Madison v. Commissioner of Public Safety

I respectfully dissent. Although I agree with the majority that there has been some confusion regarding the district court’s standard of review in proceedings under Minn. Stat. § 171:19 (1996), this court has long held that in a driver’s license reinstatement case, the district court must employ the “arbitrary and capricious” standard when reviewing the decision of the Commissioner of Public Safety. Mechtel v. Commissioner of Pub. Safety, 373 N.W.2d 832, 834 (Minn.App.1985).

Although the Commissioner’s decision is subject to review, the district court does not have de novo review. The fact…