classify on the basis of race, the challenger had to “demonstrate that the statute create[d] a racial classification in practice”); McCannel, 301 N.W.2d at 916 (stating that “the equal protection clause provides protection against arbitrary discrimination resulting from the express terms of a statute as well as from a statute’s improper execution”); State v. Stewart, 529 N.W.2d 493, 497 (Minn.App.1995) (holding that an ordinanc

2014See State v. Frazier, 649 N.W.2d 828, 833-34 (Minn.2002) (explaining that to prevail on an equal-protection challenge where the challenged statute did not, on its face, classify on the basis of race, the challenger had to “demonstrate that the statute create[d] a racial classification in practice”); McCannel, 301 N.W.2d at 916 (stating that “the equal protection clause provides protection against arbitrary discrimination resulting from the express terms of a statute as well as from a statute’s improper execution”); State v. Stewart, 529 N.W.2d 493, 497 (Minn.App.1995) (holding that an ordinanc

2007In re Estate of Turner, 391 N.W.2d 767, 769 (Minn.1986).

2007Turner, 391 N.W.2d at 769 (Minn.1986) (quoting Ferguson v. Skrupa, 372 U.S. 726, 732 , 83 S.Ct. 1028 , 10 L.Ed.2d 93 (1963)).

1991See Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456, 466 , 101 S.Ct. 715, 725 , 66 L.Ed.2d 659 (1981) (holding that a ban on one type of environmentally harmful container does not violate the equal protection clause merely because use of another harmful container is permitted to continue).

1991See Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456, 466 , 101 S.Ct. 715, 725 , 66 L.Ed.2d 659 (1981) (holding that a ban on one type of environmentally harmful container does not violate the equal protection clause merely because use of another harmful container is permitted to continue).

2011In Scott , we stated that our equal protection analysis “begin[s] with the mandate that all similarly situated individuals shall be treated alike, but only ‘invidious discrimination’ is deemed constitutionally of fensive.” 615 N.W.2d at 74 (citation omitted).

2001Unless an equal protection challenge “involves a suspect classification or a fundamental right, we review the challenge under a rational basis standard under both the state and federal constitutions.” Id.

1984The Minnesota Supreme Court has set forth the standards which must be applied in determining whether a law denies a party equal protection of the law: This court has listed three factors in measuring a statutory classification against the equal protection requirement: “(1) The distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs; (2) the classification must be genuin

1981As we recently stated in Guilliams v. Commissioner of Revenue, 299 N.W.2d 138, 142 (Minn.1980), This court has listed three factors in measuring a statutory classification against the equal protection requirement: “(1) The distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs; (2) the classification must be genuine or relevant to the purpose of the law; that is, there

1984The equal protection clause “requires that a legislative classification apply uniformly to all those similarly situated; that the distinctions separating those who are included within the classification from those who are excluded are not arbitrary or capricious, but instead are real and substantial; and that the classification is consonant with a lawful purpose.” Kossak v. Stalling, 277 N.W.2d 30, 34 (Minn.1979).

1984In Kossak , we ruled that the one-year statute of limitations provided for in the Municipal Tort Liability Act, Minn.Stat. § 466.05 (1971), violated the equal protection clause of the federal constitution. 277 N.W.2d at 35 .

1968Because we have held these provisions of the Minnesota Constitution to have the same meaning as the equal protection clause of the U. S. Constitution, *452 Minneapolis Federation of Teachers v. Obermeyer, 275 Minn. 347, 354 , 147 N. W. (2d) 358, 363 , and because the same should be true as to due process, we shall refer only to the Fourteenth Amendment, with the understanding that what we hold as to the one is equally applicable as to the others. 19 A corollary contention, buttressing the contention of unconstitutional purpose, is that the resulting statutory scheme is so irrational and unwork

1968Because we have held these provisions of the Minnesota Constitution to have the same meaning as the equal protection clause of the U. S. Constitution, *452 Minneapolis Federation of Teachers v. Obermeyer, 275 Minn. 347, 354 , 147 N. W. (2d) 358, 363 , and because the same should be true as to due process, we shall refer only to the Fourteenth Amendment, with the understanding that what we hold as to the one is equally applicable as to the others. 19 A corollary contention, buttressing the contention of unconstitutional purpose, is that the resulting statutory scheme is so irrational and unwork

2018"Under an equal protection analysis, we determine whether a statute treats similarly situated individuals differently and, if so, whether the statute survives strict scrutiny, or rational basis review." Schatz v. Interfaith Care Ctr. , 811 N.W.2d 643 , 656 (Minn. 2012).

2013See Schatz, 811 N.W.2d at 657 (explaining that when a party cannot show that he or she is similarly situated to an individual being treated differently, the party’s equal protection claim necessarily fails).

2018A. "The threshold question in an equal protection claim is whether the claimant is treated differently from others to whom the claimant is similarly situated in all relevant respects." Johnson , 813 N.W.2d at 12 ; see also State v. Cox , 798 N.W.2d 517 , 521 (Minn. 2011) ("[T]he Equal Protection Clause ... keeps governmental decisionmakers from treating differently persons who are in all relevant respects alike." (citation omitted) (internal quotation marks omitted) ). "[T]he Equal Protection Clause does not require that the State treat persons who are differently situated as though they were

2018A. "The threshold question in an equal protection claim is whether the claimant is treated differently from others to whom the claimant is similarly situated in all relevant respects." Johnson , 813 N.W.2d at 12 ; see also State v. Cox , 798 N.W.2d 517 , 521 (Minn. 2011) ("[T]he Equal Protection Clause ... keeps governmental decisionmakers from treating differently persons who are in all relevant respects alike." (citation omitted) (internal quotation marks omitted) ). "[T]he Equal Protection Clause does not require that the State treat persons who are differently situated as though they were

2015While we have applied such a test in certain equal protection cases, we need not decide whether or how to apply it here, because we can decide the case without great difficulty by applying the proper degree of scrutiny to the classifications created by the Legislature. 3 If an equal protection challenge under the Minnesota Constitution involves either a suspect classification or a fundamental right, we apply strict scrutiny, which requires the classification to be “narrowly tailored and reasonably necessary to further a compelling governmental interest.” See Greene v. Comm’r of Minn. Dep’t of

2010“An essential element of an equal-protection claim is that the persons claiming disparate treatment must be similarly situated to those to whom they compare themselves.” Id.

1993City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432, 440 , 105 S.Ct. 3249, 3254 , 87 L.Ed.2d 313 (1985).

1993City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432, 440 , 105 S.Ct. 3249, 3254 , 87 L.Ed.2d 313 (1985).

1974Reed v. Bjornson, 191 Minn. 254, 261 , 253 N. W. 102, 105 (1934); Apartment Operators Assn. v. City of Minneapolis, 191 Minn. 365, 366 , 254 N. W. 443 (1934); In re Taxes on Property of Cold Spring Granite Co. 271 Minn. 460, 466 , 136 N. W. 2d 782, 787 (1965).

1974Reed v. Bjornson, 191 Minn. 254, 261 , 253 N. W. 102, 105 (1934); Apartment Operators Assn. v. City of Minneapolis, 191 Minn. 365, 366 , 254 N. W. 443 (1934); In re Taxes on Property of Cold Spring Granite Co. 271 Minn. 460, 466 , 136 N. W. 2d 782, 787 (1965).

2009Our analysis of the conduct at issue in these tax cases seems to have been driven in part by the Uniformity Clause in the Minnesota Constitution, Article X, Section 1, which provides that "[t]axes shall be uniform upon the same class of subjects." See United Nat'l, 299 N.W.2d at 77 n. 5 ("In clarifying today that a taxpayer need not demonstrate intentional discrimination in the valuation of property for tax purposes[,]... we observe that the requirements under the uniformity clause of the state constitution and the equal protection clause of the federal Constitution are not coterminous.").

2009Our analysis of the conduct at issue in these tax cases seems to have been driven in part by the Uniformity Clause in the Minnesota Constitution, Article X, Section 1, which provides that "[tjaxes shall be uniform upon the same class of subjects." See United Nat’l, 299 N.W.2d at 77 n. 5 ("In clarifying today that a taxpayer need not demonstrate intentional discrimination in the valuation of property for tax purposes!,] ... we observe that the requirements under the uniformity clause of the state constitution and the equal protection clause of the federal Constitution are not coterminous.”).

1998J. 93 (1996); see also State v. Gaitan, 536 N.W.2d 11, 18-20 (1995) (Page, J. dissenting). [18] 514 U.S. 765 , 115 S.Ct. 1769 , 131 L.Ed.2d 834 (1995). [19] See generally State v. Russell, 477 N.W.2d 886, 889 (Minn.1991) (noting that the Minnesota Supreme Court may apply a "more stringent standard of review" as a matter of state law under the state constitution's equivalent to the federal constitution's equal protection clause). [20] Batson, 476 U.S. at 102-03 , 106 S.Ct. 1712 . [21] Morris B.

1998J. 93 (1996); see also State v. Gaitan, 536 N.W.2d 11, 18-20 (1995) (Page, J. dissenting). [18] 514 U.S. 765 , 115 S.Ct. 1769 , 131 L.Ed.2d 834 (1995). [19] See generally State v. Russell, 477 N.W.2d 886, 889 (Minn.1991) (noting that the Minnesota Supreme Court may apply a "more stringent standard of review" as a matter of state law under the state constitution's equivalent to the federal constitution's equal protection clause). [20] Batson, 476 U.S. at 102-03 , 106 S.Ct. 1712 . [21] Morris B.

2013Id. at 889-90 ; Mitchell v. Steffen, 487 N.W.2d 896, 904 (Minn.App.1992), aff'd, 504 N.W.2d 198 (Minn.1993) (analyzing the equal-protection claim under the U.S. Constitution only).

2012This court has held that the Minnesota rational-basis test “applies when analyzing any case under the equal protection clause of the Minnesota Constitution.” Mitchell v. Steffen, 487 N.W.2d 896 , 904 n. 2 (Minn.App.1992), affd, 504 N.W.2d 198 (Minn.1993). 3 But in the context of analyzing a workers’ compensation statute, the supreme court in Gluba declined to infer from the language or structure of the Minnesota rational-basis test that a higher standard than the federal standard applies to matters concerning the regulation of economic activity and the distribution of economic benefits. 735 N.

2013Id. at 889-90 ; Mitchell v. Steffen, 487 N.W.2d 896, 904 (Minn.App.1992), aff'd, 504 N.W.2d 198 (Minn.1993) (analyzing the equal-protection claim under the U.S. Constitution only).

2012This court has held that the Minnesota rational-basis test “applies when analyzing any case under the equal protection clause of the Minnesota Constitution.” Mitchell v. Steffen, 487 N.W.2d 896 , 904 n. 2 (Minn.App.1992), affd, 504 N.W.2d 198 (Minn.1993). 3 But in the context of analyzing a workers’ compensation statute, the supreme court in Gluba declined to infer from the language or structure of the Minnesota rational-basis test that a higher standard than the federal standard applies to matters concerning the regulation of economic activity and the distribution of economic benefits. 735 N.

1993Here the respondents’ claim does not involve either a suspect classification, as identified by the United States Supreme Court, nor does it implicate a fundamental right. 4 The standard of review to be used when measuring classifications created by a public welfare benefit statute against an equal protection claim was established in Jefferson v. Hackney, 406 U.S. 535 , 92 S.Ct. 1724 , 32 L.Ed.2d 285 (1972), and Dandridge, 397 U.S. 471 , 90 S.Ct. 1153 .

1993Here the respondents’ claim does not involve either a suspect classification, as identified by the United States Supreme Court, nor does it implicate a fundamental right. 4 The standard of review to be used when measuring classifications created by a public welfare benefit statute against an equal protection claim was established in Jefferson v. Hackney, 406 U.S. 535 , 92 S.Ct. 1724 , 32 L.Ed.2d 285 (1972), and Dandridge, 397 U.S. 471 , 90 S.Ct. 1153 .