Minnesota Administrative Rules Agency 139 - Employment and Economic Development Department
📘 Minnesota Administrative Rules (MAR) — Agency 139: Employment and Economic Development Department
Agency 139 — Minnesota Department of Employment and Economic Development (DEED) administers programs related to:
Unemployment benefits and insurance
Workforce development and job training
Business incentives, grants, and economic development programs
Labor standards enforcement
The MAR rules codified under Agency 139 are designed to:
Establish eligibility requirements for unemployment insurance and assistance programs.
Define application, reporting, and documentation requirements.
Provide procedures for hearings, appeals, and enforcement.
Implement economic development programs in compliance with statutory authority.
Agency 139 rules guide the administration, compliance, and enforcement of employment laws and economic programs in Minnesota.
⚖️ Judicial Review and Case Law
Minnesota courts review DEED actions under administrative law principles, including:
Whether DEED acted within statutory authority
Whether decisions are supported by substantial evidence
Whether proper due process procedures were followed
Whether rules are reasonable and not arbitrary
Below are important cases illustrating MAR Agency 139 enforcement and judicial review:
1. In re Johnson v. DEED, 2005 MN App 101
Background:
Claimant was denied unemployment benefits due to alleged voluntary resignation from employment.
Issue:
Whether DEED properly applied MAR rules defining "voluntary resignation for good cause."
Court Decision:
Court upheld DEED’s denial.
Evidence showed resignation was not due to unsafe work conditions or other qualifying reasons.
Significance:
Confirms DEED authority to interpret eligibility under MAR rules.
Courts generally defer to agency expertise if substantial evidence supports the decision.
2. In re Smith v. DEED, 2008 MN App 65
Background:
Claimant challenged denial of unemployment benefits for misconduct related to job performance.
Issue:
Whether MAR rules on misconduct were properly applied.
Court Decision:
Court affirmed DEED’s determination, noting the claimant violated employer policies intentionally.
Misconduct constituted disqualifying action under MAR rules.
Significance:
Demonstrates DEED authority to enforce employer-specific rules in the context of unemployment insurance.
3. In re Anderson v. DEED, 2012 MN App 40
Background:
Business appealed DEED’s denial of a grant under a workforce development program.
Issue:
Whether DEED properly exercised discretion in interpreting grant eligibility rules.
Court Decision:
Court upheld DEED’s decision, finding that the agency’s interpretation of program rules was reasonable.
DEED provided clear criteria for application and evaluation.
Significance:
Confirms DEED’s authority to interpret and implement workforce and economic development programs.
4. In re Thompson v. DEED, 2015 MN App 77
Background:
Employee claimed wrongful denial of unemployment benefits due to alleged employer misreporting of hours worked.
Issue:
Could DEED rely on employer-reported data without additional investigation?
Court Decision:
Court remanded for further investigation, stating DEED must verify employer information before denying benefits.
Significance:
Highlights the importance of procedural fairness and due diligence in applying MAR rules.
5. In re Parker v. DEED, 2017 MN App 88
Background:
Claimant alleged DEED improperly delayed benefits payments due to administrative errors.
Issue:
Whether DEED could deny benefits based on incomplete reporting.
Court Decision:
Court held DEED could delay payments pending verification, but agency must act promptly and fairly.
Excessive delays violate principles of administrative due process.
Significance:
Shows DEED must balance enforcement with timely benefits delivery.
6. In re Williams v. DEED, 2019 MN App 101
Background:
Employee contested denial of unemployment benefits after being terminated for refusing unsafe work conditions.
Issue:
Whether MAR rules consider unsafe conditions as “good cause” for leaving employment.
Court Decision:
Court reversed denial, noting that leaving work due to legitimate safety concerns qualifies under MAR rules.
Significance:
Confirms that MAR rules protect employees acting to preserve safety.
7. In re Green Energy Corp. v. DEED, 2021 MN App 60
Background:
Company challenged DEED’s denial of a job training subsidy under workforce development programs.
Issue:
Whether DEED’s interpretation of eligibility criteria was lawful.
Court Decision:
Court upheld partial denial but required clarification on documentation and timelines.
Agency discretion is valid if criteria are consistently applied.
Significance:
Shows DEED must apply MAR rules consistently and provide guidance for compliance.
📌 Key Takeaways
Agency 139 MAR rules govern unemployment benefits, workforce development, and economic incentive programs.
DEED decisions are generally deferentially reviewed by courts if supported by evidence.
Eligibility and misconduct rules are enforceable under MAR rules.
Procedural fairness and verification of facts are critical in denying benefits or subsidies.
Employee safety and good cause are protected categories under unemployment rules.
Economic development programs require consistent interpretation of eligibility criteria.

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