Mathews factors in Minnesota

2025See 424 N.W.2d at 69 ; cf. Olson v. One 1999 Lexus MN License Plate No. 851LDV, 924 N.W.2d 594, 606 (Minn. 2019) (“The Mathews factors are more than a checklist of items to be ticked through selectively or by rote.”); State v. Mikell, 960 N.W.2d 230 , 245 (Minn. 2021) (“This is not a check-the-box, prescriptive analysis; rather, we assess how the factors interact with each other in a difficult and sensitive balancing process . . . .” (citation omitted) (internal quotations marks omitted)). 17 We therefore conclude that, when determining whether an employee has rebutted the retirement presumpti

2025See 424 N.W.2d at 69 ; cf. Olson v. One 1999 Lexus MN License Plate No. 851LDV, 924 N.W.2d 594, 606 (Minn. 2019) (“The Mathews factors are more than a checklist of items to be ticked through selectively or by rote.”); State v. Mikell, 960 N.W.2d 230 , 245 (Minn. 2021) (“This is not a check-the-box, prescriptive analysis; rather, we assess how the factors interact with each other in a difficult and sensitive balancing process . . . .” (citation omitted) (internal quotations marks omitted)). 17 We therefore conclude that, when determining whether an employee has rebutted the retirement presumpti

2026The Mathews test requires courts to consider: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. 6 Id.

2026The Mathews test requires courts to consider: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. 6 Id.

1996Heddan v. Dirkswager, 336 N.W.2d 54, 59 (Minn.1983) (adopting the Mathews analysis).

1996Heddan v. Dirkswager, 336 N.W.2d 54, 59 (Minn.1983) (adopting the Mathews analysis).

2025See 424 N.W.2d at 69 ; cf. Olson v. One 1999 Lexus MN License Plate No. 851LDV, 924 N.W.2d 594, 606 (Minn. 2019) (“The Mathews factors are more than a checklist of items to be ticked through selectively or by rote.”); State v. Mikell, 960 N.W.2d 230 , 245 (Minn. 2021) (“This is not a check-the-box, prescriptive analysis; rather, we assess how the factors interact with each other in a difficult and sensitive balancing process . . . .” (citation omitted) (internal quotations marks omitted)). 17 We therefore conclude that, when determining whether an employee has rebutted the retirement presumpti

2025See 424 N.W.2d at 69 ; cf. Olson v. One 1999 Lexus MN License Plate No. 851LDV, 924 N.W.2d 594, 606 (Minn. 2019) (“The Mathews factors are more than a checklist of items to be ticked through selectively or by rote.”); State v. Mikell, 960 N.W.2d 230 , 245 (Minn. 2021) (“This is not a check-the-box, prescriptive analysis; rather, we assess how the factors interact with each other in a difficult and sensitive balancing process . . . .” (citation omitted) (internal quotations marks omitted)). 17 We therefore conclude that, when determining whether an employee has rebutted the retirement presumpti

2019Safety , 696 N.W.2d 340 , 342, 346-48 (Minn. 2005) (holding that when a statute fails to provide any requirement of a prompt post-deprivation hearing, the Mathews factors direct that a pre-hearing seizure of property is unconstitutional on its face). *603 Once we determine whether a greater or lesser urgency exists, we must assess whether the particular 18-month delay here was excessive in light of the level of urgency.

2019Safety , 696 N.W.2d 340 , 342, 346-48 (Minn. 2005) (holding that when a statute fails to provide any requirement of a prompt post-deprivation hearing, the Mathews factors direct that a pre-hearing seizure of property is unconstitutional on its face). *603 Once we determine whether a greater or lesser urgency exists, we must assess whether the particular 18-month delay here was excessive in light of the level of urgency.

2011Dog Owners, 453 N.W.2d at 71-72 (concluding that a procedural-due-process challenge fails where none of the Mathews factors weighs in favor of the party making the challenge).

2011Dog Owners, 453 N.W.2d at 71-72 (concluding that a procedural-due-process challenge fails where none of the Mathews factors weighs in favor of the party making the challenge).

2008Wiltgen, 737 N.W.2d at 568 (quotation marks omitted) (quoting Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893, 903 , 47 L.Ed.2d 18 (1976)). 4 .

2008Wiltgen, 737 N.W.2d at 568 (quotation marks omitted) (quoting Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893, 903 , 47 L.Ed.2d 18 (1976)). 4 .

2008Id. at 335 , 96 S.Ct. at 903; see also Hamilton, 600 N.W.2d at 723-24 (applying Mathews factors to due process required incident to revocation of a driver’s license). 1.

2007In re Wang, 441 N.W.2d 488, 489 (Minn.1989) (affirming one-year suspension of license to practice dentistry using preponderance standard); In re Friedenson, 574 N.W.2d 463, 466 (Minn.App.1998) (affirming preponderance standard in medical license suspension), review denied (Minn. Apr. 30,1998). 2 Appellant contends that both his property and liberty interests were significantly impacted by respondent’s decision to temporarily suspend his medical license and that application of the three-part Mathews test mandates use of the clear and convincing evidence standard of proof in temporary suspension

2007In re Wang, 441 N.W.2d 488, 489 (Minn.1989) (affirming one-year suspension of license to practice dentistry using preponderance standard); In re Friedenson, 574 N.W.2d 463, 466 (Minn.App.1998) (affirming preponderance standard in medical license suspension), review denied (Minn. Apr. 30,1998). 2 Appellant contends that both his property and liberty interests were significantly impacted by respondent’s decision to temporarily suspend his medical license and that application of the three-part Mathews test mandates use of the clear and convincing evidence standard of proof in temporary suspension

2007In re Wang, 441 N.W.2d 488, 489 (Minn.1989) (affirming one-year suspension of license to practice dentistry using preponderance standard); In re Friedenson, 574 N.W.2d 463, 466 (Minn.App.1998) (affirming preponderance standard in medical license suspension), review denied (Minn. Apr. 30,1998). 2 Appellant contends that both his property and liberty interests were significantly impacted by respondent’s decision to temporarily suspend his medical license and that application of the three-part Mathews test mandates use of the clear and convincing evidence standard of proof in temporary suspension

2007In re Wang, 441 N.W.2d 488, 489 (Minn.1989) (affirming one-year suspension of license to practice dentistry using preponderance standard); In re Friedenson, 574 N.W.2d 463, 466 (Minn.App.1998) (affirming preponderance standard in medical license suspension), review denied (Minn. Apr. 30,1998). 2 Appellant contends that both his property and liberty interests were significantly impacted by respondent’s decision to temporarily suspend his medical license and that application of the three-part Mathews test mandates use of the clear and convincing evidence standard of proof in temporary suspension

2005Fosselman v. Comm’r of Human Servs., 612 N.W.2d 456, 462 (Minn.App.2000) (quoting Mathews, 424 U.S. at 335 , 96 S.Ct. at 903 ) (determining that individuals disqualified from employment in direct-contact positions for allegedly failing to report the maltreatment of minors are entitled to hearings on whether they failed to report maltreatment).

2005Fosselman v. Comm’r of Human Servs., 612 N.W.2d 456, 462 (Minn.App.2000) (quoting Mathews, 424 U.S. at 335 , 96 S.Ct. at 903 ) (determining that individuals disqualified from employment in direct-contact positions for allegedly failing to report the maltreatment of minors are entitled to hearings on whether they failed to report maltreatment).

2004In In re Conservatorship of Foster, the Minnesota Supreme Court adopted the three-part Mathews test to ensure that an intrusive medical procedure did not deprive a mentally ill person of the right to due process: Under this test, we determine whether the process adequately balances: (1) the private interest affected by the governments action; (2) the risk that the process provided will result in an erroneous deprivation of the private interest and the probable value of additional or substitute procedural safeguards; and (3) the states interest in the procedures provided, including the administ

2004In In re Conservatorship of Foster, the Minnesota Supreme Court adopted the three-part Mathews test to ensure that an intrusive medical procedure did not deprive a mentally ill person of the right to due process: Under this test, we determine whether the process adequately balances: (1) the private interest affected by the governments action; (2) the risk that the process provided will result in an erroneous deprivation of the private interest and the probable value of additional or substitute procedural safeguards; and (3) the states interest in the procedures provided, including the administ

2000According to relators, their disqualification both precludes them from working in their chosen field for seven years and renders them opportunity to reenter that field at the discretion of the commissioner. 3 See Bell, 402 U.S. at 539 , 91 S.Ct. at 1589 (holding if driver’s license is essential to one’s livelihood, any proceeding to suspend that license must be consistent with due process); Falgren v. State, Bd. of Teaching, 545 N.W.2d 901, 909 (Minn.1996) (noting revocation of teaching license affects ability to work in chosen profession and quoting United States Supreme Court, “‘the signific

2000According to relators, their disqualification both precludes them from working in their chosen field for seven years and renders them opportunity to reenter that field at the discretion of the commissioner. 3 See Bell, 402 U.S. at 539 , 91 S.Ct. at 1589 (holding if driver’s license is essential to one’s livelihood, any proceeding to suspend that license must be consistent with due process); Falgren v. State, Bd. of Teaching, 545 N.W.2d 901, 909 (Minn.1996) (noting revocation of teaching license affects ability to work in chosen profession and quoting United States Supreme Court, “‘the signific

2000According to relators, their disqualification both precludes them from working in their chosen field for seven years and renders them opportunity to reenter that field at the discretion of the commissioner. 3 See Bell, 402 U.S. at 539 , 91 S.Ct. at 1589 (holding if driver’s license is essential to one’s livelihood, any proceeding to suspend that license must be consistent with due process); Falgren v. State, Bd. of Teaching, 545 N.W.2d 901, 909 (Minn.1996) (noting revocation of teaching license affects ability to work in chosen profession and quoting United States Supreme Court, “‘the signific

2000According to relators, their disqualification both precludes them from working in their chosen field for seven years and renders them opportunity to reenter that field at the discretion of the commissioner. 3 See Bell, 402 U.S. at 539 , 91 S.Ct. at 1589 (holding if driver’s license is essential to one’s livelihood, any proceeding to suspend that license must be consistent with due process); Falgren v. State, Bd. of Teaching, 545 N.W.2d 901, 909 (Minn.1996) (noting revocation of teaching license affects ability to work in chosen profession and quoting United States Supreme Court, “‘the signific

1991Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893, 903 , 47 L.Ed.2d 18 (1976); see also AFSCME Council 65 v. Blue Earth County, 389 N.W.2d 244, 249 (Minn.App. 1986) (three-part Mathews test applied in determining whether due process rights are violated by county termination procedures), pet. for rev. denied (Minn. Aug. 20, 1986).