RACE-87-003-AK

                                                      6-2600-1000-2

 

 

                              STATE OF MINNESOTA

                       OFFICE OF ADMINISTRATIVE HEARINGS

 

                      FOR THE MINNESOTA  RACING  COMMISSION

 

 

In the Matter of the                                      ORDER  DETERMINING

Occupational License                                      ENTITLEMENT   TO

of jack Haymes                                            FEES AND  EXPENSES

 

 

    On October 2, 1987, Jack Haymes and Kathy W.  Hutchinson  d/b/a  Hutchinson

Racing Stables  applied to the undersigned for an award of $6,550.45 in

attorneys' fees and expenses pursuant to the Equal Access  to  Justice  Act,

Minn.  Stat.  3.761, et Seq.  The Minnesota Racing Commission filed a response

and objection to the application.    No actual in-person hearing has  been  held

in this matter.   The record closed on December 16, 1987, upon  receipt  of  the

final submission.

 

    Appearing on behalf of the Applicants herein was Robert  J.  Hennessey,  of

the firm of Larkin, Hoffman, Daly & Lindgren, Ltd., 1500 Northwestern

Financial Center, 7900 Xerxes Avenue South,  Bloomington,  Minnesota  55431.

Appearing on behalf of the Minnesota Racing Commission  was  Special  Assistant

Attorney General Mary B. Magnuson, 200 Ford Building,  117  University  Avenue,

St. Paul, Minnesota 55155.  Based upon the record  in  the  original  contested

case and the filings in connection with the application for fees, the

Administrative Law Judge makes the following:

 

                                FINDINGS OF FACT

 

    1.   Kathy Walsh Hutchinson is licensed by the Minnesota Racing Commission

as an owner/trainer.  She has been licensed since  1985.  In  addition  to  being

licensed in Minnesota, she is also currently licensed  in  California.  She  has

been involved with horse racing since 1947.    As of December, 19B6, she

maintained 10 horses on the grounds of Santa Anita Park  Racetrack  in  Arcadia,

California, in addition to whatever other horses she had  here  in  Minnesota.

She employed three grooms, two hot walkers, an exercise boy,  a  blacksmith  and

an assistant trainer.  In addition to those employees,  she  also  has  retained

various outside contractors, notably veterinarians.

 

    2.   Jack D. Haymes was employed by Kathy Hutchinson  as  her  assistant

trainer.  He was first licensed by the Minnesota Racing  Commission  in  1986  as

Hutchinson's assistant trainer.

 

    3.   Both in theory and in practice, Hutchinson was Haymes' employer.  She

directed his activities, particularly with regard to medication of horses.

She directed which horses would get which  medications.  Although  Haymes  was

the person who actually administered the medications, it  was  Hutchinson  who

controlled those activities.

 

    4.   On September 12, the Board of Stewards suspended  Jack  Haymes  for

30 days, fined him $500, and ordered him off all grounds controlled by the

 


Commission.  On September 15, Haymes filed a Notice of Appeal and  Request  for

a Stay with the Commission.  Haymes (and Hutchinson, who had  been  similarly

suspended and fined on August 28) appeared before a panel of the Commission on

September 23.  In his Notice of Appeal, Haymes argued that there  were  serious

defects in the Commission's rules.  That same argument was repeated  to  the

Commission panel on September 23.  On October 10, 1986, the  Commission  issued

Statements of Charges, and subsequently issued Notices and Orders for  Hearing

against both Hutchinson and Haymes in connection with alleged medications  of

certain of Hutchinson's horses in violation of Commission rules.

 

    5.   As a result of the two contested cases being consolidated for

purposes of the hearing, the participants behaved as if Hutchinson had

intervened in the Haymes case, and Haymes had intervened in the  Hutchinson

case.  Attorneys for both were allowed to cross-examine witresses,  and  there

was never a distinction made between them.  Hutchinson has agreed to  pay  the

bills for Haymes' litigation.

 

    6.   The charges against Haymes were amended so that at the time of  the

administrative hearing commenced in December of 1986, he was charged with  two

violations.  First of all, Haymes was charged with permitting two  horses  to

race with medications in their systems and being responsible for positive test

samples pursuant to Minn.  Rule pts. 7890.0130, subp.  I and 7877.0170,

subp. 2 C(2).  Secondly, Haymes was charged with failing to guard  two  horses

so as to prevent the administration of medication to them in violation  of

Minn.  Rule pt. 7877.0170, subp. 2 C(3).

 

    7.   Following an administrative hearing before the undersigned, and  a

review by the Commission pursuant to Minn.  Stat.  14.61 and 14.62, the

Commission dismissed all charges against Jack Haymes by its Order of

August 19, 1987.

 

    8.   There has not been any appeal from the Commission's Order  dismissing

the charges against Haymes.

 

    9.   On October 2, 1987, Haymes and Hutchinson applied for an award  of

attorneys' fees and expenses relating to the proceeding against Haymes.

Attached thereto was an affidavit from the attorney who represented  Haymes,

Thomas F. Miley.  The affidavit sets forth, in detail, fees for Miley  and  a

clerk, as well as expenses for copying and delivery charges.  The  attorney

fees are at the rate of $75 per hour, while the clerk's fees are at the  rate

of $35 per hour.  These fees relate to activities from September 11,  1986  to

September 30, 1987.  They include various correspondence and meetings in

preparation of the September 15 Notice of Appeal and the hearing before  the

Commission panel on September 23, 1986.

 

    10. The violations herein were alleged to have occurred in  August  of

1986.  In September, a panel of the Commission heard appeals  from  stewards

suspensions and fines, and stayed actions of the stewards pending its  own

determination.  In October of 1986, statements of charges were  issued  along

with notices and orders for hearing.  The hearing was held in  December  of

1986, with a final session in February 1987.  On March 16, 1987, a  bill  was

introduced in the Senate (S.F. 922) which was ultimately enacted and  became

Laws of Minnesota 1987, chapter 69.  On March 19, a companion bill was

introduced in the House.  On March 23, the Commission published  a  proposed

rule revision in the State Register.  The proposed rules amended many  of  the

 

 

                                     -2-

 


Commission's existing rules  covering  a  variety  of  topics  relating  to  wagering,

stabling, licensure, the stewards, and other Matters.  Included in the rule

amendments, however,  was  an  amendment  which  clarified  the  prohibition  against

horses carrying foreign substances  in  their  bodies  during  a  race.  This  was  an

amendment to Rule 7890.0110, which was one  of  the  rules  at  issue  in  the

Hutchinson/Haymes contested case hearing.  The rule amendments became

effective in June of  1987.  See,  11  State  Register  2201.  In  addition,  Laws  of

Minnesota 1987, ch. 69, approved on May  7,  1987  with  an  effective  date  of  May

8, 1987, required the Commission to adopt rules prohibiting a horse from

carrying foreign substances in a  race.  Had  that  statute  and  that  rule  been  in

effect at the time of the alleged violations, they would have had a

substantial impact upon the impact of the proceedings against Hutchinson and

Haymes.  They contain the prohibition which the Commission advocated at the

contested case hearing.

 

    11. The hearing,  which  took  portions  of  four  days,  was  primarily  focused

upon expert  testimony  from  veterinarians  and  academicians  regarding  the  state

of current knowledge a bout inderal LA and its effect on hors es , particularly

how horses metabolize it.  The parties were able to dispose of some

uncontroverted issues by stipulation and agreement.  Both parties avoided

wasting time on uncontroverted matters and both proceeded in a professional

manner.  Neither party engaged in conduct that unduly or unreasonably

protracted the final resolution of the matter.

 

    Based upon the  foregoing  Findings,  the  Administrative  Law  Judge  makes  the

following:

 

                                    CONCLUSIONS

 

    1.    That the Applicant herein has complied with all substantive and

procedural requirements of law or rule so as to establish that the

Administrative Law Judge does have jurisdiction in this matter.  While the

application for fees was not filed within 40 days from the date of the

Commission's final disposition  as  required  by  Minn.  Rule  pt.  1400.8401,

subp. 3, there is no 40-day requirement in the statute.  The rule cannot

remove jurisdiction from the  ALJ  or  the  agency.  Leisure  Hills  of  Grand

Rapids v. Levine, 366 N.W.2d 302 (Minn.  App. 1985), rey. denied.

 

    2.    As a result of the consolidation, Hutchinson is deemed to be "a

person named or admitted as a party" in the Haymes case.

 

    3.    Haymes, individually, is not a "party" for purposes of the Equal

Access to Justice Act.  He  is  not  an  unincorporated  business  within  the

meaning of subpart 6(a), nor  is  he  a  partner,  officer,  shareholder,  member,  or

owner of one within the meaning of subdivision 6(b).  Haymes, individually,

may not receive fees or expenses pursuant to the statute.

 

    4.    Hutchinson is the  owner  of  an  unincorporated  business.  She  meets  the

test for the number of employees and annual revenues set forth in Minn.  Stat.

  3.761,  subd. 6(a).

 

    5.    The racing of horses was  a  business  interest  of  Hutchinson,  as

opposed to any personal interest within the meaning of Minn.  Rule

pt. 1400.8401, subp. 3 A(l)(f).  Hutchinson appeared as the owner of the

racing business.

 

 

                                        -3-

 


    6.   Hutchinson is liable to Haymes for the fees and expenses.  Her

assumption of them is not a mere gratuity, but rather reflects an  underlying

liability.  The exception contained in Minn.  Rule pt. 1400.8401,

subp. 3 (A)(1)(d) does not exempt Hutchinson.

 

    7.   The $75 per hour fee for the attorney, and $35 per hour fee for  the

law clerk, as well as the expenses claimed, are all reasonable within  the

meaning of Minn.  Stat.  3.761, subd. 5 and Minn.  Rule pt. 1400.8401,

subp. 2 B.

 

    B.   The position of the Racing Commission was substantially justified in

that it had a reasonable basis in law and fact up to the Commission panel's

meeting of September 23, at which point the Respondents' legal theory  was

fully presented.  There was always a reasonable factual basis for the

Commission's position.  However, after the September 23  presentation,  the

Commission no longer had a reasonable  '  legal basis for continuing the

proceedings against Haymes.  The Commission, therefore, was not substantially

justified in continuing the proceedings against Haymes after September 23.

 

    9.   Haymes was a prevailing party within the meaning of Minn.  Rule

pt. 1400.8401, subp. 3 A(2).

 

    10.  The attached Memorandum is incorporated herein.

 

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

 

                                     ORDER

 

    That Kathy Hutchinson is entitled to an award of fees and expenses in the

amount of $4,614.70.  This is the total of all attorneys' fees and expenses

incurred by Jack Haymes after September 23, 1986.

 

Dated this 15th  day of January, 1988.

 

 

 

 

                                         ALLAN W. KLEIN

                                         Administrative  Law  Judge

 

 

                                    NOTICE

 

    Any party dissatisfied with this determination may petition for leave  to

appeal to the Minnesota Court of Appeals pursuant to Minn.  Stat.   3.764,

subd. 2.

 

 

                                  MEMORANDUM

 

    This is the first application for an award of fees and expenses  incurred

in a contested case before the Office of Administrative Hearings pursuant  to

the Equal Access to Justice Act.   This particular case raises two issues which

deserve further explanation so that it is clear how they were decided.  The

 

 

                                      -4 -

 


first is whether or not Hutchinson qual if i es as a "party" so as to be eligible

to collect fees for Haymes under the statute.            The second is whether or not

the State was "substantially justified" in proceeding against Haymes.

 

                                             I.

 

     Minn.  Stat.  3.7b1, subd. 6, defines "party", in part, as follows:

 

           (a)  Except  as  modified  by  paragraph  (b),   "party"   means   a

                 person named or admitted as a party.......          in a  . .  .

                 contested case proceeding..........        and who is:

 

                 (1)   An   unincorporated   business,   partnership,    corpora-

                       tion, association, or organization, having not

                       more than 50 employees at the time the          .  .

                       contested case proceeding was initiated; and

 

                 (2)   An unincorporated business, partnership,          corpora-

                       tion, association, or organization whose          annual

                       revenues did not exceed $4,000,000 at the time

                       the.......    contested case proceeding was initiated.

 

           (b)  "Party"  also   includes   a   partner,   officer,   shareholder,

                  member  or  owner  of  an  entity  described   in   paragraph

                  (a), clauses (1) and (2).

 

    The Act also gives the Office of Administrative Hearings rulemaking

authority to establish procedures for the submission and consideration of

applications for awards of fees and expenses in contested case proceedings.

Pursuant to that authority, the Office adopted a more definite definition of a

"party" in Minn.  Rule pt. 1400.8401, subp. 3.   That rule, in pertinent part,

provides   as   follows:

 

          (1)   In determining who is an eligible party, the Judge

                 shall consider the provisions of subpart 2, item C,

                 and the following:

 

                 (a)   The  annual  revenues  shall  mean  the   party's   annual

                       gross revenue.

 

                 (b)   The  annual  revenue  and  the  number  of  employees   of

                       the applicant and all that's affiliated shall be

                       aggregated   .  .  .

 

                 (c)   * * *

 

                 (d)   An  applicant  who  participates  in  a   contested   case

                       on behalf of one or more other persons or entities

                       that  would  be  ineligible  is  not   itself   eligible

                       for an award.

 

                 (e)   * * *

 

                 (f)   An applicant who appears individually as a part-

                       ner,  officer,  shareholder,  member,  or  owner   of   an

 

 

                                           -5-

 


                    entity eligible under the provisions of Minnesota

                    Statutes, section 3.761, subd. 6, paragraph (a),

                    clauses (1) and (2) may only assert a claim to the

                    extent the entity which they own or control can

                    assert such claim and may not assert a claim if

                    the issues on which the applicant prevails are

                    related primarily to personal interests rather

                    than to business interests.

 

    The application of these provisions to the case of Hutchinson and her

employee, Haymes, is ambiguous and doubtful.  Based upon a review  of  the  rule

and the statute, it was determined that the words were not explicit and free

from ambiguity and that, therefore, it was appropriate to  consider  legislative

history and other factors in attempting to effectuate the intention

of the Legislature.  Minn.  Stat.  645.1b.

 

    The statute, alone, gives a clearer picture of Hutchinson's status than

does the statute combined with the rule.  Under the statute, an owner of an

unincorporated business with fewer than 50 employees and annual  revenues  less

than $4,000,000 is deemed to be a "party" so long as the business is either

named or admitted as a party.  A threshold question is whether or not the

business must be named, or merely the owner.  A good example is that of

Hutchinson.  Hutchinson did business in her own name,  without  any  corporation

or other formal entity intervening.  As such, she was an unincorporated

business.

 

    The matter is substantially complicated, however, by the rule.  The rule

adds two limitations to the statutory standard.  The first is that an

applicant participating in a contested case on behalf of one or more  other

persons or entities that would be ineligible is not itself  eligible.  To  take

a clear example, assume that an individual is engaged in a contested  case  with

the State over the revocation of his driver's license.  The  revocation  arises

out of a purely personal event, such as an implied  consent  revocation.  Assume

further that the individual was the sole shareholder and officer of a

corporation.  It would be improper for the corporation to attempt to get

involved in the revocation proceeding and then claim that it was entitled to

an award for fees and expenses.  The provision, in subpart 3  A(l)(d)  would

prevent that from happening.  It states that an applicant (the corporation)

who participates in a contested case on behalf of another person or  entity

that would be ineligible is not itself eligible.  Since the individual would

be ineligible, the corporation must be ineligible as well.

 

    A second provision in the rule which clouds the determination of whether

or not Hutchinson is an appropriate party for Haymes' fees is contained  in

paragraph (f) of the same subpart 3.  It provides that an applicant who

appears individually as an owner of an eligible entity may only assert  a  claim

to the extent that the entity which they control can assert such a  claim,  and

further that the applicant may not assert a claim if the issues are related

primarily to personal interests rather than to business  interests.  Again,  an

example might be appropriate.

 

    It is very clear from the legislative history surrounding the  adoption  of

the statute that the intent of the Legislature was to compensate small

businesses for court costs and attorneys' fees when they prevailed  against  the

State if the State's was not substantially justified.  An  example  used  during

a Senate Judiciary Committee hearing on February 24, 1986 was the following:

 

 

                                     -6-

 


          Every once in a while you get a case where the  agency  has

          the wrong person, and so you get a notice that you  are  not

          in compliance, and let's just say this is  A-Jax  Cleaning

          Company, okay, and A-Jax Cleaning Company gets  this  notice

          and calls back and says, I'm not A-Jax Cleaning  Company  in

          Brown County, I'm A-Jax Cleaning Company in  Redwood  County,

          and you got the wrong person.  And  notwithstanding  that  the

          agency knew or should have known that they got  the  wrong

          person, they proceed to commence some  disciplinary  action.

          I guess what I'm trying to say is that I think  this  would

          be valuable in the case of what I  consider  administrative

          screw-ups, where the time and hassle going into  the  defense

          is going to be compensated by the State.  I  think  it's  a

          good bill because in some of the complaints that  you  get

          against government there will be some form of redress.

 

Statement of Senator Gene Merriam, included in  partial  transcript  of

proceedings of Senate Judiciary Committee on February 24,  1986,  as  prepared  by

the Administrative Law Committee of the Minnesota Attorney General's Office

and submitted on October 27, 1986 to Administrative Law Judge Melvin B.

Goldberg, as Ex.  C, p. 2.

 

    The example given by Senator Merriam is an obvious "screw-up".  But the

Act was intended to cover less obvious situations.  There is currently a

statute, Minn.  Stat.  549.21, which allows for the  award  of  costs,

disbursements and reasonable attorney's fees in the case of bad faith,

frivolous, delaying, harassing, or fraudulent claims.     The EAJA was intended

to go beyond "bad faith" cases.  As the primary sponsor  of  the  Equal  Access  to

Justice Act stated, the bill is based upon the federal  Equal  Access  to  Justice

Law (28 U.S.C. 2412), which contains  the  phrase  "substantially  justified".  In

testimony before the House Judiciary Committee on February 11, 1986 he

explained:

 

          The "substantially justified" is the doctrine or  the  clause

          which is sort of the key to the bill, and those  who  framed

          this legislation originally in Washington tried to  make  it

          into sort of a reasonableness standard that would  sort  of

          cut down the middle between giving the small business a

          reimbursement for court costs and attorneys'  fees  whenever

          they prevail, and to automatically siding with  the  State,

          only giving reimbursement when the State reacted in bad

          faith.  So it's sort of a reasonableness standard that

          tries to cut down the middle.

 

Submission of Administrative Law Committee of  the  Minnesota  Attorney  General's

Office, Ex.  A, p. 1., Testimony of Mike Hickey, representing the National

Federation of Independent Business.  See also Ex.  E, p. 1, distributed to the

Senate Judiciary Committee on February 17, 1986.

 

    The federal Act defines "party" quite differently than the Minnesota law.

Put briefly, the federal definition is much simpler than the state's.  Under

the federal law, 28 U.S.C. 2412 (d)(2)(B), "Party" means:

 

          (i)  an individual whose net worth did not exceed

              $2,000,000  . . .  or

 


                any owner of an unincorporated business, or any

                partnership,  corporation  .  .  .  the  net  worth   of   which

                did not exceed $7,000,000.......        and  which  had  not   more

                than 500 employees    .  .  .

 

     Explaining the difference, before the various committees of the Minnesota

Legislature,  was  a  challenge  for  both  Mr.  Hickey  and   the   legislative

sponsors.   For example, before the House Judiciary Committee on February 11,

1986, the following colloquy occurred:

 

          REPRESENTATIVE  BISHOP:  I  looked   through   a   previous   draft

          of this  bill  when  it  was  before  the  House  last  year  and

          have read  a  lot  of  other  material,  and  in  each  case  I  found

          that  while  you've   covered   corporations   and   partnerships,

          individuals  who  had  exactly  the   same   business   coverage   and

          had over a million dollars of net worth        . .  .  would  have  no

          equal justice . . . .     I knew some people who would be

          covered  because  they  were  doing   business   as   [Subchapter   S]

          corporations, whereas if they were doing business as

          individuals  with  exactly  the  same   business   and   same   number

          of  employees  and  same  number  of  net  worth,  they   wouldn't.

          Can you answer that part?

 

          HICKEY:  Glad to answer.......       Representative    Bishop.    I

          concur  with  your  point  on  individuals.  It  would  be   nice   to

          cover  them  under  the  Act.  We  just  feel,  this  year,   with

          the  potential  budgetary  impact  of  the  legislation   and   in

          light  of  the  situation  here  with  the  State  budget,   we'd   be

          better  just  to  have  small  business  owners   covered.   I   think

          the  concept  works  just  as  well  for  individuals,  too,   but   I

          think  the  State's  going  to  have  a  lot  more  exposure,  and   I

          feel  for  individuals  that  are  aggrieved  by  the  State   just

          as I do for small business owners, but we just felt it

          better  to  start  off  with  a  small  undertaking  and  just   cover

          small business owners.

 

    In the Senate Judiciary Committee on February 24, 1986, the following

occurred:

 

          WILLET:  As  I  indicated,  the   subcommittee   did   a   substantial

          amount  of  work  on  the  original  proposal  and  I  believe  has

          fine-tuned  it  now  to  the  extent  that  I  believe  it  would

          remove  the  possibility  of  frivolous  cases.   I   think   that

          was  the  concern  and  nobody  certainly  wants  that  to   hap-

          pen .  .  . .  Under  subdivision  5,  the  parties   eligible   to

          recover  would  include  the  sole  owner  of   an   unincorporated

          business or other business entities with a maximal 50

          employees.  And  that'S  to  keep  it  down  to  the  small   business

          and  that's  the  ones  we  are   concerned   about.   Individuals,

          an  individual  would  not  be  eligible  to  recover.   That   was

          handled  by  the  subcommittee  too  because  there   was   concern

          about just having frivolous cases by individuals just

          pouring  into  the  court  and  that's  not  the  intent  of  this

          proposal .  .  .  .

 


CHAIRMAN: Senator Willet,  what's  the  justification  for

doing this for small business but not for individuals who

might have problems with the State and end up  winning  their

case but having high attorney fees?

 

WILLET: Well, Mr. Chairman, the main thrust  here,  and  I

suppose the argument there could be to include those, but

the main reason was, is there would be,  and  we  couldn't

think of any cases where that would be the case.  Most

cases would  come  in terms of safety regulations or  environ-

mental  questions  with maybe developers or expanding

businesses.   And  the cases in terms of individuals would  be

either slight  or  nonexistent that we could point  to.  There

may be some  that  I did not think about, but I couldn't put

my finger on  any  that would be substantial that you would

probably want  to  consider.  And the concern by the subcom-

mittee was that they did not want to load  up  the  docket

with just maybe some frivolous action in the court.

 

 

 

POGEMILLER: Mr. Chairman, Senator  Sieloff,  I  am  having

trouble following all this but are, have you in  any  way,

and I am just going to have to take your  word  for  this,

have you in any way changed the criteria  that  the  busi-

nesses that would be covered by this would be unincorporated

business with less than 50 employees and  less  than  four

million in revenue?

 

SIFLOFF: No, I have only changed the  standing  to  invoke

the Act by adding to that not only the business  itself,  the

corporation, but also the persons who, like the  owner  of

the corporation, the little corporation, or the member of

the nonprofit organization or somebody  who  is  impacted,

because what happens in these things is that they are

dragged into these cases personally and should have

standing along with the entity itself.

 

POGEMILLER: Senator Sieloff, all of these  changes  you  made

here, and again I haven't had time to go through them all,

in no way broadens coverage of this from the way  it  came

out of subcommittee?

 

SIELOFF: No. No. You still  have  to  have  no  more  than

50 employees or no more than $4  million.  It's  the  same

standards.

 

COUNSEL:  I think it substantively is the same.  It takes

out the language talking about.  It doesn't include a

person suing or being sued as an individual  but  I  think

with the type, as you say, it has to be one or two  and  it's

the same standards.  You know, under  50  employees  or/and

under $4 million.  That's the controlling language.

 

 

                            -9 -

 


    When it came time to adopt the Office of Administrative Hearings' rule,

there was a great deal of comment on the proposed definition of a "party",

both at  the  rulemaking  hearing,  and  in  written  submissions.  The

Administrative Law Committee of the Minnesota Attorney General's Office was

particularly vigorous in urging a narrow construction of the Act, one that

would limit the amount of any claims paid out.  On the other hand, licensed

professionals such as a medical doctor, a psychiatric institute, and attorneys

representing licensed professionals, urged a broad reading of the Act so that

they would be allowed to collect if they prevailed in disciplinary proceedings

and showed the State was not substantially justified.  The Administrative Law

Judge who conducted that hearing recognized the problem and encouraged debate

and submission on it.  He then prepared his Report, which described the

proposed definition of an eligible "party" as the rule which generated the

most comment.  He noted the following:

 

          The most troublesome  argument  raised  by  several  parties  in

          oral and  written  testimony  concerns  the  limitations  that

          must be put on  the  principle  of  including  the  licensed

          professional within the coverage of EAJA.  On the one hand,

          there is the professional  who  has  no  employees  and  simply

          bills for his time   . . .  who therefore meets any reasonable

          definition  of  an  "unincorporated  business."  On  the  other

          hand, there is the  licensed  professional  who  must  work  for

          another person or  entity  (the  dental  assistant  who  must

          work under  the  supervision  of  a  licensed  dentist).  The

          latter person is clearly not included within the meaning of

          the EAJA which is to apply only to an "unincorporated

          business  . . .  [citing from the statute]."

 

          The legislative  history  is  not  conclusive.  There  is  a

          clear legislative intent  to  limit  the  applicability  of  the

          Act to small businesses,  and  not  provide  coverage  to  all

          individuals who prevail in proceedings involving the

          State.  The  limitation  was  made  primarily  to  limit  the

          State's potential exposure.  This is a reasonable limitation

          given the  Legislature's  lack  of  experience  with  claims

          under EAJA.  However, the applicability of the term

          "unincorporated  business"  to   the   professionally-licensed,

          sole practitioner was not directly addressed by the

          Legislature (at least as evidenced by the materials

          submitted in this proceeding).

 

 

 

          The OAH takes the position  that  if  an  applicant  for  fees

          can establish that he/she  is  a  "Person"  that  meets  the

          unincorporated business definition  of  subd.  6,  as  well  as

          the rest of the Act, then  he/she  is  a  party  entitled  to

          compensation.  That position is reasonable given the

          legislation . . . .   There are many  arguments  that  can  be

          advanced  for  distinguishing  between  the   self-employeed

          licensee  and  the  employee-licensee.  There  may  also  be

          situations where  a  professional  licensee  cannot  meet  the

          definition  of  an  unincorporated  business.  These   arguments

          are best made on  an  individual  basis  to  an  administrative

 

                                        -10-

 


          law judge or a court.  To avoid excessive litigation the

          Legislature may wish to clarify the EAJA.  The OAH rules

          are the best that can be drafted under the existing

          legislation given the variety of factual circumstances that

          must be covered.

 

    The position adopted by the Administrative Law Judge in approving the

proposed rules is essentially the same conclusion as was reached  by  the

Attorney General's Administrative Law Committee.  In its initial post-hearing

submission, the Committee recognized that the distinction between a business

and an individual created a problem, and urged the Administrative Law  Judge  to

avoid deciding it one way or the other.  The Committee stated:

 

          The rules which are proposed do not specifically bar  EAJA

          claims by licensees who have been involved in disciplinary

          proceedings.  If licensees who are involved in  such  cases

          wish to assert claims under EAJA, they are free to do  so.

          If such claims are filed, the parties can then litigate the

          issue of the applicability of EAJA to that specific

          licensee and proceeding.  This is clearly the best means by

          which to resolve these difficult issues.  The  question  of

          whether  . . . any particular person is  an  "unincorporated

          business," is best resolved in the context of a concrete

          factual situation which has been proven in a contested case

          hearing, not in the abstract setting of a rulemaking

          proceeding.

 

    A review of the legislative history of both the statutory adoption  and  the

rulemaking hearing convinces me that the distinction between a business  and  an

individual was intended to be a distinction based upon the type of activity

that was at issue.  If it was a business activity, it is  covered  by  the

statute, but if it is a purely personal activity, then it is not.  The

distinction will be difficult to draw in some cases, but it is exactly the

kind of distinction that must be drawn by taxpayers, tax advisors and tax

collectors every day when taxpayers attempt to deduct the cost of hobbies,

claiming that they are really businesses.  Based upon all  the  facts  and

circumstances, a decision must be made as to whether the activities  engaged  in

are primarily for profit, or primarily for pleasure.  That is the distinction

that was intended to be drawn in the EAJA by the  Legislature.  The  rule

adopted by the Office is ambiguous, and Administrative Law Judge Goldberg

candidly acknowledged the ambiguity and acknowledged his willingness to defer

resolution of the problem to later case-by-case determinations in the context

of concrete fact situations.

 

    It is unquestioned that the horseracing business, at least as  practiced  by

Kathy Hutchinson, was a business.  It was not a hobby or a personal interest.

It was how she made her livelihood, and was clearly a profit-oriented

operation.  Based on the analysis set forth above, it is concluded that the

horseracing business of Kathy Hutchinson qualifies as an "unincorporated

business" that was intended to be covered under EAJA to the same extent as if

she had incorporated it.

 

   A more difficult question arises, however, out of the  fact  that  the

expenses and attorneys' fees were incurred to defend Jack Haymes, not Kathy

Hutchinson.  Haymes was clearly an employee of Hutchinson,  but  was  also

 

 

                                     -11-

 


licensed separately.   The applicable rule of the  Racing  Commission  required

that assistant trainers must be employed by a  licensed  trainer.  Minn.  Rule

pt. 7877.0130, subp. 3 C. The immediate analogy is that of  a  dentist  and  a

dental assistant, as proposed by Administrative Law Judge  Goldberg,  who  stated

in his Report that the dental assistant is clearly not  included  within  the

meaning of an "unincorporated business".    However, it is believed  that  Judge

Goldberg was referring to a dental assistant who was charged with some

wrongdoing that had nothing to do with the dentist.  For  example,  a  dental

assistant who is employed by a dentist and who assaults a patient and is

subject to a license revocation proceeding is involved in that  proceeding  as  a

result of his or her own intentional act that (presumably)  was  not  directed,

authorized or condoned by the licensed dentist.  It was  beyond  the  scope  of

her employment.  If the dental assistant were fined $500 by the licensing

board, clearly the licensed dentist would have no responsibility  to  pay  that

fine on behalf of the assistant.    It is the assistant who was responsible for

the assault, and who must pay the fine.  The assistant is not an

"unincorporated business", and thus would not be eligible to  recover  under  the

Act.

 

    On the other hand, however, what of the dental assistant  who  is  merely

following the orders of the employer, the licensed dentist,  without  any  intent

or knowledge of wrongdoing, but who still becomes embroiled in a disciplinary

proceeding?  Assume that the licensed dentist directed the  assistant  to  take

certain actions which both believed were perfectly legal and appropriate.

Does that change the outcome of the EAJA's applicability?

 

    The general rule, both in Minnesota and elsewhere, is  that  a  principal

must reimburse an agent for the necessary costs of litigation, including

attorneys' fees, brought against the agent by third persons  because  of  the

agent's acts done in the furtherance of the agency business.  3 C.J.S.,

 Agency 322.

 

         A principal is subject to a duty to exonerate an agent who

         is not barred by the illegality of his conduct to indemnify

         him for expenses of defending actions by third persons

         brought because of the agent's authorized conduct, such

         actions being unfounded but not brought in bad faith . . . .

 

Restatement_2d  _of Agency,  439.    The economic rationale for  this  common-law

rule was set forth by Judge Learned Hand in Admiral Oriental Lines  v.  United

States, 86 F.2d 201 (2d Cir. 1936) as:

 

         The venture is the principals         as the profits will be

         his.   So should the expenses.    Since by hypothesis the

         agent's outlay is not due to his mismanagement, it should

         be regarded only as a loss, unexpected it is true, but

         inextricably interwoven with the enterprise."

 

86 F.2d at 202.  In other words, the principal must bear the costs of

litigation, even the agent's separate costs of litigation, just as the

principal must bear other costs of the business.

 

   A variant on the standard occurs, however, when both  the  principal  and  the

agent are sued together.   In such a case, if the  principal  retains  competent

attorneys to defend the action against both the principal and  the  agent,  the

 

 

 

                                     -12-

 


agent may not  be  reimbursed  for  the  cost  of  independent  attorneys,  so  long  as

there  were  no  antagonistic  defenses  requiring  separate  representation,  and   the

principal's  attorneys  were  adequately  defending  the  agent.  For  example,   in

the c ase of Adams v. North Range Iron-Co., 191  Minn.  55,  253  N.  W.  3  (1934),  a

corporation owned  a  mining  lease  on  land  in  Crow  Wing  County.  Plaintiff  Adams

was hired as the corporation's managing officer.  The corporation sublet the

leased land to a third party to mine ore upon it.  In negotiating the

sublease, Plaintiff  Adams  acted  for  the  corporation,  with  the  knowledge  and

approval of its board of directors.       Later,  the  sublessee  sued  the  company,

Adams, and the two co-owners of the company, charging that it had been

fraudulently  induced  to  sublease  the  land.  The  company  employed   attorneys   to

defend the  lawsuit  on  behalf  of  all  of  the  defendants.  The  sublessee  obtained

a verdict against the  company  and  Adams  for  a  great  deal  of  money.  Adams

happened to own  substantial  assets  of  his  own,  and  feared  that  if  the  company

could not pay the  judgment,  he  would  be  forced  to.  He  elected  to  consult

other  attorneys  and  employed  them  to  appeal  the  judgment.  Adams'  attorneys

and the company's attorneys worked together and prepared a joint appeal

brief.  They obtained a reversal of the judgment in the Circuit Court of

Appeals.  Adams then sought indemnification from the company for his

attorneys' fees  and  expenses.  The  company  denied  the  claim  and  Adams  sued.

The trial court found for the company, and Adams appealed to the Minnesota

Supreme Court.  The Minnesota Supreme Court affirmed the trial court, on the

ground that the company had performed its obligation to Adams by hiring

competent counsel to represent both it and him.  The court stated that Adams

was the sole officer of the company, and if there had been any

misrepresentation  made  during  negotiations,  the  misrepresentation   was   made   by

Adams.  There  was  no  allegation  that  any  other  person  participated  in  the

negotiations, or that the company did anything to expose itself to liability

other than what was  done  through  Adams.  The  Court  said  there  were  no  facts  to

base a claim  of  a  divergence  of  interests  or  antagonistic  positions  between

the two.  The  court  was  satisfied  that  under  the  facts  of  the  case,  both   Adams

and the  company  would  either  stand  or  fall  together.  The  Supreme Court held

that Adams was  not  entitled  to  reimbursement  for  the  fees  of  his   separate

attorneys.

 

    In the  Admiral  Oriental  Lines  case,  supra,  judge  Hand  stated  that   where

the principal and' agent are  both-sued and where the  agent  had  a   different

                      

interest to protect that was not necessarily coincident with the principal's,

then the agent is entitled to defend its separate interest with separate

attorneys and  is  also  entitled  to  indemnification  from  the  principal  for  those

attorneys' fees.

 

    A more recent case analyzing both the Adams and Admiral Oriental cases

stated the rule thusly:

 

          Together, these cases stand for the proposition that where

          the principal defends itself, the agent is not eligible for

          indemnification unless the principal's defense leaves the

          agent's interests unprotected.

 

Basmajian v. Christie, Manson & Woods, 629 F. Supp. 995 (S.D.N.Y. 1986).

 

    In the case of Hutchinson and Haymes, different attorneys were used

because of the  potential  for  a  conflict  or  divergence  of  interests  between  the

two.  Although  that  divergence  never  ripened  into  open  disagreement  or  an

 

 

 

                                        -13-

 


adversary relationship, Haymes was separately represented  because  Hutchinson's

attorneys could not defend his interests if they came into conflict with

Hutchinson's interests.  Under such a scenario, the case law  holds  that  Haymes

is entitled to reimbursement for his reasonable attorneys' fees by

Hutchinson's business.  Contrary to the Commission's  Memorandum  in  Response

and Objecting to Application for Expenses and Attorney Fees, Hutchinson's

payment was not a "gratuitous gesture".  So long as they had divergent

interests warranting separate attorneys, she was obligated to  reimburse  Haymes

for reasonable costs of defense, including attorneys' fees.

 

                                      II.

 

    The rules adopted to implement the Equal Access to Justice Act  specify,  in

a number of places, that a prevailing party is not entitled  to  reimbursement

solely because the agency did not prevail in the contested  case.  See  Minn.

Rule pt. 1400.8401, subp. 3 A(2)(c) and subp. 3 C. Compensation  is  limited  to

those cases where the applicant shows that the State's position was not

"substantially justified", meaning that it did not have a reasonable basis in

law and fact, based on the totality of the circumstances prior to  and  during

the contested case proceeding.

 

    It is concluded that prior to the September 23, 1986  Commission  hearing,

the Commission was proceeding on a reasonable basis -- that the horses had

been given medication, that they had raced with medication in  their  systems,

and that numerous rules had been violated by Hutchinson, Haymes,  or  both.  But

after the filing of the September 15 Notice of Appeal and after the

September 23 presentation to the Commission panel, the Commission did  not  have

a reasonable legal basis for continuing to proceed against  Haymes.  After  that

date, the Commission's position was not "substantially justified".

 

                                      Ill.

 

 

    As noted in Conclusion 1, there is a question regarding the  validity  of

the Office's rule setting a 40-day time limit for the filing of  an  application

for fees.

 

    The rule at issue, Minn.  Rule pt. 1400.8401, subp. 3, provides  that  the

application must be filed within 40 days of an agency's final decision.

 

    In this case, the Commission's final decision was issued on August 19.

The application for fees was filed on October 2, which is 44 days later.

 

    In the case of Leisure     Hills  of  Grand    Rapids v.Levine, 366 N.W.2d 302

(Minn.  App. 1985), rev. denied, the Court held    at a similar rule was  invalid

to limit the jurisdiction of an agency because the time limit for  filing  an

appeal was not in a statute -- it was only in a rule.  The  Court  reasoned  that

the limits of the Agency's jurisdiction had to be set by the Legislature, and

that the Agency could not limit its own jurisdiction by rule.

 

    The same factual situation exists here -- there is no time limit  in  the

statute.  The 40-day limit is only in a rule.  The rule, therefore, is

ineffective to bar this claim.

 

 

                                              A. W. K.

 

 

                                     -14-