11-1902-21378-2

STATE OF MINNESOTA

OFFICE OF ADMINISTRATIVE HEARINGS

 

FOR THE DEPARTMENT OF LABOR AND INDUSTRY

 

 

In the Matter of the Residential Building Contractor License of Eilertson Exteriors, LLC, and Thomas W. Eilertson, Individually

 

FINDINGS OF FACT,

CONCLUSIONS, AND

RECOMMENDATION

 

          The above-entitled matter came on for a prehearing conference before Administrative Law Judge Barbara L. Neilson on July 27, 2010, at 1:30 p.m. at the Office of Administrative Hearings in St. Paul, Minnesota.  Christopher M. Kaisershot, Assistant Attorney General, appeared on behalf of the Department of Labor and Industry ("the Department").  There was no appearance by or on behalf of the Respondents, Eilertson Exteriors, LLC, and Thomas W. Eilertson. 

By letter dated July 27, 2010, the Department made a motion that the Respondents be found to be in default.  The letter informed Respondents that their written reply to the motion must be filed and served within ten days.  The OAH record remained open until August 10, 2010, for receipt of a substantive response to the motion from the Respondents.  Although Respondents returned the Department’s motion letter to the Department on August 5, 2010, with some notations and other materials, the Respondents did not provide any substantive response to the motion or offer any reason for their failure to appear for the prehearing conference. 

STATEMENT OF ISSUES

 

          The issues presented in this case are as follows:

          (1)      whether Respondents Eilertson Exteriors, LLC, and Thomas W. Eilertson engaged in fraudulent, deceptive or dishonest practices by presenting a $15,000 sham money order as payment for an outstanding debt;

          (2)      whether Respondents demonstrated financial irresponsibility and untrustworthiness by failing to pay a material provider $2,961.87 for its contribution to a project;

          (3)      whether Respondent Thomas W. Eilertson demonstrated financial irresponsibility and untrustworthiness by failing to satisfy a civil judgment of $9,032.29 that was obtained against him by Discover Bank; and

          (4)      whether Respondent, and its principal, Thomas Eilertson, failed to comply with the Department’s requests for information, documents, or other requests from the Department.

          The Administrative Law Judge concludes that the Respondents did engage in the misconduct alleged by the Department, there are grounds for the Commissioner to impose discipline, and the May 24, 2010, Licensing Order issued by the Commissioner should be affirmed. 

          Based upon all of the proceedings herein, the Administrative Law Judge makes the following:

FINDINGS OF FACT


                    1.       Respondent Eilertson Exteriors, LLC, holds a residential building contractor license (No. 20551371) that was issued by the Department on November 29, 2005.  Respondent Thomas W. Eilertson is the principal in that company.[1] 

                    2.       On February 24, 2010, Discover Bank obtained a $9,032.29 civil judgment against Respondent Thomas Eilertson in Hennepin County District Court.  There is no evidence that Respondent has satisfied or appealed Discover Bank’s judgment.[2]

                    3.       On March 17, 2010, the Department opened an investigation based on a complaint by a material provider (Complainant) that had not been paid $2,961.87 for its contribution to Respondents’ Minneapolis project in May and June 2009.  Complainant reported that Respondent Eilertson was a guarantor of the obligation.[3]

                    4.       Respondents provided Complainant with a $15,000 “money order” that was not a negotiable instrument drawn on a financial institution.  The “money order” provided no routing numbers or bank information, but merely listed the Social Security number of Respondent Eilertson’s wife as the “account number” and directed that the $15,000 should be drawn from that “bonded account.”  Respondents claimed that their obligation to Complainant was extinguished, at least in part, because the Complainant did not “rebut” within five days the contents of their purported “Verified Notice to the Public Within the Admiralty, in the Nature of a Commercial Affidavit of Truth.”[4]

                    5.       Complainant reported that Respondents had failed to pay the outstanding balance of $2,961.87.[5]

                    6.       On March 30, 2010, the Department sent Respondents an information request concerning, among other issues, Respondents’ unpaid debt to Complainant and the status of Discover Bank’s judgment against Respondent Eilertson.

                    7.       Respondents returned the Department’s information request with the following notations:  “Return of uncertified, unverified, fraudulent documents ‘void for cause’ without prejudice,” “this communication is a dishonor,” “I give no consent to these proceedings,” and “no jurisdiction granted.”  Respondents also noted, “The collateral is now owned unconditionally by a private entity.  You have no position and no claim.  Provide legislated black letter law that you can make any claim against this ‘person.’”  Finally, Respondents asserted that the Department was “an unwelcome unlawful third party interloper to a lawful contract.”[6]

                    8.       On May 24, 2010, the Department served Respondents with a Licensing Order which revoked the residential building contractor’s license of Eilertson Exteriors, imposed a $2,500 monetary penalty against Eilertson Exteriors, and required Eilertson Exteriors and Thomas Eilertson to cease and desist from acting or holding themselves out as a residential building contractor, remodeler, or roofer in the State of Minnesota.[7]

                    9.       On June 1, 2010, the Department received Respondents’ request for a hearing to contest the May 24, 2010, Order.[8]

                    10.     The Notice and Order for Prehearing Conference initiating this contested case proceeding was served on the Respondents via first class mail on June 14, 2010, at their address in Minneapolis.[9]

                    11.     The Notice and Order for Prehearing Conference set a prehearing conference for July 27, 2010, at 1:30 p.m.[10]

                    12.     The Notice and Order for Prehearing Conference contained the following language: 

Respondent’s failure to appear at the hearing or any prehearing conference, or any failure to comply with an order of the Administrative Law Judge, may result in a finding that the Respondent is in default, that the Department’s allegations contained in this Notice and Order may be accepted as true, and its proposed action may be upheld.[11]

                    13.     On June 28, 2010, the Administrative Law Judge mailed correspondence to Respondents and enclosed materials regarding the contested case hearing process.  On July 8, 2010, Respondents returned the correspondence packet.  Each of the pages was crossed out and the words “void” or “void for cause” were written across each page.  On the cover letter addressed to Respondents, Respondents wrote “the living man gives no consent to these proceedings,” and “this contract ‘offer’ refused respectfully.”[12]

                    14.     No one appeared at the prehearing conference on July 27, 2010, on behalf of Respondents.  Respondents did not seek and were not granted a continuance before the hearing.  Respondents did not contact the Administrative Law Judge between the date of the hearing and the date of this Report to offer any explanation for their failure to appear.

                    17.     Based upon the Respondents’ failure to appear at the July 27, 2010, prehearing conference, the Department filed a motion that Respondents be found to be in default in this proceeding.  The Department’s motion was submitted by letter dated July 27, 2010.[13]

                    18.     Respondents returned the Department’s motion letter to the Department on August 5, 2010.  On the top of the letter Respondents wrote, “void for cause,” “all rights reserved,” “without prejudice,” and “this commercial contract offer is refused.”  Respondents also submitted additional documents with the returned letter, but they are largely unintelligible and provide no explanation for Respondents’ failure to appear at the prehearing conference.[14] 

                    19.     Because Respondents failed to appear at the prehearing conference in this matter, they are in default.  Pursuant to Minnesota Rules part 1400.6000, the allegations contained in the Notice and Order for Prehearing Conference are hereby taken as true and incorporated into these Findings of Fact.

          Based upon the foregoing Findings of Fact, the Administrative Law Judge makes the following:

CONCLUSIONS

1.       The Administrative Law Judge and the Commissioner of the Department of Labor and Industry have jurisdiction over this matter pursuant to Minn. Stat. §§ 14.50, 326B.082, 326B.083, and 326B.84.

2.       The Notice and Order for Prehearing Conference issued by the Department was proper and the Department has fulfilled all relevant procedural requirements of law and rule.

3.       The Respondents, having made no appearance at the prehearing conference, and not receiving a continuance or other relief, are in default.  Pursuant to Minn. Rules part 1400.6000, the allegations contained in the Notice and Order for Prehearing Conference are hereby taken as true.

          4.       Minn. Stat. § 326B.082, subd. 11(b), authorizes the Commissioner to deny, suspend, limit, place conditions on, or revoke a person’s license or censure the person holding the license if the Commissioner finds that the person:

(6)      failed to cooperate with a commissioner's request to give testimony, to produce documents, things, apparatus, devices, equipment, or materials, or to access property under subdivision 2;

* * *

(8)      engaged in any fraudulent, deceptive, or dishonest act or practice; or

(9)      performed work in connection with the permit, license, registration, or certificate or conducted the person's affairs in a manner that demonstrates incompetence, untrustworthiness, or financial irresponsibility.

5.       Minn. Stat. § 326B.84 authorizes the Commissioner of Labor and Industry to deny, suspend, limit, place conditions on, or revoke a license, or censure the person holding the license, if the licensee, qualifying person, or agent owner:

(2)      has engaged in a fraudulent, deceptive, or dishonest practice;

* * *

(15)    has engaged in an act or practice whether or not the act or practice directly involves the business for which the person is licensed, that demonstrates that the applicant or licensee is untrustworthy, financially irresponsible, or otherwise incompetent or unqualified to act under the license granted by the commissioner; or

(16)    has failed to comply with requests for information, documents, or other requests from the department within the time specified in the request or, if no time is specified, within 30 days of the mailing of the request by the department.

          6.       Minn. Rules part 2891.0040 states that “any fraud or dishonesty in the execution of, or in the material alteration of, any contract, mortgage, promissory note, or other document incident to a building transaction” constitutes an act or practice that is considered fraudulent, deceptive, or dishonest under Minn. Stat. § 326B.84, subd. 1(2).

7.       Minn. Stat. § 326B.082, subd. 12, authorizes the Commissioner to issue a licensing order revoking a license, imposing monetary penalties of up to $10,000 for each violation, and requiring that the person cease and desist from committing the violation. 

8.       Based upon the facts alleged in the Notice and Order for Prehearing Conference, the Respondents engaged in fraudulent, deceptive or dishonest practices by presenting a sham money order as payment for an outstanding debt.  Respondents demonstrated financial irresponsibility and untrustworthiness by failing to pay Complainant for materials and supplies and by failing to satisfy Discover Bank’s judgment.  Respondents also failed to comply with requests for information, documents, or other requests from the Department.  Accordingly, the Respondents harmed the public by engaging in conduct that demonstrated that they are untrustworthy, financially irresponsible, or otherwise incompetent or unqualified to act under a residential building contractor license, in violation of Minn. Stat. §§ 326B.082, subd. 11(b)(6), (8), and (9), and 326B.84 (2), (15), and (16). 

9.       The Respondent is subject to discipline under Minn. Stat. §§  326B.082, 326B.083, and 326B.84.  The imposition of sanctions is in the public interest.

Based upon the foregoing Conclusions, the Administrative Law Judge makes the following:

RECOMMENDATION

IT IS HEREBY RECOMMENDED that the May 24, 2010, Licensing Order issued by the Commissioner of Labor and Industry against the Respondents, Thomas W. Eilertson and Eilertson Exteriors, LLC, be AFFIRMED.

Dated:  August 12, 2010

 

s/Barbara L. Neilson                                 

BARBARA L. NEILSON

Administrative Law Judge

 

Reported:  Digitally recorded (no transcript prepared). 

 

NOTICE

          This Report is a recommendation, not a final decision.  The Commissioner of Labor and Industry will make the final decision after a review of the record.  The Commissioner may adopt, reject or modify the Findings of Fact, Conclusions, and Recommendations.  Under Minn. Stat. § 14.61, the final decision of the Commissioner shall not be made until this Report has been made available to the parties to the proceeding for at least ten days.  An opportunity must be afforded to each party adversely affected by this Report to file exceptions and present argument to the Commissioner.  Parties should contact the Office of the Commissioner of Labor and Industry, 443 Lafayette Road, St. Paul, MN  55155, to ascertain the procedure for filing exceptions or presenting argument.  Pursuant to Minn. Stat. § 14.62, subd. 1, the Agency is required to serve its final decision upon each party and the Administrative Law Judge by first-class mail or as otherwise provided by law. 

 

If the Commissioner fails to issue a final decision within 90 days of the close of the record, this report will constitute the final agency decision under Minn. Stat. § 14.62, subd. 2a.  The record closes upon the filing of exceptions to the report and the presentation of argument to the Commissioner, or upon the expiration of the deadline for doing so.  The Commissioner must notify the parties and the Administrative Law Judge of the date on which the record closes.

 



[1] May 24, 2010, Licensing Order (attached to and incorporated in Notice and Order for Prehearing Conference).

[2] May 24, 2010, Licensing Order.

[3] May 24, 2010, Licensing Order.

[4] May 24, 2010, Licensing Order.

[5] May 24, 2010, Licensing Order.

[6] May 24, 2010, Licensing Order.

[7] Notice and Order for Prehearing Conference, p. 2, and attached May 24, 2010, Licensing Order.

[8] Notice and Order for Prehearing Conference, p. 2.

[9] Affidavit of Service by First Class Mail of Ann Kirlin, attached to the Notice and Order for Prehearing Conference.

[10] Notice and Order for Prehearing Conference, p. 1.

[11] Notice and Order for Prehearing Conference, p. 3.

[12] Letter to Respondents, dated June 28, 2010, returned on July 8, 2010.

[13] Department’s Letter Motion for Default Judgment, July 27, 2010.

[14] Documents Department received from Mr. Eilertson on August 5, 2010.