In a landmark decision filed today, the Minnesota Court of Appeals issued a declaratory judgment holding invalid the Sprinkler Rule adopted by the Minnesota Department of Labor & Industry (DLI). The Builders Association of the Twin Cities (BATC) brought the challenge against the Sprinkler Rule, which had required sprinklers in newly-constructed single- and two-family homes, but excepted single-family homes under 4,500 square feet. BATC alleged that the Sprinkler Rule was invalid because it was adopted outside DLI’s rulemaking authority, it violated the constitutional requirement of substantive due process, and furthermore, in the process of adopting the Sprinkler Rule, DLI violated statutory rulemaking procedure. The Court of Appeals agreed on all counts.
The Court of Appeals determined that DLI failed to demonstrate there was substantial evidence supporting the 4,500-square foot threshold. There was “simply no evidence or explanation” supporting the notion that new two-family homes and single-family homes 4,500 square feet or greater present a unique fire-safety risk that justifies requiring sprinklers. Furthermore, the Court of Appeals noted there was no explanation in the record for why DLI adopted a threshold of 4,500 square feet as opposed to a threshold of any other square footage, be it 3,000 or 5,000 square feet. Consequently, the Court of Appeals held the Sprinkler Rule was “arbitrary and not the result of a reasoned determination.” The lack of evidence supporting the Sprinkler Rule meant that DLI had also acted outside its authority by adopting a rule that was not “based on the application of scientific principles, approved tests, and professional judgment.” Finally, the court recognized that DLI had failed to comply with Minnesota law insofar as it required DLI to consider the costs of the Sprinkler Rule on small businesses and cities.
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