Minnesota Voters Alliance v. Anoka-Hennepin School District

The Anoka-Hennepin School District (the district) (defendant) placed three levy ballot questions on a special-election ballot, seeking voter approval of new and existing levies to fund district programs. Minnesota state election laws allowed school districts to levy taxes to fund school activities after obtaining voter consent. School districts in Minnesota were allowed to explain proposed levies to voters but would trigger campaign and reporting requirements if they promoted, rather than explained, levy propositions. The district distributed a brochure explaining the proposed levies and spent $15,000 on the brochure. The purely factual brochure contained accurate information about the tax impact of the proposed levies and did not exaggerate any effects of a failure to pass the levies. The Minnesota Voters Alliance and Donald Huizenga (collectively, the district opponents) (plaintiffs) filed an administrative action claiming that the district had promoted the levies, violating election laws regarding unfair campaign practices and campaign-finance reporting. The district claimed it was merely explaining, not promoting, the levies in the brochure. An administrative-law judge granted summary disposition to the district. The state appellate court affirmed the dismissal of the unfair-campaign-practices claim but reversed the dismissal of the campaign-finance-reporting claim. On remand, an administrative-law-judge panel again ruled in favor of the district. The panel found the district did not promote the levies and, as a result, was not required to report the $15,000 brochure expenditure. The district opponents appealed the panel’s ruling to the state appellate court.