Jeremy McNitt, Respondent/Cross-Appellant v. Minnesota IT Services (MNIT), Appellant/Cross-Respondent
CourtSupreme Court of Minnesota
Date FiledSeptember 2, 2026
DocketA231948
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
STATE OF MINNESOTA
IN SUPREME COURT
A23-1948
Court of Appeals Gaïtas, J.
Concurring in part, dissenting in part,
Hudson, C.J., Thissen, J.
Jeremy McNitt, Concurring in part, dissenting in part, Thissen, J.
Took no part, Procaccini, J.
Respondent/Cross-Appellant,
vs. Filed: September 2, 2026
Office of Appellate Courts
Minnesota IT Services (MNIT),
Appellant/Cross-Respondent.
________________________
Cassandra C. Wolfgram, Matthew J. Schaap, Dougherty, Molenda, Solfest, Hills &
Bauer P.A., Apple Valley, Minnesota, for respondent/cross-appellant.
Keith Ellison, Attorney General, Peter Farrell, Acting Solicitor General, Saint Paul,
Minnesota, for appellant/cross-respondent.
Keith Ellison, Attorney General, Madeleine DeMeules, Assistant Attorney General, Saint
Paul, Minnesota, for amici curiae Minnesota Departments of Management and Budget,
Public Safety, Natural Resources, Human Services, Administration, Education,
Employment and Economic Development, and Office of Higher Education.
Paul A. Merwin, Patricia Y. Beety, Saint Paul, Minnesota, for amicus curiae League of
Minnesota Cities.
Ann K. Bloodhart, George N. Henry, Saint Paul, Minnesota, for amicus curiae
Metropolitan Council.
Luke Grundman, Minneapolis, Minnesota, for amicus curiae Mid-Minnesota Legal Aid.
Brianna H. Boone, Catherine Boruff, Saint Paul, Minnesota, for amicus curiae Southern
Minnesota Regional Legal Services.
1
Shauna Faye Kieffer, Minneapolis, Minnesota, for amicus curiae Minnesota Association
of Criminal Defense Lawyers.
________________________
SYLLABUS
1. An administrative law judge’s report and recommendation does not become
the final decision in the case if the agency commissioner timely accepts, modifies, or
rejects the recommendation under Minnesota Statutes section 14.62, subdivision 2a
(2022).
2. Under Minnesota Statutes section 364.03, subdivision 3 (2024), a public
employer has discretion to determine whether an applicant for public employment has
demonstrated sufficient rehabilitation and present fitness to perform the duties of the
public employment sought once the applicant produces competent evidence of
rehabilitation under subdivision 3(a).
Affirmed in part, reversed in part, and remanded.
OPINION
GAÏTAS, Justice.
In this case, we interpret a provision of the Criminal Offenders Rehabilitation Act
to determine if a public employer may disqualify a job applicant with a prior criminal
conviction from public employment, even after the applicant has produced competent
documentary evidence of rehabilitation under Minnesota Statutes section 364.03,
subdivision 3(a) (2024). In 2022, respondent/cross-appellant Jeremy McNitt applied for a
job with appellant/cross-respondent Minnesota IT Services (MNIT). MNIT offered
2
McNitt the position, subject to a background check. That background check revealed
McNitt’s prior conviction for possession of child pornography.
Following the process outlined in the Criminal Offenders Rehabilitation Act,
MNIT determined that McNitt’s conviction related to the position sought and asked
McNitt for evidence of rehabilitation and present fitness for employment. Minn. Stat.
§ 364.03. McNitt provided MNIT with an order showing that he had been discharged
from probation early and evidence that he had remained law-abiding for at least one year
since his release from probation. Additionally, McNitt offered, among other things, a
description of the circumstances surrounding his offense and several references. After
receiving this information, MNIT determined that McNitt’s criminal conviction
disqualified him from the position and informed McNitt that he could not apply for public
employment for ten years.
McNitt administratively appealed his disqualification under the Minnesota
Administrative Procedure Act. After the parties cross-motioned for summary disposition,
an administrative law judge found that McNitt had provided sufficient evidence of
rehabilitation and present fitness, and he rejected MNIT’s argument that under the
Criminal Offenders Rehabilitation Act, the agency retained sole discretion to decide
whether McNitt demonstrated sufficient rehabilitation once McNitt produced competent
evidence of rehabilitation. The administrative law judge recommended that the
Commissioner of MNIT rescind McNitt’s disqualification and hire him.
The Commissioner rejected the recommendation. The Commissioner remanded for
a contested case hearing and a new recommendation as to whether the agency had abused
3
its discretion in disqualifying McNitt and informing McNitt that he could not apply for
public employment for ten years.
Based on an intervening case from this court, however, the administrative law
judge determined that he no longer had jurisdiction to hold a contested case hearing, and
he returned the matter to the Commissioner. The Commissioner issued an order
dismissing McNitt’s grievance, affirming the decision to disqualify McNitt from public
employment based on the conviction, and directing McNitt that he could reapply for
public employment in January 2027.
McNitt appealed the Commissioner’s decision to the court of appeals. The court of
appeals concluded that MNIT did not have discretion to disqualify McNitt because
McNitt had provided competent evidence of rehabilitation under the Criminal Offenders
Rehabilitation Act. Accordingly, the court of appeals reversed the Commissioner’s
decision and remanded for further proceedings.
MNIT petitioned for review, and McNitt petitioned for conditional cross-review.
We accepted review of two issues: first, whether the administrative law judge’s initial
recommendation became the final decision because the Commissioner had no authority to
remand the matter for an evidentiary hearing; and second, whether the agency had
discretion to disqualify McNitt from the position after McNitt produced competent
evidence of rehabilitation under section 364.03, subdivision 3(a).
We affirm in part as to the first issue and conclude that the administrative law
judge’s recommendation was not the agency’s final decision. As to the second issue, we
reverse and hold that a public employer retains discretion to disqualify an applicant after
4
the applicant produces competent evidence of rehabilitation under subdivision 3(a).
Finally, because the court of appeals did not address McNitt’s remaining arguments after
determining that the disqualification was improper—a determination we now reverse—
we remand to the court of appeals to consider those remaining issues.
FACTS
Minnesota IT Services (MNIT) is a state agency that provides information
technology services to state government agencies. In November 2021, MNIT posted a
web-developer job opening with the Minnesota Department of Education. Jeremy McNitt
applied for the position in January 2022. McNitt was offered the job, subject to a
background check. That background check revealed McNitt’s 2017 conviction for
possession of child pornography.
The Criminal Offenders Rehabilitation Act (CORA) establishes standards and
procedures that public employers must follow when considering a job applicant with a
criminal history.1 Minn. Stat. §§ 364.01–.10. CORA seeks to “encourage and contribute
to the rehabilitation of criminal offenders,” acknowledging that “[t]he opportunity to
secure employment … is essential to rehabilitation and the resumption of the
responsibilities of citizenship.” Minn. Stat. § 364.01.
At issue here is the CORA provision in Minnesota Statutes section 364.03, which
addresses disqualification from public employment due to a prior conviction.
1
CORA defines “public employment” as including “all employment with the state
of Minnesota, its agencies, or political subdivisions.” Minn. Stat. § 364.02, subd. 4. As a
state agency, MNIT is a public employer.
5
Subdivision 1 states that “no person shall be disqualified from public employment”
unless the conviction “directly relate[s] to the position of employment sought.”
Subdivision 2 outlines factors that a public employer “shall consider” when determining
whether the conviction “directly relates to the position of public employment sought.”
Finally, subdivision 3 states that even if the prior conviction does directly relate to the
position sought, an applicant “shall not be disqualified from the employment or
occupation if the person can show competent evidence of sufficient rehabilitation and
present fitness to perform the duties of the public employment sought.” Minn. Stat.
§ 364.03, subd. 3(a) (2024).2 Subdivision 3(a) states that “[c]ompetent evidence of
sufficient rehabilitation may be established by the production of” enumerated documents.
Id. Subdivision 3(b) also lists evidence that, “[i]n addition to the documentary evidence
presented,” an employer “shall consider,” including “the nature and seriousness of the
crime,” “all circumstances relative to the crime,” “the age of the person at the time the
crime was committed,” “the length of time elapsed since the crime,” and “all other
competent evidence of rehabilitation and present fitness presented.” Id., subd. 3(b)
(2024).
After receiving the results of McNitt’s background check, MNIT first followed the
process outlined in subdivision 2 and determined that McNitt’s conviction “directly
2
We accepted review of the 2024 version of Minnesota Statutes section 364.03,
subdivision 3. After the court of appeals issued its decision in this case, the Legislature
amended subdivision 3. See Act of May 18, 2026, ch. 97, art. 9, § 2. To the extent that the
parties submitted supplemental filings requesting that we consider the amended statute,
these requests are not properly before us, and we do not consider them.
6
relates to the position of public employment sought.” Id., subd. 2. Next, pursuant to
subdivision 3, MNIT requested that McNitt provide proof of “any and all competent
evidence of sufficient rehabilitation and present fitness to perform the duties of the
position.” MNIT also identified for McNitt the documentary evidence listed in
subdivisions 3(a) and 3(b) that “may be used as competent evidence of sufficient
rehabilitation.”
McNitt provided MNIT with documents listed in subdivision 3(a), including his
release order showing his early discharge from probation and a document stating that his
background check verified that he had remained law-abiding for at least one year since
his release from a correctional institution. He also provided MNIT with documents listed
under subdivision 3(b), including a description of the circumstances surrounding his
offense and several reference letters.
In March 2022, MNIT informed McNitt that the agency would not be hiring him
for the position “based upon [his] background check results and [his] prior conviction.” It
advised McNitt that he would be disqualified from public employment for ten years.
MNIT explained that “the nature and seriousness of the crime is very high.”
McNitt administratively appealed his disqualification, and MNIT initiated a
contested case hearing pursuant to the Minnesota Administrative Procedure Act. Minn.
Stat. §§ 14.001–.69. In December 2022, both parties cross-moved for summary
disposition, which is the “administrative equivalent of summary judgment.” Pietsch v.
Minn. Bd. of Chiropractic Exam’rs, 683 N.W.2d 303, 306 (Minn. 2004). Following a
hearing on the motions, the administrative law judge (ALJ) issued a report and
7
recommendation on February 10, 2023. The ALJ found that McNitt provided sufficient
evidence of rehabilitation and present fitness and rejected MNIT’s argument that it
retained sole discretion in determining whether McNitt demonstrated sufficient
rehabilitation. Thus, the ALJ recommended that McNitt’s motion for summary
disposition be granted. The ALJ recommended that MNIT rescind McNitt’s
disqualification from public employment and provide McNitt with the applied-for
position or a comparable one. The record in the matter closed on March 31, 2023.
Under the version of the Minnesota Administrative Procedure Act then in effect,
the Commissioner of MNIT had 90 days to accept, modify, or reject the ALJ’s
recommendation. Minn. Stat. § 14.62, subd. 2a (2022) (stating that the report or order of
the ALJ becomes the final decision unless the agency “modifies or rejects it” within
90 days of the record closing).3 Before issuing his order, the Commissioner asked the
parties how they wished to proceed if genuine issues of fact precluded the Commissioner
from granting either of the motions for summary disposition. McNitt requested that the
matter be remanded for a contested case hearing in such a situation.
Within the 90-day window, on June 21, 2023, the Commissioner issued Findings
of Fact, Conclusions of Law, and Order determining that CORA afforded MNIT with
3
Under this previous version of the Minnesota Administrative Procedure Act, an
agency did not have express authority to remand to an ALJ following an ALJ’s report and
recommendation. In re Surveillance & Integrity Rev. (SIRS) Appeals by Trinity Home
Health Care Servs. & Etyane Ayana, 996 N.W.2d 178, 187 (Minn. 2023). The Legislature
has since amended the Minnesota Administrative Procedure Act to give agencies the
express authority to remand to an ALJ if certain conditions are met. See Act of
May 23, 2025, ch. 39, art. 2, §§ 19–21, 2025 Minn. Laws 1195, 1219–21 (codified at
Minn. Stat. § 14.62 (Supp. 2025)).
8
discretion to disqualify McNitt. The Commissioner adopted some of the ALJ’s findings
of fact and modified others. The Commissioner also adopted some of the ALJ’s legal
conclusions. However, the Commissioner rejected the ALJ’s legal conclusion that CORA
does not afford MNIT with discretion to determine whether an applicant has been
disqualified from public employment, and the Commissioner similarly rejected the ALJ’s
conclusion that the subdivision 3(a) evidence submitted by McNitt conclusively
established sufficient rehabilitation. Finally, the Commissioner rejected the ALJ’s
conclusion that there were no genuine issues of material fact and thus rejected the
recommendation to grant McNitt’s summary disposition motion. The Commissioner then
remanded for an evidentiary hearing to address, in part, whether MNIT abused its
discretion when it concluded that McNitt was disqualified from public employment for
ten years.
Before an evidentiary hearing was held, we issued our decision in In re
Surveillance & Integrity Rev. (SIRS) Appeals by Trinity Home Health Care Servs. &
Etyane Ayana, 996 N.W.2d 178 (Minn. 2023). There, we held that under the then-current
version of the Minnesota Administrative Procedure Act, a state agency does not have the
authority to remand an ALJ’s report or order. Id. at 179. Given this decision, the ALJ
determined that he lacked jurisdiction to conduct a contested case hearing on remand.
The ALJ returned the file to MNIT on October 30, 2023. One month later, in
November 2023, the Commissioner issued his second Findings of Fact, Conclusions of
Law, and Order, affirming the earlier determination of disqualification and dismissing
9
McNitt’s administrative appeal. This time, the Commissioner’s order stated that McNitt
could reapply for public employment as of January 28, 2027.
McNitt then appealed to the court of appeals by writ of certiorari. McNitt v. Minn.
IT Servs., 14 N.W.3d 284 (Minn. App. 2024). In a precedential opinion, the court of
appeals held that, once an applicant provides the documents required under Minnesota
Statutes section 364.03, subdivision 3(a), public employers lack discretion to disqualify
the applicant based on a previous conviction. Id. at 285. The court of appeals further held
that because McNitt provided all required documentation under subdivision 3(a), MNIT
could not disqualify McNitt from the position. Id. at 292–93. The court of appeals
reversed the Commissioner’s final November 2023 order and remanded for further
proceedings. Id. at 294.
In doing so, the court of appeals rejected McNitt’s argument that SIRS
independently required reversal. Id. at 288–90. McNitt contended that under this court’s
decision in SIRS, the Commissioner did not have authority to remand the matter to the
ALJ for an evidentiary hearing, and thus, the Commissioner exceeded the 90-day window
for action under the Minnesota Administrative Procedure Act. Id. He argued that this, in
turn, made the ALJ’s original report—recommending that summary disposition be
granted in McNitt’s favor—the final decision in the case. Id. The court of appeals
disagreed, concluding that SIRS was distinguishable and that the Commissioner “timely
modified and rejected the ALJ’s report and recommendation in its order remanding the
matter to the ALJ.” Id. at 290.
10
MNIT filed a petition for review challenging the court of appeals’ decision that a
public employer lacks discretion to disqualify applicants once the documents in
subdivision 3(a) are produced. McNitt petitioned for conditional cross-review,
challenging whether the ALJ’s report and recommendation granting summary disposition
was instead the final decision. We granted both petitions.
ANALYSIS
I.
We first must determine what is the final decision that we are reviewing. Thus, we
begin by addressing the issue raised in McNitt’s cross-petition as to whether the ALJ’s
report and recommendation granting summary disposition became the final decision in
this case. This is a question of statutory interpretation, which we review de novo. SIRS,
996 N.W.2d at 184. “We consider our prior interpretations of a statute in reviewing
subsequent disputes over the meaning of the statute.” Keystone Township v. Red Lake
Watershed Dist., 20 N.W.3d 612, 620 (Minn. 2025) (citation omitted) (internal quotation
marks omitted).
The Minnesota Administrative Procedure Act establishes a procedure for state
agencies to follow in reviewing an ALJ’s report and recommendations in a contested
case. At the time of McNitt’s administrative appeal, Minnesota Statutes section 14.62,
subdivision 2a, gave an agency 90 days to “modif[y] or reject[]” an ALJ’s report. Under
this provision, if the agency failed to timely modify or reject the report, the ALJ’s report
“constitute[d] the final decision in the case.” Minn. Stat. § 14.62, subd. 2a.
11
We recently addressed this provision in SIRS. There, the ALJ issued a report and
recommendation following a contested case hearing where the agency presented evidence
that a company had failed to comply with the requirements of a government program.
SIRS, 996 N.W.2d at 182. The agency determined that the ALJ had failed to give proper
weight to certain evidence. Id. at 183. Rather than rejecting the ALJ’s report and
recommendation, however, the agency issued an order remanding the case to the ALJ for
further proceedings. Id.
On review, we concluded that the agency in SIRS did not have the authority to
remand the case to the ALJ. Id. at 187. Interpreting section 14.62, we stated that the
statute “provides the agency with three options after receiving the ALJ’s report with
recommendation: to accept the ALJ’s report as the agency’s final decision; to ‘modif[y]’
the ALJ’s report; or to ‘reject’ the ALJ’s report.” Id. Because we determined that a
remand was not an implied rejection, and because the agency failed to timely accept,
modify, or reject the ALJ’s recommendations, we concluded that the ALJ’s report and
recommendation was the binding decision in that case. Id. at 180.4
McNitt argues that here, as in SIRS, the ALJ’s report and recommendation became
the final decision in his case because MNIT had no authority to remand to the ALJ for an
evidentiary hearing. According to McNitt, the only options available to the agency were
accepting, modifying, or rejecting the ALJ’s report. And he asserts that MNIT failed to
4
As noted above, after our decision in SIRS, the Legislature amended the Minnesota
Administrative Procedure Act to allow agencies to remand to an ALJ when a limited set
of conditions exist. See Act of May 23, 2025, ch. 39, art. 2, §§ 19–21, 2025 Minn. Laws
1195, 1219–21 (codified at Minn. Stat. § 14.62 (Supp. 2025)).
12
accept, modify, or reject the ALJ’s report before the 90-day period under the Minnesota
Administrative Procedure Act expired. McNitt contends that the ALJ’s report and
recommendation—that McNitt’s motion for summary disposition be granted and that
MNIT rescind McNitt’s disqualification from public employment—thus became the
agency’s final decision.
MNIT responds that the court of appeals properly rejected McNitt’s analysis. The
court of appeals distinguished the circumstances in McNitt’s case from those presented in
SIRS in two ways. First, the court of appeals noted that in SIRS the ALJ’s report and
recommendation followed an evidentiary hearing, whereas here, there was no evidentiary
hearing. McNitt, 14 N.W.3d at 289–90. Rather, the ALJ’s report and recommendation was
made in connection with the grant of summary disposition to McNitt. Id. Second, the
court of appeals observed that, unlike SIRS, here the agency expressly rejected the ALJ’s
report and recommendation within the statutory 90-day period. Id. at 290.
We disagree with the court of appeals that our holding in SIRS does not apply to an
ALJ’s report and recommendation at the summary disposition stage. Our reasoning in
SIRS did not depend on the procedural posture of the contested case, but on the fact that
the contested-case requirement of Minnesota Statutes section 14.62, subdivision 2a,
applied. We determined that the plain language of the statute “does not provide an option
to ‘remand.’ ” SIRS, 996 N.W.2d at 191. Noting that, in some instances, agency authority
may be implied from express powers granted by the Legislature, we further concluded
that agencies did not have an implied power to remand. Id. at 188, 191. Thus, under the
then-existing version of the statute, the Commissioner did not have the authority to
13
remand the case back to the ALJ. See id. at 194–97 (Chutich, J., dissenting) (discussing
the court’s conclusion “that a commissioner may never remand a case to an ALJ”). To the
extent that the court of appeals’ decision holds that under the then-existing version of
section 14.62, an agency had authority to remand a contested case at the summary
disposition stage, we reverse the decision.
However, we are persuaded by the court of appeals’ reasoning that our decision in
SIRS does not dictate the outcome here because the cases are distinguishable in one
critical respect. As the court of appeals observed, unlike in SIRS, where the agency took
no action beyond remanding to the ALJ, the Commissioner’s initial order here expressly
rejected a number of the ALJ’s conclusions within the 90-day statutory deadline. The
Commissioner’s initial order rejected the ALJ’s legal conclusions that under CORA, an
applicant who presents competent evidence of rehabilitation is per se rehabilitated and an
agency lacks discretion to determine whether the applicant has been sufficiently
rehabilitated. And the Commissioner rejected the ALJ’s ultimate recommendation that
summary disposition be granted to McNitt. In SIRS, we held that a remand is not an
implicit rejection of an ALJ’s report and recommendation. But here, the Commissioner
explicitly rejected the ALJ’s conclusions. Thus, the ALJ’s report and recommendation
does not “constitute[] the final decision in the case” because “the agency modifie[d] or
reject[ed] it … within 90 days after the record of the proceeding close[d].” Minn. Stat.
§ 14.62, subd. 2a. Instead, the Commissioner’s order—and not the ALJ’s report and
14
recommendation, which was timely rejected and modified by MNIT—is the final
decision in the case.5
II.
Having determined that the Commissioner’s order was the final decision in the
case under the Minnesota Administrative Procedure Act, we now turn to the merits of the
issue presented here—whether Minnesota Statutes section 364.03 provides a public
employer with discretion to decide whether a job applicant has demonstrated sufficient
rehabilitation and present fitness once the applicant has presented competent evidence of
rehabilitation under subdivision 3(a) of the statute. To address this issue, we must
interpret section 364.03.
We review questions of statutory interpretation de novo. State v. Holl, 966 N.W.2d
803, 808 (Minn. 2021). First, we determine whether the statute’s language, on its face, is
ambiguous. State v. Henderson, 907 N.W.2d 623, 625 (Minn. 2018). In doing so, we give
the text of the statute its plain and ordinary meaning. Emerson v. Sch. Bd. of Indep. Sch.
Dist. 199, 809 N.W.2d 679, 682 (Minn. 2012). We examine the language of a statute as a
whole to give effect to all its provisions, Minn. Stat. § 645.16, and “no word, phrase, or
5
We, like the court of appeals, treat the Commissioner’s November 2023 Findings
of Fact, Conclusions of Law, and Order as the final decision in this case. Critically, the
cross-petition issue for which we granted review only asked whether “the administrative
law judge’s report and recommendation granting summary disposition bec[a]me the final
decision, in accordance with Minn. Stat. § 14.62, subd. 2(a) and In re Surveillance and
Integrity Review (SIRS), 996 N.W.2d 178 (Minn. 2023) ….” We have rejected that
argument, and we were not otherwise asked to review whether the Commissioner’s June
2023 order or November 2023 order should be treated as the final decision in this case.
15
sentence should be deemed superfluous, void, or insignificant,” In re Reichmann Land &
Cattle, LLP, 867 N.W.2d 502, 509 (Minn. 2015) (citation omitted) (internal quotation
marks omitted). A statute is ambiguous only if its language is susceptible to more than
one reasonable interpretation. Am. Fam. Ins. Grp. v. Schroedl, 616 N.W.2d 273, 277
(Minn. 2000). If the statute is ambiguous, we seek to resolve the ambiguity using
applicable canons of construction. Holl, 966 N.W.2d at 808. If the statute is
unambiguous, however, our inquiry ends there—we must “abide by the plain language of
the statute.” Id.
Before turning to the specific statutory interpretation questions presented here, we
briefly provide an overview of CORA and section 364.03. In CORA, the Legislature
“declare[d] that it is the policy of the state of Minnesota to encourage and contribute to
the rehabilitation of criminal offenders and to assist them in the resumption of the
responsibilities of citizenship.” Minn. Stat. § 364.01. To that end, CORA establishes
when employers may consider a job applicant’s criminal record and the procedures they
must follow when doing so. Under section 364.03, subdivision 1, an employer may
disqualify an applicant for a prior conviction only when that conviction “directly relate[s]
to the position of employment sought.” Minn. Stat. § 364.03, subd. 1. Section 364.03,
subdivision 3(a) further provides the following:
A person who has been convicted of a crime or crimes which directly relate
to the public employment sought or to the occupation for which a license is
sought shall not be disqualified from the employment or occupation if the
person can show competent evidence of sufficient rehabilitation and present
fitness to perform the duties of the public employment sought or the
occupation for which the license is sought.
16
Id. Subdivision 3(a) goes on to state that “competent evidence of sufficient rehabilitation
may be established by the production of” documentation listed in that subdivision. These
documents are the person’s United States Department of Defense form DD-214 showing
their honorable discharge from military service, or:
(1) a copy of the local, state, or federal release order; and
(2) evidence showing that at least one year has elapsed since release from
any local, state, or federal correctional institution without subsequent
conviction of a crime; and evidence showing compliance with all terms and
conditions of probation or parole; or
(3) a copy of the relevant Department of Corrections discharge order or other
documents showing completion of probation or parole supervision.
Minn. Stat. § 364.03, subd. 3(a).
Subdivision 3(b) states that “in addition” to the documentary evidence listed in
subdivision 3(a), “the licensing or hiring authority shall consider any evidence presented
by the applicant regarding” the crime committed, including its nature and seriousness;
“all circumstances relative to the crime,” including mitigating circumstances; the age of
the person at the time of the crime; the length of time elapsed since the crime; and “all
other competent evidence of rehabilitation and present fitness presented, including, but
not limited to, letters of reference by persons who have been in contact with the applicant
since the applicant’s release from any local, state, or federal correctional institution.” Id.,
subd. 3(b).
Both McNitt and MNIT contend that the statutory text is unambiguous. But they
offer competing interpretations of the text.
17
McNitt focuses on the words “shall not be disqualified” in the first sentence of
subdivision 3(a). Minn. Stat. § 364.03, subd. 3(a). He argues that this phrase—and the
use of the word “shall” in particular—guarantees that an applicant who produces
competent evidence of sufficient rehabilitation and present fitness is not disqualified from
public employment. McNitt then directs us to the second sentence in subdivision 3(a),
which identifies types of “[c]ompetent evidence of sufficient rehabilitation,” including “a
copy of the local, state, or federal release order” and “evidence showing that at least one
year has elapsed since release … without subsequent conviction of a crime.” Id.
According to McNitt, because he presented an order showing that he had been released
from probation and evidence that he had been law-abiding for at least one year following
his discharge from probation, he “shall not be disqualified” from public employment.
MNIT, on the other hand, focuses on the latter half of the first sentence of
subdivision 3(a), which states that the applicant shall not be disqualified “if the person
can show competent evidence of sufficient rehabilitation and present fitness.” Id. Under
MNIT’s interpretation of this phrase, an applicant “shall not be disqualified” only if the
applicant “can show competent evidence of sufficient rehabilitation and present fitness.”
In other words, according to MNIT, the statute provides a process for demonstrating
sufficient rehabilitation and present fitness for a job but does not guarantee a result.
MNIT also directs our attention to the second sentence of subdivision 3(a), which
states that “[c]ompetent evidence of sufficient rehabilitation may be established by the
production of” certain documents. Id. (emphasis added). Noting that the word “may” is
generally interpreted as permissive, MNIT contends that the listed documents may or may
18
not establish sufficient rehabilitation. See Minn. Stat. § 645.44, subd. 15 (“ ‘May’ is
permissive.”). And, MNIT argues, if the documents listed in subdivision 3(a) were
conclusive evidence of sufficient rehabilitation, then subdivision 3(b)—which states that
a public employer “shall consider any evidence presented by the applicant” regarding the
circumstances underlying the conviction and “all other competent evidence of
rehabilitation and present fitness presented,” such as “letters of reference”—would be
superfluous. Minn. Stat. § 364.03, subd. 3(b).
McNitt interprets the second sentence of subdivision 3(a) differently. He contends
that the word “may” simply means that the listed documents are not the exclusive means
of proving sufficient rehabilitation. According to McNitt, subdivision 3(a) provides
“multiple avenues” that an applicant may use to show sufficient rehabilitation: either by
presenting the documents that constitute “competent evidence of sufficient rehabilitation”
or the other evidence that a public employer must consider.
The court of appeals was persuaded by McNitt’s interpretation of section 364.03.
It concluded that, under the unambiguous language of the statute, “once an applicant
provides the documentation listed in subdivision 3(a), the applicant has satisfied the
statutorily defined means of demonstrating rehabilitation and shall not be disqualified
from employment.” McNitt, 14 N.W.3d at 292–93.
We disagree. For the reasons stated below, we conclude that McNitt’s reading of
the statute is unreasonable and that the language and structure of section 364.03 plainly
confer discretion on a public employer to decide whether an applicant has established
19
sufficient rehabilitation even after the applicant has produced the documents identified in
subdivision 3(a).
Our analysis starts with the language of subdivision 3. The first sentence of
subdivision 3(a) states that an applicant “shall not be disqualified … if [the applicant] can
show competent evidence of sufficient rehabilitation and present fitness to perform the
duties of the public employment sought.” Minn. Stat. § 364.03, subd. 3(a) (emphasis
added). To state the obvious, the ordinary meaning of the word “if” makes the first part of
the sentence conditional upon the latter. See The American Heritage Dictionary of the
English Language 874 (5th ed. 2011) (defining “if” as “[i]n the event that,” “[g]ranting
that,” or “[o]n the condition that”); State v. Thonesavanh, 904 N.W.2d 432, 436
(Minn. 2017) (noting that this court may “look to dictionary definitions to determine the
common and ordinary meanings” of terms). Thus, the statute directs that if an applicant
“can show competent evidence of sufficient rehabilitation and present fitness to perform
the duties of the public employment sought” the applicant “shall not be disqualified.”
Minn. Stat. § 364.03, subd. 3(a).
The critical question, then, is what constitutes “competent evidence of sufficient
rehabilitation and present fitness to perform the duties of the public employment sought.”
This takes us to the second sentence of section 364.03, subdivision 3(a), which lists
“documentary evidence” that “may” establish sufficient rehabilitation, and
subdivision 3(b), which lists other evidence that the hiring authority “shall consider.”
Subdivision 3(a) provides that “[c]ompetent evidence of sufficient rehabilitation may be
established by the production of” several listed documents, including the United States
20
Department of Defense form DD-214, a release order, or a Department of Corrections
discharge order. Minn. Stat. § 364.03, subd. 3(a). Subdivision 3(b) then instructs the
following: “In addition to the documentary evidence presented, the licensing or hiring
authority shall consider any evidence presented by the applicant regarding” several
enumerated factors, such as the nature and seriousness of the crime, the length of time
elapsed since the crime, and “all other competent evidence of rehabilitation and present
fitness presented.” Id., subd. 3(b). For three reasons we conclude that under this
language, a public employer is not stripped of its discretion by the production of
documentation under subdivision 3(a).
First, we are persuaded by the Legislature’s decision to use words that convey
discretion throughout subdivision 3 of the statute. The use of the permissive word “may”
in the second sentence of subdivision 3(a)—“[c]ompetent evidence of sufficient
rehabilitation may be established by [certain documents]”—indicates the Legislature’s
intent to give a public employer discretion to decide whether the documents identified in
subdivision 3(a) constitute “competent evidence of sufficient rehabilitation.” Id.,
subd. 3(a) (emphasis added). The words “competent” and “sufficient” further enforce our
conclusion that the Legislature intended to give public employers discretion in decision-
making. See The American Heritage Dictionary of the English Language 376, 1742 (5th
ed. 2011) (defining “competent” as “[a]dequate for the purpose” and “sufficient” as
“[b]eing as much as is needed; adequate; enough”). We decline to read these words out of
the statute. As written, it is not enough for the applicant to merely produce “evidence of
21
rehabilitation”—that evidence must be competent and demonstrate sufficient
rehabilitation.
Indeed, by requiring evidence of “sufficient” rehabilitation in CORA, the
Legislature recognized that the rehabilitation of individuals with criminal convictions is a
process, not a black-and-white result. See Rehabilitation, Black’s Law Dictionary (12th
ed. 2024) (defining “rehabilitation” as “[t]he process of seeking to improve a criminal’s
character and outlook so that he or she can function in society without committing other
crimes” (emphasis added)); Minn. Stat. § 364.01 (declaring it the policy of the state of
Minnesota to “encourage and contribute to the rehabilitation of criminal offenders and to
assist them in the resumption of the responsibilities of citizenship”). And this necessarily
means that some entity must be empowered to decide when an applicant has been
sufficiently rehabilitated. The surrounding language makes it evident that this entity is the
public employer. See Minn. Stat. § 364.03, subd. 2 (stating that it is the “hiring or
licensing authority” that considers the enumerated factors to determine if the conviction
“directly relates to the posi