OAH 8-3001-17706-2

 

 

STATE OF MINNESOTA

OFFICE OF ADMINISTRATIVE HEARINGS

 

FOR THE DEPARTMENT OF TRANSPORTATION

 

In the Matter of the MnDOT Detroit Lakes Regional Headquarters, Construction Project Number 00TZ1791B

 

FINDINGS OF FACT,

CONCLUSIONS AND

RECOMMENDATION

 

The above-entitled matter came on for an evidentiary hearing before Administrative Law Judge Eric L. Lipman on June 8 through June 20, and June 23 through June 25, 2009.  For 11 days the evidentiary hearing was held at the Office of Administrative Hearings in St. Paul, Minnesota.  For two days, the evidentiary hearing was held at the Clay County Courthouse in Moorhead, Minnesota. The parties submitted Post-Hearing Memoranda on August 14, 2009 and Responses on August 28, 2009.  The hearing record closed on August 28, 2009.

 

Michael A. Sindt, Assistant Attorney General, represented the Minnesota Department of Transportation, Office of Construction and Innovative Contracting (“MnDOT-OCIC”).  Thomas R. Revnew and Michael L. McCain, Seaton, Beck & Peters, P.A., represented Comstock Construction, Incorporated (“Comstock”).  Cynthia B. Jahnke, Assistant Attorney General, appeared on behalf of Minnesota Department of Labor and Industry (“DOLI”).

 

STATEMENT OF ISSUES

 

1.       Does MnDOT-OCIC have legal authority to enforce the prevailing wage requirements under its contract for the Detroit Lakes Regional Headquarters, Construction Project Number OOTZ1791B?

 

2.       Did Comstock err in the assignment of contract-related tasks to the particular job classifications listed under Minn. R. 5200.1000?

 

3.       How much, if any, back wages does Comstock owe its employees?

 

The Administrative Law Judge concludes that MnDOT-OCIC does have the authority to enforce the prevailing wage requirements of Minnesota law as to Construction Project Number OOTZ1791B.  The Administrative Law Judge further concludes that MnDOT-OCIC has failed to prove that Comstock misclassified any of the labor tasks that the contractor undertook for this project.  Accordingly, the undersigned recommends that the Commissioner dismiss the MnDOT-OCIC claim in its entirety and remit to Comstock the $27,074.86 in contract proceeds that has been held by the Department pending a final “close out” of Project Number OOTZ1791B.

 

Based upon all of the testimony and exhibits, and the arguments of the parties, the Administrative Law Judge makes the following:

 

FINDINGS OF FACT

 

CONTRACT FORMATION:

 

1.               On or about August 17, 2000, Comstock and MnDOT entered into a contract that involved adding onto and remodeling MnDOT’s Detroit Lakes District Regional Headquarters.[1]

 

2.               The project had three key components: adding to, and remodeling of, the Headquarters Building; demolition of Building Number 90617 at the Headquarters site; and construction of an addition to the Material Lab Building with a connection of the Lab to the Headquarters Building.[2]

 

3.               The project involved a doubling of the facility from approximately 70,000 square feet to 140,000 square feet.  Further, the project permitted the agency to address a number of then-existing building code issues as well as expand functionality of the Regional Headquarters.  This project was a complicated undertaking, which combined into a single, integrated statement of work, six smaller renovation projects.[3]  

 

4.               The contract required Comstock to pay employees who worked on the project prevailing wages that were consistent with Minnesota’s Prevailing Wage Act (Minn. Stat. §§ 177.41 - 177.44).[4]

 

5.               By including the prevailing wage requirements in its agreement with Comstock, MnDOT hoped to assure that persons who worked on the project would receive the real value of the services that they performed.[5] 

 

6.               The contract lists the master job classifications and provides contractors with codes to use in classifying work.  The listing of job classifications in the contract includes more than 140 distinct categories of work.[6]

7.               As part of the solicitation process, MnDOT-OCIC included a schedule of prevailing wages for the period of contract performance.  These wage rates, issued at the time of contract formation, were effective throughout the life of the contract.[7] 

 

8.               Under the terms of the MnDOT–Comstock contract, Comstock was required to submit certified payroll reports to MnDOT-OCIC, and to make certified payroll records available within three business days, if so requested by agency officials.  The payroll records were to contain, among other things, the employee’s name, applicable classification codes under the prevailing wage law, hourly wage rates, and daily and weekly hours worked in each job classification.[8]

 

9.               Notwithstanding the requirement that the awardee of the contract pay wages that were then-prevailing for work within particular job classifications, there are no provisions of the contract that require the awardee to use only union-affiliated laborers or craftsmen when completing the contract work.[9] 

 

10.           Similarly, there are no provisions of the contract which require the awardee to classify as a skilled craftsman only those employees who earlier completed a union-affiliated apprenticeship program in the particular trade.[10]

 

11.           Approximately eighty-five percent of the work that Comstock has performed in Minnesota is within a 70 mile radius of Detroit Lakes, Minnesota.[11]

 

THE PREVAILING WAGE SYSTEM IN MINNESOTA:

 

12.           In Greater Minnesota, both union-affiliated and non-union “Merit Shop” contractors use a mix of laborers and skilled craftsmen to accomplish the completion of contract work.  The ratios of skilled craftsmen to unskilled workers will vary in particular settings depending upon the complexity of the contract work and the relative experience of the unskilled laborers in the “crew.”[12] 

 

13.           Comstock and other contractors in Greater Minnesota refer to the combinations of laborers and skilled craftsmen as the “crew mix” for a particular task.[13]

 

14.           In Greater Minnesota, Union contractors and Merit Shop contractors compete on the basis of being able to skillfully apply a mix of construction experience and trade skills to the completion of contract work.  The clever and profitable contractor, whether it is affiliated with unionized tradesmen and laborers, or not, will attempt to increase its profit margin by using lower-cost, common laborers in the place of higher-cost, higher-skilled tradesmen, whenever it is appropriate to do so.  By segregating out those elements of the contract work which do not require special skills or training to complete, and assigning these tasks to unskilled laborers, contractors are able to accomplish the contract work at a lower overall cost.[14] 

 

15.           This practice is not without controversy or its critics.  A key point of contention is whether the handling of materials used by skilled tradesmen may be undertaken by an unskilled, common laborer.[15] 

 

16.           The customs and practices of the construction industry are different in the Detroit Lakes area than it is in other areas of the state.[16] 

 

17.           Minn. R. 5200.1040 provides that each class of labor that is established must be based upon:

 

the particular nature of the work performed with consideration given to those trades, occupations, skills, or work generally considered within the construction industry as constituting distinct classes of labor.[17]

 

18.           Minn. R. 5200.1040 further provides that when establishing a new class of labor, the Department of Labor and Industry must consider:

 

work classifications contained in collective bargaining agreements, apprenticeship agreements on file with the department, the United States Department of Labor Dictionary of Occupational Titles, and customs and usage applicable to the construction industry.[18]

 

19.           No Major Job Classification in Minn. R. 5200.1100 includes a definition of the scope of work that is encompassed by the classification.[19]   

 

20.           There are, from time to time, disputes amongst trade unions as to which craft should have the opportunity to perform certain construction-related work.[20]

 

21.           As new products are introduced into the construction industry – particularly those that blend together the methods of different trades – earlier-established lines of demarcation between skilled crafts can become blurred and indistinct.[21]

 

22.           In general, trade unions in Minnesota find it advantageous to avoid jurisdictional conflicts with other local union organizations.  In the comparatively rare instance of a jurisdictional dispute that cannot be resolved informally, local union organizations have access to a more formal dispute-resolution process within the larger federation of labor organizations.[22] 

 

23.           Among tradesmen in the construction industry there is general knowledge as to scope of work under each of the Major Job Classifications, but the text of Minn. R. 5200.1100 is not specific enough to resolve difficult classification cases.[23] 

 

24.           Government officials concede that classification of a particular employee’s work is difficult when two different trade unions claim the very same duties.[24] 

 

25.           Roxanne Wilder, the principal labor inspector on MnDOT-OCIC building projects, summarized the uncertainty as to the meaning of the regulations in this way:

 

Many classification descriptions include general information and are not specific – each specific trade wants to have jurisdiction over as many tasks as possible.  Defined and undefined jurisdiction may vary by area of the United States and of the State of Minnesota.

 

Thus, even amongst those administering the state’s labor standards, there is general uncertainty as to the scope and meaning of the Major Job Classifications.[25] 

 

26.           Persons who are knowledgeable about construction practice in Minnesota can (and frequently do) differ as to the meaning of the Major Job Classifications.[26] 

 

27.           The Dictionary of Occupational Titles is a useful general reference source as to the duties that are undertaken in the construction trades, but its many hundreds of classifications for the construction industry do not align well with the smaller number of categories in the Master Job Classification list.[27]

 

28.           Whenever she is uncertain as to how to classify a particular task in the construction industry, it is Ms. Wilder’s practice to seek clarification from DOLI officials as to the proper job classification.[28] 

 

29.           When resolving disputes as to the proper classification of workers in the construction trades, DOLI officials attempt to make determinations based upon the duties of the workers.[29]

 

30.           The informal determinations rendered by DOLI officials on classification issues are enforced by MnDOT-OCIC.[30]

 

31.           While DOLI asserts that there are no “specific position descriptions for workers performing on state funded projects” in Minnesota statute or rule, in practice, labor investigators in both MnDOT-OCIC and DOLI fill gaps in the regulations by applying the terms of other, earlier informal determinations.  Labor investigators in DOLI and MnDOT-OCIC save paper copies of informal job classification determinations made by DOLI and apply the terms of these earlier determinations to current contracts.[31]

 

32.           As Ms. Wilder described in an October 12, 2005 electronic mail message to Erik Oelcker, Senior Labor Investigator for DOLI:

 

I based my decisions or assignments on your previous responses to our requests.  Each time you send a response, I add what you decided to a running document of classification descriptions since we have nothing formal.  It is the only way we can keep track of what tasks are applied to each task.[32]

 

33.           Further, while labor investigators are scrupulous in characterizing their use of prior determinations as “reference materials” only, the manner in which these materials are used makes clear that that earlier determinations are applied as if they were formal rules.  The privately-maintained collections of earlier agency statements are given general applicability and future effect so as to make specific the law that is enforced by DOLI.[33]

 

34.           The Labor Compliance Unit of MnDOT-OCIC undertakes approximately 300 labor investigations each year – from minor compliance actions to larger scale investigations.[34] 

 

35.           Labor investigator caseloads, on average, include approximately 50 active investigations at any one time.[35] 

 

36.           Charles Groshens, Senior Labor Investigator at MnDOT-OCIC, testified that approximately ninety-five percent of the enforcement problems arise out of the lack of clear definitions of the classification standards.  Most cases within the Labor Compliance Unit settle without litigation.[36]

 

37.           Ms. Wilder was hired in 1998 to do labor compliance for the building section of MnDOT-OCIC.[37]

 

38.           Ms. Wilder has a limited knowledge of construction practice.  While she has undertaken coursework on soil testing and road finishing practice, she has not undertaken any coursework in construction building practice or worked as part of a construction team on a building project.[38]

 

39.           Ms. Wilder testified that with her case load of building contracts to review, she is not able to review contractor submitted payrolls as quickly as she would like.  It is not uncommon for there to be long delays in her completion of reviews of contractor performance.[39]

 

CONTRACT PERFORMANCE:

 

40.           Comstock began construction on the project on or about September 5, 2000.[40]

 

41.           The Statement of Work under the contract was structured so that MnDOT employees at the Regional Headquarters site could undertake their regular work duties while Comstock was undertaking demolition, site preparation or renovation work on other portions of the site.[41] 

 

42.           Phase I of contract performance was complete in May of 2001.  Phase II of contract performance was complete in February of 2002.[42]

 

43.           The project was substantially complete in May of 2002.  The final phase of contract performance, Phase III, was complete in July of 2002.[43]

 

44.           MnDOT-OCIC did not adduce evidence that any of the work performed under the contract fell below either the standards for quality set forth in the contract or the agency’s subjective expectations of acceptable workmanship.  Indeed, to the contrary, agency officials expressed the view that Comstock did work of “very good quality” on the regional headquarters project.[44]

 

45.           Employees of Comstock were obliged to complete daily time cards reflecting the work performed at the job site.  Employees were directed to list:

 

(a)            The employee’s name, the date and day of the week on which work was performed;

 

(b)            the Job Number – in this instance, denominated by Comstock project “2415”;

 

(c)            the name of the project;

 

(d)            the basic category of the work that was performed, from among a series of “category codes” listed by Comstock on the time card;

 

(e)            the type of work performed by the employee;

 

(f)              the start and end times of particular tasks; and

 

(g)            the number of hours worked.[45]

 

46.           At the end of each work day, employees completed the time card entries and deposited the completed forms in a specially-designated box in the employee’s break room.[46] 

 

47.           On a weekly basis, Kevin Koppang, Comstock’s Project Manager on the Detroit Lakes project, reviewed the employee time cards and assigned what he believed to be the appropriate three-digit prevailing wage classification code to the work that was performed.  Employees were then paid the corresponding prevailing wage for the work that was completed.  In support of its tabulations, Comstock submitted a weekly certified payroll report to MnDOT-OCIC.[47] 

 

48.           Additionally, Koppang drew out data from the job category designations on the time card – sometimes adjusting the listed designation to reflect the proper coding – for input into Comstock’s bid estimation system.  Comstock uses a comparison of the hours that it earlier projected for each category of work, with its actual later experience on the job, to refine and improve its bidding estimation system.[48]

 

49.           MnDOT-OCIC reviewed payroll materials of building contractors and subcontractors working under the contract so as to assure itself that required wages, benefits and tax payments were promptly made.[49] 

 

50.           As part of her duties, Ms. Wilder was on-site at the Detroit Lakes Regional Headquarters twice following award of the contract to Comstock.  Ms. Wilder attended the first Construction Meeting for the project, on September 26, 2000, and returned in April of 2001 while contract performance was underway.[50] 

 

51.           On September 27, 2001, Ms. Wilder sent Comstock a letter stating that Comstock was in compliance with contract labor provisions during the first 46 weeks of contract performance.[51] 

 

52.           Mr. Groshens of MnDOT-OCIC concedes that it was reasonable for Comstock to infer from the September 27, 2001 letter that Comstock was in compliance with the labor standards of Contract Number 425783.[52] 

 

53.           At the time of its receipt of the September 27, 2001 letter, a significant amount of work under the contract had been completed.[53]

 

54.           Based upon the September 27, 2001 letter, Comstock officials continued to classify and pay its employees as it had from the beginning of contract performance.[54]

 

55.           Pursuant to a set of instructions from Ms. Wilder, in the autumn of 2001, wage payments to subcontractor employees under the contract were routed to MnDOT-OCIC instead of being remitted directly to the employees.  By early 2002, a collection of these payments was in still the possession of MnDOT-OCIC – placed in a drawer by Ms. Wilder and forgotten for several months.[55]

 

56.           A Contract Administrator, Jodi Alfson, wrote and telephoned Ms. Wilder about the release of the checks, but received no reply.[56]

 

57.           On February 15, 2002, Kevin Koppang of Comstock made inquires about the delayed release of subcontractor wage checks.  In a tone of genuine urgency, Koppang wrote:

 

This needs to get resolved immediately….  Our subcontractors Blahna and McArthur are threatening that they won’t return to the jobsite to continue with their work until the issue with these checks [is] resolved.  This would obviously hold up progress if this would happen…. Your immediate attention to this matter would be greatly appreciated as this issue has been on the table for an extraordinary amount of time.[57]

 

58.           In reply, on February 19, 2002, Ms. Wilder apologized for the three-month delay in remitting the sums owed to the subcontractor employees.  In this same correspondence, Wilder states that there are deficiencies with Comstock’s payment practices.  Wilder writes:

 

I also need to let you know that I have a problem with the information received from Comstock – some of the time cards identify work performed that is inappropriately classified and inappropriately paid – some are correctly classified and incorrectly paid – please begin review of your time cards against your payment records so that we can address and correct these issues soon ….

 

Ms. Wilder’s reply does not detail which employees’ work was correctly classified nor does it identify which employees’ work was incorrectly classified.[58]

 

59.           MnDOT-OCIC’s claim that Comstock employees had been inappropriately classified and paid is made for the first time four days after Mr. Koppang demanded that MnDOT-OCIC release the paychecks due to the subcontractor employees.[59] 

 

THE EXCHANGE OF INFORMATION BETWEEN THE PARTIES REGARDING PROPER CLASSIFICATION PRACTICE:

 

60.           MnDOT-OCIC officials concede that they have a duty to detail any non-compliance if the agency claims that a contractor has not met the requirements of the prevailing wage law.[60] 

 

61.           Ms. Wilder’s electronic mail message of February 19, 2002 does not detail what contract work was underpaid.[61] 

 

62.           Ms. Wilder testified that she sent a letter describing the shortcomings in Comstock’s allocation of assignments among job classifications in July of 2002.  Comstock officials disclaim ever having received such a letter.[62]

 

63.           Ms. Wilder claims that the partially-complete, unsigned, non-letterhead version of a letter dated July 11, 2002 (included in the hearing record as Exhibit 707), was sent to Comstock officials.  This item directs Comstock to remedy “all violations indicated,” but, unlike the descriptions regarding Comstock’s subcontractors, does not list any violations relating to Comstock.  Wilder explains that she orally detailed those shortcomings to Contract Administrator Joni Alfson.  Ms. Wilder’s testimony on this point is simply not credible.[63] 

 

64.           The better and internally-consistent explanation is that the letter dated July 11, 2002, was a draft that was neither completed nor sent by Ms. Wilder to Comstock in the summer of 2002.  Viewing this exhibit to be an uncompleted draft, explains why there is missing detail as to the nature of the claimed labor standards violations by Comstock; why (unlike other contemporaneous documents from MnDOT-OCIC) there is no signed, letterhead version of this item in the hearing record; why, despite the claim that a carbon copy of this letter was circulated to ten different government officials, MnDOT-OCIC only has a draft version of the letter in its possession; and why Comstock officials never received this letter in 2002.[64]  

 

65.           On a number of occasions in 2002 and 2003, Comstock staff asked Ms. Wilder to identify the specific claimed prevailing wage law violations – namely, which tasks had been improperly classified by the firm.[65] 

 

66.           In a letter dated October 13, 2003, Ms. Wilder directed Comstock to either: (a) submit all of its cancelled employee paychecks, check ledgers and employee timekeeping records for each employee to MnDOT-OCIC; or (b) “conduct a self audit” and submit the results for Ms. Wilder’s review.[66]

 

67.           Between the two alternatives, Comstock chose to conduct a self-audit.  During this process, Comstock officials reviewed employee time cards, daily reports and payroll reports for all of the employees who worked on the Detroit Lakes Project.[67]

 

68.           While conducting the self-audit, Comstock asked Ms. Wilder for a list of claimed violations along with a list of governing labor classifications.  Comstock sought to use the official materials in completing its review.[68]

 

69.           On November 13, 2003, Ms. Wilder responded to Comstock’s request by stating that she would fax to Comstock a compilation of classification determinations received by MnDOT-OCIC from DOLI.  Ms. Wilder cautioned, however, that the determinations that she was transmitting were not found in either a statute or a rule, and should only be used “for reference” by Comstock.[69]

 

70.           In a facsimile transmission of the same day, Ms. Wilder forwarded to Comstock an informal compilation of job classification determinations that had been rendered by Erik Oelker, Senior Labor Investigator of DOLI, in the past.  The compilation bore the following legend at the bottom of each page:

 

NOTE:  This document is to be used for reference only.  Information included is a compilation of many but not all of the determinations made by the Department of Labor and Industry (DOLI) in response to specific questions of work classification requirements for specific projects.  Not all definitions of work classifications are included.  Questions regarding tasks not included in this document should be presented in writing to the Department of Transportation for determination by DOLI.[70]

 

71.           As instructed, Comstock requested guidance in interpreting the distinctions between major classifications in four problem areas under the contract:  (1) the distinction between “common laborers” and “skilled laborers”; (2) the distinction between laborers and skilled tradesmen; (3) the scope of duties of an “ironworker;” and (4) the scope of duties of a “carpenter.”[71]

 

72.           The complete reply of Mr. Oelker of DOLI on these questions was as follows:

 

Per your correspondence of December 1, 2003, Minnesota Rules and Statutes do not provide for specific position descriptions for workers performing on state funded projects.  The class of labor indicated in the Major Job Classifications is based on common usage in the industry, scope of work in union contracts, apprenticeship standards, and the U.S. Department of Labor Dictionary of Occupational Titles, as provided in Minnesota Rules which have the force and effect law.

 

The classification of labor and prevailing wages are enforced by the contract agency that owns the project on a case by case basis.  Federal projects where the federal wage rates are included have no effect [on] the Minnesota law or rules, so the rates and classes of labor may be different of more specific.  The code 102 Skilled Laborer rate applies to those laborers assisting a Skilled Craft Journeyman (Bricklayer Tenders, Carpenter Tenders, etc.)

 

If a contractor wishes to contest the determination of a contract agency in regard to compliance, the contractor should go through the legal process provided through the agency.[72]

 

73.           At the evidentiary hearing, Rosyln Wade, the Director of the Labor Standards Unit of DOLI, acknowledged that Mr. Oelker’s December 1, 2003 response letter to Comstock “doesn’t reply directly to the contractor’s concerns.”[73] 

 

74.           On February 13, 2004, officials of MnDOT-OCIC met with representatives of Comstock at Comstock’s Wahepton, North Dakota, headquarters in an effort to resolve the disputes.[74]

 

75.           So as to avoid the expense of copying and transmitting to MnDOT-OCIC all payroll records relating to the project, in June of 2004, Comstock completed a “self-audit” of its classification practice; and forwarded the audit results to Ms. Wilder.  When this report could not be located at the agency, a follow-on packet was again sent to MnDOT-OCIC in November of 2004.[75]

 

76.           By way of a letter dated December 16, 2004, Ms. Wilder wrote Comstock stating:

 

I am disappointed that Comstock did not submit more detailed documentation for more payroll periods than what I received….

 

I must ask that the timekeeping records written by the employees for all project periods until the end of June 2001.  If I find that the included work descriptions match the tasks performed by the classifications included on the payroll reports, I will not ask for further documentation.  If not, I will have to ask for all periods.[76]

 

77.           Believing that the time and expense Comstock had invested to complete a “self-audit” of the payroll records was a fool’s errand, particularly as Ms. Wilder had demanded large stores of documents, with the further prospect that all payroll records would be sought, Kevin Koppang wrote the Facility Program Director of MnDOT-OCIC, Richard L. Post.  Koppang objected to Ms. Wilder’s demand that additional records be copied and forwarded to her.[77]

 

78.           By way of a January 19, 2005 electronic mail message to Mr. Koppang, Director Post was conciliatory.  He acknowledges that “the system is complicated at best and takes an inordinate amount of time to complete these investigations,” but explains that he is “required to have clearance from our Labor Compliance Investigator before I can release any remaining funds” under the contract.  In an effort to ease the tensions between the parties, he proposes that Ms. Wilder again travel to Comstock’s Wahepton, North Dakota headquarters to review payroll records and pledges that he will “ensure we keep on this to get done.”[78]

 

79.           At the evidentiary hearing, Ronald Lagerquist, MnDOT-OCIC’s architect on the project, conceded that it was inappropriate for the agency to demand copies of employee time cards nearly two years after the completion of the project work.[79] 

 

80.           On February 16, 2005, Ms. Wilder was given complete and unfettered access to the payroll-related records relating to the contract.[80]

 

81.           On June 21, 2005, Ms. Wilder provided Comstock with formal determination of the amount of back wages owed.  The determination stated that, as a result of a series of prevailing wage violations, Comstock owed $113,138.88 in additional wages.[81]

 

82.           Through the remainder of 2005 and through much of 2006, Comstock sought to have MnDOT reconsider its determination that back wages were owed.  Its attorneys wrote letters to various agency officials; from Ms. Wilder up to then-Commissioner of Transportation, Carol Molnau.[82]

 

83.           Having received a copy of the letter that Comstock wrote to Commissioner Molnau, indicating that Comstock may pursue resolution of its claims through litigation, Ms. Wilder sent an electronic mail message to Erik Oelcker of DOLI.  Ms. Wilder wrote requesting a written statement in which Oelcker would assert that he agreed with MnDOT-OCIC’s classification of tasks according to the “Classification Identification List.”  Ms. Wilder had obtained the “Classification Identification List” in an earlier meeting with Oelcker.  Wilder requested this documentation “for the file.”[83]  

 

84.           On April 3, 2006, Ms. Wilder issued a determination as to the amount of back wages owed by Comstock.  In this determination, MnDOT-OCIC asserted that Comstock owed $109,561 in additional wages for prevailing wage violations.[84]

 

85.           On August 10, 2006, Ms. Wilder issued another determination as to the amount of back wages owed by Comstock.  In this determination, MnDOT-OCIC asserted that Comstock owed $111,428.11 in additional wages for prevailing wage violations.[85]

 

86.           At the evidentiary hearing, a former aide to Ms. Wilder, Susan Rousseau, testified that Ms. Wilder sent the August 10, 2006 determination to Comstock knowing that there were tabulation errors and inaccuracies in the spreadsheet which buttressed MnDOT-OCIC’s demand for back wages.[86]

 

87.           There is no evidence in the record rebutting Ms. Rousseau’s testimony.[87]

 

88.           On September 22, 2006, MnDOT Programs Facilities Director Richard L. Post issued an “Order Letter” demanding that Comstock pay back wages in the amount of $111,428.41, or, within 20 days of receipt of the letter submit a written request for an administrative hearing.[88]

 

89.           On October 10, 2006, Comstock requested a contested case hearing as to these claims.[89] 

 

90.           Before and after the commencement of the contested case proceedings in this matter, MnDOT-OCIC had a number of determinations of the amount of back wages owed.  The demands are as follows:

 

Date of Demand

Amount of the Demand

Exhibit

June 21, 2005

$113,136.88

745

April 3, 2006

$109,561.18

756

August 10, 2006

$111,428.41

760

June 20, 2007

$114,065.47

763

October 23, 2007

$104,749.12

764

June 11, 2009

$98,772.38

Transcript at 630[90]

 

91.           MnDOT-OCIC has held $27,074.86 earned by Comstock under the contract pending a final “close out” of the project.[91] 

 

MnDOT-OCIC’S CLASSIFICATIONS OF CONTRACT WORK:

 

92.           MnDOT-OCIC’s claim for back wages follows from a series of inferences made by agency officials from Comstock time cards and payroll records.[92]

 

93.           If, for example, a Comstock employee listed “rebar” in the space on the time card provided for “Type of Work,” MnDOT-OCIC reasoned that because the rebar is made of steel, and ironworkers work with steel, the work listed for that day was properly characterized as “iron work.”[93]   

 

94.           It is not clear from the time card entry “rebar” whether the employee was unloading rebar, clearing away rebar from the construction site or fastening rebar to a permanent structure – facts that otherwise would be determinative of a proper classification of the employee’s duties.  Further, it is not uncommon in the construction industry for a worker to inaccurately characterize the work that he or she performed when later describing the day’s duties on a time card.[94] 

 

95.           Over time, Ms. Wilder used four different versions of the Classification Identification List authored by Mr. Oelcker to assign the work of Comstock employees among the various job classifications in the contract.[95] 

 

96.           The “4th version of the task assignment list” was developed in December of 2007 after MnDOT-OCIC officials met with representatives of Comstock.[96]

 

97.           The Classification Identification Lists MnDOT-OCIC used to assign Comstock employees to job classifications were issued, revised and reformatted by state officials without rulemaking.[97]

 

98.           Ms. Wilder’s assignment of tasks to particular classifications was not done contemporaneously with, or proximately in time to, performance of the contract work.[98]

 

99.           Ms. Wilder did not verify the accuracy of the descriptions made by Comstock employees on their time cards.[99]

 

100.       During the process of assigning Comstock employees to particular job classifications, Ms. Wilder did not know the skill level or construction-related experience of any of the employees that she assigned to job classifications.[100]

 

101.       When assigning workers to particular job classifications, Ms. Wilder was not clear as to the level of effort that was required to complete the work that she attributed to particular employees.[101] 

 

102.       Ms. Wilder assumed, without knowing, that the workers that she assigned to skilled crafts had the skills to complete the work that was attributed to them.[102] 

 

103.       Messrs. Bertek, Blazek, J. Davids, T. Davids, Eddington, Hanson, Heitmann, Hendrickson, Lehmann, Miller, Muehlberg, Owens, Rozic, Sauve, Siemieniewski and Van Winkle did not have the construction skills, knowledge or experience to complete the skilled craft work that MnDOT-OCIC attributes to them.[103]

 

104.       Tradesmen who are knowledgeable of practices in the construction industry expressed doubt that anyone could, after contract performance was complete, accurately assign workers to particular job classifications based upon the descriptions that were made in employee time cards.[104] 

 

105.       Beyond the minimal descriptions of the work on the employee time cards and daily reports, MnDOT-OCIC does not have any evidence of the work that was performed by particular employees. MnDOT-OCIC did not introduce any contemporaneously-produced evidence – such as photographs, survey information or affidavits from employees or other persons on the construction site – which describes what was work was undertaken by Comstock employees on particular days.[105]

 

106.       The record does not include testimony from any employee who worked on the project suggesting that his work was misclassified.

 

107.       There was no testimony from any other person who observed the performance of the contract work detailing how the duties of Comstock employees were misclassified.

 

108.       Neither the Labor Compliance Unit, nor Ms. Wilder, had sufficient knowledge of what work had been performed by Comstock employees, on particular days, so as to accurately assign work to particular job classifications.[106]

 

109.       Ms. Wilder concedes that it was difficult for her to classify work that had occurred at the Detroit Lakes site 9 years earlier.[107] 

 

110.       In Greater Minnesota, laborers frequently handle materials used by tradesmen in skilled crafts – including handling, delivering, laying and tying rebar.[108]

 

111.       While the task of tying rebar is claimed by trade unions representing ironworkers, as Mr. Koppang demonstrated at the evidentiary hearing, aiming the braces of a “rebar gun” at the point of intersection between two steel rods which have been placed at right angles to each other, and pulling the trigger on the rebar gun, does not require the special skills of an ironworker to accomplish.[109] 

 

112.       During the evidentiary hearing, Ms. Wilder could neither identify nor describe the proper use of a rebar gun.[110]  

 

113.       Director Wade acknowledges that Comstock has a legitimate complaint if MnDOT-OCIC classified the very same construction tasks inconsistently during contract performance.[111]   

 

114.       MnDOT-OCIC classified the description of work with “footings” inconsistently – assigning similarly denominated work to the classification for laborer, carpenter and ironworker.[112]

 

115.       MnDOT-OCIC classified the description of work with “metal panels” inconsistently – assigning similarly denominated work to the classification for sheet metal worker, carpenter and ironworker.[113] 

 

116.       MnDOT-OCIC classified the description of work with “metal decking” inconsistently – assigning similarly denominated work, performed on or around the same days, by the same personnel, as carpentry, sheet metal work and iron work.[114]  

 

117.       MnDOT-OCIC’s classification of the installation of “metal decking” as sheet metal work results in a lower classification and wage rate than Comstock’s classification of this task as iron work.[115]

 

118.       MnDOT-OCIC classified the description of work with “temporary shelters” inconsistently – assigning similarly denominated work to the classification for laborer and sheet metal worker.[116]  

 

119.       MnDOT-OCIC classified the description of work of “reinforcing walls” inconsistently – assigning similarly denominated work, performed on or around the same days, as cement masonry and iron work.[117]

 

120.       MnDOT-OCIC classified the “repair of a door, because the cement mason screwed up” as Cement Masonry.[118] 

 

121.       MnDOT-OCIC did not use a consistent practice of apportioning the work when an employee placed more than one descriptor on his time card.[119]

 

122.       MnDOT-OCIC attributed work on non-prevailing wage projects as if it were contract related work that required the payment of prevailing wages.[120]

 

DOLI’s PARALLEL RULEMAKING PROCESS:

 

123.       In the late 1990’s, agency officials were aware of the need for, and benefits of, additional detail defining the Major Job Classifications.[121] 

 

124.       The lack of definitions within the Major Job Classifications is problematic for contractors that wish to comply with the law.  The scope and limits of the Major Job Classifications cannot be ascertained by knowledgeable tradesmen, even after a diligent inquiry of government officials.[122]

 

125.       At the evidentiary hearing, for example, Director Wade described the meaning of Major Job Classification 102 – “Laborer, skilled (assisting skilled craft journeyman)” in this way:  “Someone who has more skills than a laborer and lesser skills than a skilled journeyman.”  What level of additional skills over that of common laborers is required before this separate and higher classification is applicable, is not clear from either Minn. R. 5200.1100 or this record.[123]

 

126.       In October of 1999, a panel of the Minnesota Court of Appeals “encourage[d] formal rulemaking by the Minnesota Department of Labor and Industry or other appropriate agency,” so as to define terms within Minnesota’s prevailing wage law.  Urging the development of formal rules, the panel wrote: “This court is not unmindful of the problems that case-by-case enforcement of the prevailing-wage law creates for contractors who want to bid on state highway projects.”[124]

 

127.       In June of 2004, a second panel of the Minnesota Court of Appeals likewise urged DOLI to undertake rulemaking to define job classifications, so that agency might “observe the basics of procedural due process in making classification decisions.”  As the appellate panel observed in AAA Striping Service Co. v. Minnesota Dep’t of Transportation:

 

To determine whether and to whom DOLI is accountable for decisions not to follow through with rulemaking, we note the importance of classification and the context in which such decisions are made. Workers, labor unions, contractors, subcontractors (including AAA), and perhaps even local units of government, have a substantial interest in the classification process. Fair wages, workers' livelihoods, the financial feasibility of projects and entrepreneurial opportunities for contractors may be affected by these decisions.  The statutes mandate investigation and hearings necessary to define worker classifications.  This is strong legislative directive to observe the basics of procedural due process in making classification decisions.  We conclude that at a minimum, DOLI should engage in rulemaking as specified in its own regulation, or, in the alternative, make available a reconsideration process with a contested case proceeding when requested by an aggrieved party.[125]

 

128.       In February of 2007, the Office of the Legislative Auditor issued a program evaluation of the prevailing wage system in Minnesota.  The Legislative Auditor concluded in part:

 

The source of the problem is that the rules promulgated by the Department of Labor and Industry do not define the job responsibilities of the various job classes for either commercial or highway/heavy construction. In particular, there is no definition of the responsibilities of common or skilled laborers in comparison to those of skilled tradesmen….

 

RECOMMENDATION

 

The Department of Labor and Industry should promulgate rules that define the job responsibilities of workers in the various construction job classes listed in the department’s rules.[126]

 

129.       Notwithstanding DOLI’s awareness of the difficulties caused by the lack of definitions in the Major Job Classifications, two decisions of the Court of Appeals urging the agency to undertake rulemaking, a Legislative Auditor report similarly recommending that rulemaking be undertaken to define the scope of the Major Job Classifications, the effort to provide additional detail did not start in earnest until May of 2008.  Director Wade noted that the political sensitivity of the topic of the Major Job Classifications, the costs to DOLI associated with developing definitions through rulemaking, the scale of the work that would be required to define the missing terms and the lack of direction from senior agency officials all contributed to the long periods of delay in defining the scope of the Major Job Classifications.[127] 

 

130.       In May of 2008, however, an unflattering exposé of the prevailing wage system appeared on the Twin Cities NBC-affiliate KARE-11.  The television report was critical of the lack of definition within prevailing wage classifications.  Following the broadcast of the KARE-11 investigative report, Commissioner of Labor and Industry Steve Sviggum directed officials in the Labor Standards Unit to develop the missing definitions.[128] 

 

131.       Director Wade in turn assigned each labor investigator within DOLI’s Labor Standards Unit a set of job titles in the Major Classification List, with the instruction to begin drafting the missing definitions.  Ms. Wade estimates that this drafting effort required at least 240 work hours.[129] 

 

132.       Four weeks after airing of the KARE-11 broadcast, DOLI likewise resuscitated a rulemaking proceeding that it had started 9 ½ years earlier, but left dormant, relating to revisions of the Major Job Classification system.[130]

 

133.       On May 29, 2008, DOLI requested a rulemaking hearing on a set of partial revisions to the Major Job Classifications and the approval of the Additional Notice Plan for these proposed rules.  As the Administrative Law Judge summarized this rulemaking proceeding:

The Department has proposed amendments clarifying when the Commissioner must determine whether work performed by a class of labor not named in the master job classifications is included in an existing class, adding a general class of labor, and clarifying the minimum number of hours of work required for a worker to be included in the wage survey process.  The proposed amendments also create separate classifications for certain highway-heavy and commercial construction duties; create new classifications or amend existing classifications relating to landscaping and seeding, and painting and striping of roads; and create new classifications or amend classifications relating to warning lights, warning signs, and other traffic control devices.  The proposed rule amendments also create new classifications or amend existing classifications for survey workers, quality testers, articulated haulers, and off-road trucks.[131]

 

134.       A broader and more detailed set of revisions to the Master Job Classifications is still the subject of discussion and deliberations among a DOLI Working Group on the Prevailing Wage Rules.[132]

 

135.       Government officials concede that definitions to the Master Job Classifications would be helpful so as to advise bidders and awardees which wage and fringe benefit rates apply to which tasks.[133] 

 

136.       In the autumn of 2008, Dick Anfang, President of the Minnesota State Building and Construction Trades Council convened a group of representatives from the various construction trades to revise the classification descriptions drafted by DOLI.  By way of a letter dated November 24, 2008, Mr. Anfang forwarded a draft set of classification descriptions that “represent the consensus of the Building Trades unions.”  As Mr. Anfang explained: “Consensus over an issue like trade definitions is not easy to reach.”[134]

 

137.       Notwithstanding the consensus that has been achieved amongst the various trade unions, not all union leaders agree that the accords described in the consensus document reflect the proper demarcations between various skilled trades.[135] 

 

138.       Moreover, even as to the Trades Council draft, there still remain some areas of overlap between the various skill trades.[136]

 

CONTESTED CASE PROCEEDINGS:

 

139.       The Notice and Order for Hearing in this matter was issued by MnDOT-OCIC on December 4, 2006.[137]

 

140.       On January 30, 2007, Comstock requested MnDOT-OCIC identify and disclose all of the witnesses and potential exhibits that may be introduced at hearing.[138] 

 

141.       On February 6, 2007, MnDOT-OCIC partially responded to the request, assuring Comstock that it would update its disclosures consistent with any scheduling orders from the OAH.[139]

 

142.       On August 16, 2007, MnDOT-OCIC served its Expert Witness List pursuant to the then-current scheduling order, identifying sixteen potential expert witnesses.  Comstock objected to this number of expert witnesses as unreasonable and requested a prehearing conference to discuss the issue.[140]

 

143.       On August 27, 2007, counsel participated in a teleconference with the Administrative Law Judge.  As a result of the teleconference, the Administrative Law Judge issued a Third Prehearing Order permitting MnDOT-OCIC to introduce the testimony of its “expert” tradesmen, provided that affidavits from the witnesses were submitted by Monday, September 24, 2007.  The Administrative Law Judge also ordered both parties to exchange statements from any non-tradesman expert witnesses, including a summary of the facts and opinions of their expected testimony by September 17, 2007.  Comstock was ordered to serve its expert tradesman affidavits by Monday, October 15, 2007 and the period for discovery was extended another fourteen days until Monday, October 29, 2007.[141]

 

144.       On September 17, 2007, MnDOT-OCIC served Comstock with its Expert Witness Statement, disclosing expected testimony from John R. Natwick and Doug Holmberg. Holmberg’s report, however, was not complete and he noted that his opinions were “preliminary.”  Indeed, it appeared that Mr. Holmberg was expecting additional information from MnDOT-OCIC before finalizing his opinion.[142]

 

145.       By way of papers filed on September 21, 2007, Comstock sought summary disposition on MnDOT-OCIC’s claims for additional wages.  Comstock argued that MnDOT-OCIC’s claims were based upon:  (1) rights to recovery that are barred by the doctrine of laches; (2) arbitrary and capricious government actions; (3) unauthorized rulemaking by MnDOT-OCIC or the Minnesota Department of Labor and Industry and (4) unconstitutionally vague rules.[143]

 

146.       On September 24, 2007, Comstock received affidavits for seven of MnDOT-OCIC’s expert tradesman.  MnDOT-OCIC informed Comstock that “[t]he State has requested, but not yet received” affidavits from the following individuals: Harold Gordon, Jerome Johnson, Lee Steinbecker and Steve Raatikkla.[144]

 

147.       On Tuesday, September 25, 2007, Comstock received affidavits from Messrs. Raatikka and Johnson.   Thereafter, on Thursday, September 27, Comstock received an expert tradesman affidavit for Harold Gordon from MnDOT-OCIC.  MnDOT-OCIC failed to submit an affidavit for Mr. Steinbecker.  Accordingly, on September 26, 2007, Comstock filed and served a letter in which it moved for an Order barring MnDOT-OCIC from introducing testimony from Gordon, Johnson, Steinbecker and Raatikkla.[145]

 

148.       Pursuant to the stipulation of the parties, in lieu of proceeding to the earlier-scheduled evidentiary hearing, oral argument was heard upon Comstock’s Motion for Summary Disposition on January 10, 2008.[146]

 

149.       On February 7, 2008, the Administrative Law Judge recommended that the Commissioner of Transportation grant-in-part and deny-in-part Comstock’s Motion for Summary Disposition.[147]

 

150.       Thereafter, the parties filed written exceptions to the Administrative Law Judge recommendations and an oral argument was held before Deputy Commissioner Khani Sahebjam of the Minnesota Department of Transportation.[148]

 

151.       On October 10, 2008, Deputy Commissioner Sahebjam rejected the February 7, 2008 recommendations and remanded this matter to OAH for additional proceedings.  The remand order included the directive to develop the hearing record “on the following issues”:

 

(1)  Does MN/DOT have legal authority to enforce the prevailing wage requirements for the Detroit Lakes Regional Headquarters, Construction Project Number OOTZ1791B;

 

(2)  Based upon consideration of all the evidence in the record and the testimony of experts and other witnesses, what tasks do the disputed Master Job Classifications encompass and how should the workers who performed the tasks of installing waterproofing, providing tools to Cement Masons, helping painters, typing rebar, erecting chain link fences and installing Venetian blinds be classified; and,

 

(3)  Based on the classifications determined, how much if any, in back wages does Comstock owe its employees?[149]

 

152.       Comstock sought review of the October 10, 2008 decision, by way of a certiorari appeal to the Minnesota Court of Appeals.  The Court of Appeals discharged the writ of certiorari, and dismissed the appeal as untimely filed, on December 2, 2008.[150]

 

153.       A prehearing scheduling conference in this matter was held on December 18, 2008, and DOLI was represented at this conference by its attorney, William Bierman, Esq.  As detailed in the Fourth Pre-Hearing Order, Mr. Bierman later petitioned for his agency’s intervention in this matter and received the service of filings from other parties.[151]

 

154.       DOLI’s motion for intervention was granted on February 25, 2009.[152]

 

155.       On March 10, 2009, the parties entered into a Stipulation providing a schedule for the disclosure and exchange of materials in advance of a rescheduled evidentiary hearing.  In part, the Stipulation declared:

 

The Department of Transportation and Comstock have already exchanged statements identifying any person whom they intend to call as an expert witness as well as statements summarizing the facts and opinion of that testimony.

 

This Stipulation was adopted the Administrative Law Judge on March 19, 2009.[153]

 

156.       Under the terms of the stipulated scheduling order, the period for discovery closed on Friday, May 8, 2009.[154]

 

157.       During a status conference on May 20, 2009, MnDOT-OCIC sought clarification of the respective burdens of proof during the upcoming evidentiary hearing.  The Administrative Law Judge expressed the view that because MnDOT-OCIC asserts that Comstock broke the law, and owes its employees back wages, MnDOT-OCIC bore the burden of establishing the right to recover these sums.[155] 

 

158.       On May 20, 2009, MnDOT-OCIC served Comstock with a near-complete set of its proposed exhibits and a listing of its witnesses.  MnDOT-OCIC filed and served a copy of its proposed Exhibit 200-A out of time on Tuesday, May 26, 2009.[156]

 

159.       At a May 26, 2009 Pre-Hearing Conference, MnDOT-OCIC’s counsel represented that the author of its Exhibit 8 – Doug Holmberg – was working for a copper mining company in the Democratic Republic of the Congo.  Further, counsel maintained that Mr. Holmberg has not been within reach of a subpoena during the period following the Court of Appeals’ dismissal of the writ of certiorari in December of 2008, through the close of discovery in this matter on May 8, 2009.  Specifically, Counsel for MnDOT-OCIC made the following representations at the Pre-Hearing Conference.

 

“The expert in the Congo is still in the Congo and won’t be back into the United States until July.”

 

“He has been out of the country for over a year and I had extreme difficulty in getting him and even more difficulty in getting him to respond.”

 

“[Mr. Holmberg has been out of the country] all of 2009 and part of 2008.”[157]

 

MnDOT-OCIC requested that Mr. Holmberg testify at the hearing by telephone.

 

160.       In a Seventh Pre-Hearing Order, dated June 3, 2009, the Administrative Law Judge granted-in-part Comstock’s Motion in Limine.  The Order excluded the expert testimony of Doug Holmberg on the grounds that Comstock had not been afforded a fair opportunity to examine him prior to the evidentiary hearing.[158]

 

161.       On the first day of the evidentiary hearing, counsel for MnDOT-OCIC sought to introduce elements of Mr. Holmberg’s expert report, notwithstanding the fact that Mr. Holmberg was not called as a witness or present at the evidentiary hearing.  The Administrative Law Judge sustained Comstock’s objection to the receipt of such evidence.  Unable to establish a proper foundation for the introduction of Holmberg’s findings, in the absence of its author, Counsel for MnDOT-OCIC asserted that he would seek to present the excluded report directly to the Commissioner.[159]

 

162.       Exhibit 200 and a set of later supplements to this exhibit were developed by Ms. Wilder and MnDOT-OCIC in advance of the evidentiary hearing in this matter.[160]

 

163.       Over the objection of Comstock, the Administrative Law Judge permitted MnDOT-OCIC to offer a supplement to Exhibit 200 as an exhibit at the evidentiary hearing notwithstanding the fact that this item was first presented six days after the due date for filing hearing exhibits.  The supplement was marked for identification as Exhibit 200-A.[161]

 

164.       Exhibit 200-A contains numerous errors and, in the judgment of its principal author, Ms. Wilder, is unreliable.[162] 

 

165.       Similarly, a still later set of revisions to Exhibit 200-A, offered by MnDOT-OCIC out of time, on the fourth day of the evidentiary hearing, were not complete substitutes for 200-A.  These supplemental items, marked for identification as Exhibits 200-B and 200-C, are only partial substitutions for Exhibit 200-A.  MnDOT-OCIC proposed that these supplemental exhibits overlay part of Exhibit 200-A, notwithstanding the fact that the calculations reflected in the various pieces of the proposed combination do not match or reconcile with each other.[163] 

 

166.       If accepted into the hearing record, Exhibits 200-B and 200-C would conflict with the data recorded on the daily summaries of Exhibit 200-A; rendering the combined mixture confusing and undecipherable.[164]

 

167.       On the second day of the evidentiary hearing, Comstock offered into the hearing record transcripts of the sworn deposition testimony of Erik Oelcker.[165]

 

168.       Earlier, in January of 2009, Mr. Oelcker suffered a traumatic brain injury.  He has been directed by his physicians not to focus his mind on any matter for any length of time so as to provide an opportunity for his brain to heal.  In the judgment of his physicians, Mr. Oelcker is medically unavailable for trial.[166] 

 

169.       Counsel for MnDOT-OCIC had a full and fair opportunity to develop the evidentiary record at Mr. Oelcker’s depositions on July 10, 2007 and October 4, 2007, and a motive that was identical to that on the first day of the evidentiary hearing, but counsel chose not to do so. The Administrative Law Judge, citing Minn. R. Evid. 801(b)(1), accepted into the record a certified copy of Mr. Oelcker’s July 10, 2007 and October 4, 2007 depositions.[167]

 

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

CONCLUSIONS

 

1.               The Administrative Law Judge and the Commissioner of Transportation have jurisdiction over this matter pursuant to Minn. Stat. §§ 14.50 and 177.44, subd. 7.

 

2.               The Notice of Hearing is proper in all respects and the Department complied with all substantive and procedural requirements of law and rule.

 

3.     The Minnesota Prevailing Wage Law is a minimum wage law that applies to construction projects financed in whole or in part by state funds.  Its purpose is to ensure that those who work on such projects are paid wages comparable to wages paid for similar work in the community.[168] 

 

4.     The Minnesota Prevailing Wage law is codified at Minn. Stat. §§ 177.41 - 177.44.  The accompanying administrative rules are set forth at Minn. R. 5200.1000 - 5200.1120.  Together, the statutes and the rules govern the determination, certification, and payment of prevailing wages to laborers, workers and mechanics working on state-funded construction projects. 

 

5.     Under the Minnesota Prevailing Wage Act, DOLI establishes the labor classifications for workers and determines the prevailing wage rate for the classifications.[169] 

 

6.     Without a regulatory definition of “common laborer,” the requirement that workers performing the duties of a common laborer must be paid the wages then-prevailing in the community for that labor class, is so vague that persons of common intelligence must necessarily guess at the meaning of the Act’s obligation.

 

7.     Without a regulatory definition of “skilled laborer,” the requirement that workers performing the duties of a skilled laborer must be paid the wages then-prevailing in the community for that labor class, is so vague that persons of common intelligence must necessarily guess at the meaning of the Act’s obligation.

 

8.     Without a regulatory definition of “carpenter,” the requirement that workers performing the duties of a carpenter” must be paid the wages then-prevailing in the community for that labor class, is so vague that persons of common intelligence must necessarily guess at the meaning of the Act’s obligation.

 

9.     Without a regulatory definition of “sheet metal worker,” the requirement that workers performing the duties of a sheet metal must be paid the wages then-prevailing in the community for that labor class, is so vague that persons of common intelligence must necessarily guess at the meaning of the Act’s obligation.

 

10. Without a regulatory definition of “cement mason,” the requirement that workers performing the duties of a mason must be paid the wages then-prevailing in the community for that labor class, is so vague that persons of common intelligence must necessarily guess at the meaning of the Act’s obligation.

 

11. Without a regulatory definition of “ironworker,” the requirement that workers performing the duties of an ironworker must be paid the wages then-prevailing in the community for that labor class, is so vague that persons of common intelligence must necessarily guess at the meaning of the Act’s obligation.

 

12. The consequences – in terms of corporate reputation, profitability and opportunity for future work – can be severe if a state contractor does not abide by the Prevailing Wage Act.  These consequences may include misdemeanor criminal sanctions (including imprisonment) and a $300 fine.  Moreover, “[e]ach day that the violation continues is a separate offense.”  Lastly, the Department may preemptively reject the bids and proposals of any contractor that has a history of noncompliance with the prevailing wage laws.[170]

 

13. The agencies’ claim that contractors can, and do, obtain meaningful guidance on the proper classification of employees from the Labor Standards Unit of DOLI is not supported by this record.[171]

 

14. DOLI’s claim that it is developing regulatory definitions of each skilled craft and each class of labor on a “case-by-case basis” is not supported by the evidentiary record.[172]

 

15. The Major Job Classifications in Minn. R. 5200.1100 are so imprecisely defined that they encourage arbitrary and discriminatory enforcement.

 

16. While MnDOT has neither a policy nor a rate-setting role under the prevailing wage laws, it does have a role in enforcing these requirements.  The Commissioner of Transportation is authorized by state law to “require adherence” to the provisions of the state prevailing wage laws from its contractors.[173]

 

17. The hearing record does not detail why MnDOT-OCIC moved from its position, stated in September of 2001, that Comstock was in compliance with the labor provisions of the contract, to the view expressed five months later, in February of 2002, that Comstock “inappropriately classified and inappropriately paid” its employees. 

 

18. The record does not detail, much less establish, how any of Comstock’s classifications of employee work was in error.

 

19. Comstock’s assignment of workers among various job classifications was reasonable and in accordance with the terms of the MnDOT – Comstock contract.

 

20. The Administrative Law Judge adopts as Conclusions any Findings that are more appropriately described as Conclusions.

 

21. The Memorandum that follows explains the reasons for these Conclusions, and the Administrative Law Judge therefore incorporates that Memorandum into these Conclusions.

 

Based upon these Conclusions, the written submissions of the parties, the affidavits and other documents filed in this matter, and the argument of counsel, the Administrative Law Judge makes the following:

 

RECOMMENDATION

 

(1)            The Commissioner should DISMISS the Notice and Order for Hearing in this matter.

 

(2)            The Commissioner should direct MnDOT-OCIC to remit to Comstock the $27,074.86 in contract proceeds that has been held pending a final “close out” of Project Number OOTZ1791B.

 

Date:  September 28, 2009.

 

_Eric L. Lipman                              _

 

ERIC L. LIPMAN

Administrative Law Judge

 


NOTICE

 

This report is a recommendation, not a final decision.  The Commissioner of Transportation will make the final decision after a review of the record and may adopt, reject or modify these Findings of Fact, Conclusions, and Recommendation.  Under Minn. Stat. § 14.61, the Commissioner shall not make a final decision until this Report has been made available to the parties for at least ten days.  The parties may file exceptions to this Report and the Commissioner must consider the exceptions in making a final decision. Parties should contact Khani Sahebjam, Deputy Commissioner of Transportation, 395 John Ireland Boulevard, Mailstop 100, St. Paul, Minnesota 55155-1899, (651) 366-4800, to learn the procedure for filing exceptions or presenting argument.

 

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. In order to comply with this statute, the Commissioner must then return the record to the Administrative Law Judge within 10 working days to allow the Judge to determine the discipline to be imposed. 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.

 

Pursuant to Minn. Stat. § 14.62, subd. 1, the Commissioner is required to serve its final decision upon each party and the Administrative Law Judge by first class mail.

 


MEMORANDUM

 

I.                 Authority of MnDOT-OCIC to Seek Enforcement of the Prevailing Wage Provisions Against Comstock

 

Comstock moved for dismissal of MnDOT-OCIC’s claims for back wages on the grounds that MN-DOT lacks the authority to enforce the requirements of Minnesota prevailing wage laws, and that as a result, OAH lacks the jurisdiction to entertain a contested case on this same subject.

 

Comstock argues that MnDOT-OCIC is without the authority to press its prevailing wage claims because the Minnesota Legislature has conferred these enforcement responsibilities upon DOLI.  Comstock contends that under Minn. Stat. § 177.44, the only enforcement role MnDOT-OCIC has as to prevailing wages is as to contracts “for the construction or maintenance of a highway.”  Because the instant contract was for the construction and renovation of buildings, and not a “highway,” Comstock maintains that MnDOT-OCIC is without the authority to ensure compliance with the prevailing wage statutes.

 

MnDOT-OCIC responds that it does have the authority to ensure compliance with the prevailing wage statutes; and that it is drawn from two different sources.  MnDOT-OCIC asserts that it may ensure compliance with the prevailing wage laws because the Commissioner has the authority to erect buildings that are “incidental” to maintenance of the state highway system – and these “incidental” activities are likewise subject to the prevailing wage laws.  As MnDOT-OCIC argues, because the agency personnel who will work in the Detroit Lakes Regional Headquarters will later “maintain the highways,” the renovation contract was itself for the “construction or maintenance of a highway” under Minn. Stat. § 177.44.  Additionally, MnDOT-OCIC argues that under the terms of Section 810 of the underlying contract, it has full authority to enforce compliance with the prevailing wage laws against Comstock.  These arguments are addressed in turn below.

 

          Minn. Stat. § 177.44, subd. 1 provides:

A laborer or mechanic employed by a contractor, subcontractor, agent, or other person doing or contracting to do all or part of the work under a contract based on bids as provided in Minnesota Statutes 1971, section 161.32, to which the state is a party, for the construction or maintenance of a highway, may not be permitted or required to work longer than the prevailing hours of labor unless the laborer or mechanic is paid for all hours in excess of the prevailing hours at a rate of at least 1-1/2 times the hourly basic rate of pay of the laborer or mechanic. The laborer or mechanic must be paid at least the prevailing wage rate in the same or most similar trade or occupation in the area.[174]

 

MnDOT-OCIC and Comstock agree that the first two requirements of the statute are satisfied in this case – namely, that the underlying contract was one that was “based on bids,” and as to which “the state is a party.”  The dispute centers on whether the renovations and upgrades to MnDOT’s Detroit Lakes Regional Headquarters are fairly considered to be “for the construction and maintenance of a highway.”

 

          In the view of the Administrative Law Judge, Minn. Stat. § 177.44 cannot be read so broadly as to include the construction and renovations of facilities which merely benefit the highway system, but are themselves not part of the maintenance or construction of any particular roadway.  Read against the backdrop of applicable canons of statutory construction,[175] Minn. Stat. § 177.44 does not reach the OCIC-Comstock contract.

 

          Yet, this conclusion does not end the inquiry.  While Comstock argues that if Minn. Stat. § 177.44 does not authorize an enforcement role for MnDOT-OCIC, no such role is possible; this is not our law.  The state courts have announced that so long as the Legislature has not prohibited a state agency from pursuing a particular objective, the agency has wide latitude to negotiate for contract rights and benefits that it deems beneficial to the public interest. 

 

The case of Watson Construction Company v. City of Saint Paul is particularly instructive in this regard.  In that case, the contractor sought recovery of the building permit fees that it paid to the City of Saint Paul in connection with the construction, for the State of Minnesota, of the Centennial Office Building.  While the contractor objected to payment of the permit fees on the grounds that the City’s architects and engineers had no jurisdiction over a state project in the Capitol Complex, the Minnesota Supreme Court disagreed.  The Court reasoned that because no law prohibited oversight by the City staff on such project, and obtaining permits from the City was a matter that the state had bargained for in its building contract, providing for the purchase of local permits and inspections was not unlawful.  As Justice Murphy wrote for the Court:

 

The requirement that the contractor secure and pay for the building permit was a condition which the state could properly include in the contract as one under which the work should be done.  It does not necessarily follow that, since this condition imposed upon the contractor the requirement to comply with the ordinances of the city, the state by imposing the condition surrendered its sovereign rights and created a burden upon the public. On the contrary, we can only assume that an additional benefit would accrue to the state from subjecting the contractor to the additional inspection and supervision of the city architect.  Since there is no conflict here between the state and the municipality and the permit requirement of the contract has placed no burden upon the state, it cannot be said that the issue of state sovereignty is in any way involved.[176]

 

A similar rationale applies in this case.  Because there is no statutory prohibition on MnDOT-OCIC undertaking an enforcement role on prevailing wages under its building contracts, such a role is one as to which it could permissibly bargain for in its contract.[177]

 

          MnDOT did contract for such role in its building contract with Comstock.  Section 810 of the underlying contract, paragraphs 1.23 and 1.24, state in pertinent part:

 

The Commissioner of Transportation shall require adherence to the state prevailing wage law, as such, the Department will withhold funds sufficient to protect the Department’s interests in the implementation of these Special Provisions against the Contractor as provided for under section 1906, Standard Specifications for Construction. Minn. Stat. § 177.44, subd. 7.

 

          ….

 

1.24  LABOR AND INDUSTRY WAGE RATES

 

A.  PREAMBLE

 

1. It is in the public interest that public works projects be constructed and maintained by the best means and, highest quality of labor reasonably available and that persons working on public works be compensated according to the real value of the services they perform. Therefore, the Department of Transportation will administer this Contract according to the provisions set forth in Minn. Stat. § 177.41 - 177.44 and 6 MCAR 5200.1000 - 5200.1120.

 

B.  MINIMUM WAGE RATES

 

1.  The minimum hourly rates of wages required to be paid to the various laborers and mechanics employed by the Contractor and the subcontractors in the construction work on the contract shall be an amount equal to the sum of the basic hourly rate plus applicable fringe benefits as certified by the Minnesota Department of Labor and Industry for State Funded Construction Projections. 

 

          ….

 

5.  The Department-of Transportation shall apply classifications of labor, as listed under 6 MCAR 5200.1100 - Master Job Classifications. Under Standard Specifications for Construction 1906, the Department shall withhold such amounts as may be needed to protect the Department’s interests in consideration of charges or assessments against the Contractor, whether arising from this contract or any other contract with the Department.[178]

 

The payment of prevailing wages to laborers and mechanics of the Contractor, and the ability to enforce these requirements against Comstock, were bargained-for exchanges under the contract.

 

II.               Exclusive Jurisdiction of the District Court on any Contract Dispute

 

Alternatively, Comstock asserts that even if MnDOT-OCIC has enforceable claims against it, MnDOT-OCIC has selected the wrong forum for resolution of this dispute.  Comstock relies upon Supplementary Condition Number 4 of the contract when asserting that all such disputes must be venued in the District Court of Minnesota for Ramsey County.  Supplemental Condition Number 4 states in pertinent part:

 

The Contractor and the State may exercise those remedies in District Court as may be available to them in connection with any dispute arising out of this agreement which cannot be settled by the parties.[179]

 

The Administrative Law Judge finds the case of Florida State Board of Administration v. Law Engineering and Environmental Services, Inc., instructive.  In that case, a Florida-based pension fund, sued its Georgia-based engineer, over a dispute involving a property in Minnesota, in the U.S. District Court for the District of Minnesota.  Construing the forum-selection clause of the contract between the pension fund and the engineering firm, Judge David S. Doty wrote:

 

Generally, courts have found that use of the words “may” and “should” signify permissive clauses, while use of the words “shall,” “will” or “must” signify mandatory clauses.

 

The forum selection clause in Paragraph E contains no mandatory language and evinces no intent to make jurisdiction exclusive. It merely provides that any legal action with regard to the agreement “may be brought in the Courts of the State of Florida or in the United States District Court of Florida located in Leon County ....” The fact that the clause does not contain any mandatory or exclusive language but instead includes the permissive words “may be brought” illustrates that the clause does not require but merely permits plaintiff to file suit in Florida.[180]

 

Similarly, in this case, the authorization that the State “may exercise” available legal remedies in Minnesota District Court, is a permissive but not a mandatory provision of the contract.[181]

 

                    The question then necessarily arises: Is the selection of the Office of Administrative Hearings a proper forum for resolution of the dispute between the parties?  The Administrative Law Judge concludes that OAH is a proper forum.  The underlying contract confers upon MnDOT the contractual right to administer the contract in accordance with Minnesota’s prevailing wage laws and to withhold such funds due Comstock “as may be needed to protect the Department’s interests ….”[182]  Because MnDOT wishes to inform its exercise of contract administration powers (in what is a highly-contentious, factually-intensive dispute), use of the contested case procedures is wholly consistent with Minn. Stat. §§ 14.02  and 14.57.  Further, while this dispute could have been presented to other tribunals, between MnDOT and Comstock, the agency won the proverbial “race to the courthouse.”[183]  Having sought resort to remedies outside of the contract, first, MnDOT was permitted to select its forum.[184]


III.             Proof of Classification Error

 

          Minnesota Rule 1400.7300, subpart 5, sets out the burden of proof in contested cases before the Office of Administrative Hearings.  It reads:

 

Burden of proof.  The party proposing that certain action be taken must prove the facts at issue by a preponderance of the evidence, unless the substantive law provides a different burden or standard.  A party asserting an affirmative defense shall have the burden of proving the existence of the defense by a preponderance of the evidence.  In employee disciplinary actions, the agency or political subdivision initiating the disciplinary action shall have the burden of proof.

 

          Because MnDOT-OCIC asserts that as a result of violations of Minnesota’s prevailing wage laws Comstock owes its employees $98,772.38 in additional wages, and seeks to enforce this claim through either a setoff of withheld contract amounts, or referral of Comstock for suspension or debarment, or all three,[185] it is the party that is “proposing that certain action be taken” under Minnesota Rule 1400.7300.  Accordingly, MnDOT-OCIC has the burden of proving the facts at issue by a preponderance of the evidence.

 

          This construction of the rule is likewise consistent with the practice in earlier cases where the Department of Labor and Industry has sought to enforce the wage and hour laws,[186] and where employees have sought to recover on their own for claims under the Fair Labor Standards Act.[187]

 

          The case of In the Matter of the Truck Rental Rate Effective December 20, 2004, cited by MnDOT-OCIC, does not point to a different conclusion.  In that case, a set of private trucking firms challenged the adequacy and completeness of the Commissioner’s rate-setting methods.  Because the trucking companies asserted that the agency had acted illegally, and requested relief, those firms bore the burden to prove the facts at issue in that dispute by a preponderance of the evidence.[188]  This is not our case.  In this case, MnDOT-OCIC asserts that its contractor has acted illegally and has requested a determination that it is lawfully entitled to relief.  In such a posture, it bears the burden of proving its entitlement to recover on its claims.

 

IV.            Proof of Back Wages Owed

 

A.              MnDOT-OCIC Failed to Shoulder its Burden of Proof as to Classification Errors by Comstock

 

The record does not include any proof of classification error by Comstock.

 

A key infirmity follows from MnDOT-OCIC’s reading of the Prevailing Wage Act.  As MnDOT-OCIC reads the Act, workers are to be apportioned among different major job classifications based upon the nature of the construction materials that are used on a particular work day.  For example, in its Post-Hearing brief, MnDOT-OCIC asserts that all activity under the contract that involved structural steel must be classified as “iron work.”[189]  Under this view, no common laborer hours would accrue for unpacking, loading, maintaining or cleaning up any item which happens to be made of steel.  Such a view is at odds with the sworn testimony of its own expert witnesses and the arguments it advanced at the evidentiary hearing.  It is not a proper reading of either the contract or the Prevailing Wage Act.

 

For purposes of the Prevailing Wage Act, workers should be classified based upon the skills they render, rather than the materials they touch.[190]

 

Likewise important to this dispute is the breath and meaning of Major Job Classification 102, “Skilled Laborer.”  In its Post-Hearing submissions, MnDOT-OCIC argues that the Skilled Laborer classification extends to any work that “assists” a skilled craftsman.[191]  The boundary on what it means to “assist” a skilled craftsman is not offered by MnDOT-OCIC; and presumably is so expansive that it includes tasks that, at other times, the MnDOT-OCIC and its experts assert were properly undertaken by “Common Laborers.”[192] 

 

MnDOT-OCIC urged that the descriptions of the duties in Exhibit 151 represent the general and common understanding of the various duties in the construction trades.[193]  The description of the duties of Common Laborers that is found in Exhibit 151 states that such workers have significant roles in unloading materials, removing materials, installing metal fencing, welding in place pre-cast panels and performing pipe rehabilitation work.  Presumably these are all tasks that “assist” skilled journeymen and that the craftsmen find helpful.[194]

 

Because one cannot distinguish between skilled laborers and common laborers on the basis of their helpfulness to a skilled craftsman, MnDOT-OCIC’s reading of Major Job Classification 102 is disfavored.

 

Most problematic, even if there was enough detail in the major job classifications for MnDOT-OCIC to sort workers between different job classifications, the agency simply does not have a basis for undertaking this apportionment.  As detailed in the Findings above, because so much time has passed since contract performance was underway, officials of MnDOT-OCIC cannot say with any certainty what work was performed by whom on which days.  The agency surmises; it infers; but none of its guesses as to who did what work are firmly grounded in the record.

 

No witnesses called by MnDOT-OCIC spoke authoritatively as to any errors in the classifications made by Comstock and MnDOT-OCIC offered no reasonable basis to contest the apportionment made by Comstock. 

 

Lastly, the basis for the about-face made by the agency – from its position in September of 2001, that Comstock was in compliance with the labor provisions of the contract, to the view expressed in February of 2002, that Comstock “inappropriately classified and inappropriately paid” its employees – was never adequately explained.  The labor investigator’s claim that the deficiencies were orally detailed to Comstock’s Contract Administrator is not credible and is not supported by the underlying record.

 

The best explanation of MnDOT-OCIC’s sudden turnabout was that Ms. Wilder sought to retaliate against Comstock; punishing it for Mr. Koppang’s intemperately worded electronic mail message regarding the withholding of payments due to subcontractor employees.  The abrupt switch in MnDOT-OCIC’s assessment of Comstock – made at a time that Comstock was nearing completion of the project work, but shortly after Koppang had criticized Wilder’s performance – lends support to this view.  Moreover, Ms. Wilder’s later transmission of a demand for payment that she knew contained errors, fortifies the conclusion that retaliation was her aim.[195] 

 

Comstock is entitled to dismissal of the claims for back wages and a release of the contract earnings held by MnDOT-OCIC.

 

B.              Ordinarily, Ambiguities in Government Contracts are Construed Against the Drafting Agency 

 

MnDOT-OCIC’s claim for back wages is likewise hobbled because it did not establish that there is a single, commonly held understanding of terms such as “common laborer,” “skilled laborer,” “carpenter,” “sheet metal worker” or “ironworker”; or that Comstock’s construction of any of these contractual terms was unreasonable.[196]

 

In those instances in which a government agency had the sole control over the drafting of a contract,[197] as is the ordinary practice with state procurements, and the contract terms are susceptible to more than one meaning, the ambiguous terms are construed against the agency.[198]

 

          In this case, because MnDOT-OCIC could have included additional detail as to the meaning and boundaries of the different Major Job Classifications, but did not do so, it is improper for it to insist upon application of the missing terms.  MnDOT-OCIC may not unilaterally revise the contract terms because it prefers other – but unstated – meanings to apply.  The agency must accept the contract as the agency drafted it.

 

C.              Evidence of the Accord Negotiated Among Minnesota’s Trade Unions in 2008 is Not Proof of Widespread Practice in 2000, 2001 or 2002.

 

          Much of MnDOT-OCIC’s case-in-chief was centered on the drafting that occurred in the autumn of 2008, by the Minnesota State Building and Construction Trades Council, marking the boundary lines between different Major Job Classifications.[199]  As MnDOT-OCIC reasons, because the Trades Council was able to develop a 63-page packet setting forth demarcation lines between various job classifications, these delineations have always been obvious to those in the construction industry.[200]

 

          The hearing record reflects a very different reality.  President Anfang notes in his November 24, 2008 transmittal letter how difficult it was to achieve the agreements that are reflected in the “consensus” draft.[201]  Moreover, as recently as the evidentiary hearing, MnDOT-OCIC’s own expert witnesses did not agree that the consensus document reflects a proper understanding of the various skilled trades.[202] 

 

          Thus, as useful as the Trade Council draft is to the effort to one day define the Major Job Classifications, this draft does not memorialize the views of either the agency or Comstock at the time of contract formation; it does not memorialize the views of the broader contracting industry during the year 2000, 2001 or 2002; and it does not reflect a widespread understanding of the meanings of the Major Job Classifications today.[203]  At most, it is a recent set of compromises among some stakeholders.

 

          Moreover, a comparison between the classification descriptions developed by DOLI,[204] or the later Trade Council draft,[205] and the Major Job Classifications in Minn. R. 5200.1100, makes clear how much of the needed detail is missing from the regulations.  This broad and deep range of detail has never been assumed.

 

V.              Comstock’s Other Claims of Error

 

          At the close of MnDOT-OCIC’s case-in-chief, Comstock renewed the legal arguments it made in its first Motion for Summary Disposition.  Resting upon the detailed record of the evidentiary hearing, Comstock asserted that MnDOT-OCIC’s: (1) claim for back wages follows from an arbitrary application of the classification standards; (2) use and application of informal job classification determinations amounts to unpromulgated rulemaking; and (3) enforcement of the Prevailing Wage Act determinations was unconstitutional as applied to it.


A.              The Evidentiary Record Makes Clear that the Labor Standards Provisions of the Contract were Arbitrarily Applied

 

Under the Minnesota Administrative Procedures Act, a key inquiry is whether the agency’s decision represents a reasonable judgment under the circumstances and not merely the exercise of will.[206]  An agency fails to undertake reasoned decision-making when it:

 

relied on factors which the legislature had not intended it to consider, if it entirely failed to consider an important aspect of the problem, if it offered an explanation for the decision that runs counter to the evidence or if the decision is so implausible that it could not be ascribed to a difference in view or the product of agency expertise.[207]      

 

          As detailed in the Findings above, none of MnDOT-OCIC’s six different demands for payment of back wages followed from reasoned decision-making.  When rendering its demands for back wages MnDOT-OCIC: relied upon factors that the Legislature had not intended it to consider;[208] entirely failed to consider important aspects of the problem when classifying contract work;[209] offered explanations for its regulatory demands that ran counter to the evidence;[210] and proffered explanations for its classification decisions that were so implausible that they could not be ascribed to a difference in view or the product of agency expertise.[211]

 

Comstock is entitled to dismissal of the claims for back wages and a release of the contract earnings held by MnDOT-OCIC.

 

B.              The Evidentiary Record Makes Clear that the Informal Classification Determinations of DOLI were Applied as if they were Formal Rules

 

Comstock also argues that MnDOT-OCIC’s claims should be dismissed on the grounds that the wage classification determinations rendered by Mr. Oelcker and Ms. Wilder are not lawful or enforceable.  Comstock asserts that the classification determinations applied in this case are unpromulgated rules and may not be given effect.  In Comstock’s view, because MnDOT-OCIC is applying informal classification determinations from DOLI, across contractors, and giving these determinations future effect, the classification decisions should have been developed through rulemaking.

 

MnDOT-OCIC and DOLI respond that when their labor investigators announce that a given task fits into a particular job classification, they are not rulemaking, but rather undertaking a “case-by-case” adjudication of the meanings of the Major Job Classifications.[212]  Executive Branch agencies are granted considerable discretion to decide whether to develop regulatory policy “deductively,” by promulgating a new rule, or “inductively,” through a series of individual adjudications.[213]  Further, the appellate courts have instructed that every executive branch agency – and in the area of labor classifications, DOLI in particular – has the “flexibility and discretion to depart from formal rulemaking” when applying a given legal standard to a particular set of facts.[214]

 

While the agencies’ argument is cleverly phrased, in this instance, neither MnDOT-OCIC nor DOLI was using “case-by-case adjudications” to develop the missing definitions for the terms “skilled laborer,” “sheet metal worker,” “carpenter,” “cement mason” or “ironworker.”  A few points deserve special emphasis.

 

First, when Comstock sought regulatory guidance from the agencies on the meaning of the Major Job Classifications, initially from MnDOT-OCIC, and then later from DOLI, Ms. Wilder and Mr. Oelcker both disclaimed that their agencies sought to render formal regulatory definitions beginning with this contract.[215]

 

Second, the Minnesota appellate courts have held that it is simply not appropriate to authoritatively determine questions as to which there is widespread social or political interest, through case-by-case adjudication.[216] The reasons are obvious.  Persons interested in, or affected by, those determinations, might not have fair notice that a policy affecting their interests is being developed.[217]  

 

The regulatory meanings of the terms “common laborer,” “skilled laborer,” “sheet metal worker,” “carpenter,” “cement mason” and “ironworker,” as used in the Major Job Classifications, are questions that undoubtedly interest thousands of Minnesota tradesmen and their employers.  DOLI has known of the widespread interest in this topic because it has received requests from interested stakeholders, urging it to undertake rulemaking, for more than a decade.  Moreover, in 2008, as part of a rulemaking on a related, but far less controversial set of definitions within the Major Job Classifications, DOLI provided notices of its proposed actions to 1,600 interested individuals, contractors, companies and associations.[218]  Most telling of all, in 2006, when DOLI proposed a set of rules that “would remove the de facto importation of prevailing wage rates onto private construction work as a requirement of having an apprenticeship program,” the agency received over 5,000 written requests from interested persons seeking a hearing on those rules.[219]  The scope and meaning of the prevailing wage rules are matters of widespread interest that are inappropriate for determination through “case-by-case adjudication.”

 

Third, implicit in the recognition of case-by-case adjudications as an alternative to notice and comment rulemaking, is that any incremental development of policy will involve similar formality.  It simply cannot be that the occasional electronic mail message from Mr. Oelcker, or notes from a telephone consultation with Ms. Drier, has the same regulatory significance as rules promulgated by the agency following notice and comment rulemaking.  As the record in this case makes clear, such writings do not contain the “principles of law or policy lawfully declared by the agency as the basis for its decisions in particular cases” and they are not maintained by either MnDOT-OCIC or DOLI so as to permit interested persons to petition for conversion of these informal writings into formal rules.[220]  A conclusion that senior labor investigators could add to the classification rules in this way does considerable violence to the scheme established by the Minnesota Legislature in Chapter 14.  As the Minnesota Supreme Court has written: 

 

The purpose of the Administrative Procedure Act is to ensure that we have a government of law and not of men. Under that act, administrative officials are not permitted to act on mere whim, nor their own impulse, however well intentioned they might be, but must follow due process in their official acts and in the promulgation of rules defining their operations.[221]

 

The agencies’ construction of the terms “common laborer,” “skilled laborer,” “carpenter,” “sheet metal worker,” “cement mason” and “ironworker” is only grounded on these “impulse[s] … however well intentioned they may be ….”  Comstock is entitled to dismissal of MnDOT-OCIC’s claim for back wages.

 

C.              The Commissioner Could Defer the Question of the Constitutionality of the Labor Standards Regulations as Applied to Comstock

 

Comstock asserts that the text of Minn. R. 5200.1040 and 5200.1100 fail to provide sufficient guidance as to how construction work should be classified.  Comstock argues that without sufficient definiteness, the rules fall below the required constitutional standards.  The challenge is two-fold:  First, Comstock contends that because violations of the prevailing wage laws can result in criminal penalties, the state labor classifications may not be so imprecise that “persons of common intelligence must guess at its meaning or differ as to its application.”[222]  Secondly, Comstock argues that the rules are so incomplete that the classification determination process results in decisions that are inconsistent, wholly subjective and arbitrary.[223] 

 

Under both the state and federal constitutions, administrative rules must meet certain due process standards of definiteness.[224]  A rule is void for vagueness if it fails to give a person of ordinary intelligence a reasonable opportunity to know what is prohibited or fails to provide sufficient standards for enforcement by executive branch officials.[225]  Thus, if a regulation defines an act in a manner that encourages arbitrary enforcement, or is so indefinite that people must guess at its meaning, it is impermissibly vague.[226] 

 

Likewise important, in a contested case proceeding, neither an Administrative Law Judge nor the head of an Executive Branch agency may declare a statute or rule “facially unconstitutional.”  The power to declare a law unconstitutional in all settings is vested with the judicial branch of state government.[227] 

 

At its widest arc, the authority of an agency head includes the power to consider whether application of a statute or rule in a particular factual setting, meets the constitutional standards that have been announced by our courts.[228]

 

While the underlying record would support a determination in Comstock’s favor on its constitutional claims, the Commissioner may wish, for sound prudential reasons, not to ground his decision upon any particular reading of the state or federal constitutions.  Given Comstock’s entitlement to complete relief on its other claims, resolution of this case does not require the Commissioner to reach Comstock’s constitutional claims.  In like circumstances, the state courts avoid deciding a case on constitutional grounds when other, non-constitutional bases for the judgment exist.[229]

 

VI.            The Contested Case Process

 

          Pursuant to Minnesota Rule 1400.5500, subparts B, J and Q, the Administrative Law Judge entered a series of detailed scheduling orders.  These orders were entered so as to facilitate the early exchange of discoverable information amongst the parties, grant the parties genuine opportunities to depose adverse witnesses and focus the parties’ preparations for the evidentiary hearing.

 

          The most recent of the scheduling orders followed from a joint stipulation among counsel, in which the attorneys jointly agreed upon the discovery and filing deadlines that would precede the evidentiary hearing.[230]

 

          During the evidentiary hearing, the Administrative Law Judge enforced the deadlines established in these orders in a way that excluded from the hearing record evidence that was arguably relevant, but which was not disclosed in a timely fashion.[231]

 

          Because counsel for MnDOT-OCIC pledged to present the materials that were excluded from the hearing record directly to the Commissioner, and again urge its receipt into the record, some further description of these events may be helpful.[232] 

 

           A.      Receiving Telephonic Testimony from Mr. Holmberg

 

As noted above, in the Seventh Pre-Hearing Order, the Administrative Law Judge excluded the expert testimony of Doug Holmberg, via telephone, on the grounds that Comstock had not been afforded a fair opportunity to examine him prior to the evidentiary hearing.

 

While mindful that it is not uncommon for the Office of Administrative Hearings to receive testimony from witnesses telephonically, it is also true that in all but rare instances, this procedure is undertaken upon the stipulated agreement of the parties.

 

          In the rare case where telephone testimony is received over the objection of a party, a close balancing of the benefits and the harms to the fact-finding process from receiving such testimony is undertaken by the Administrative Law Judge. 

 

Important to the balancing of interests in this case, was the fact that Mr. Holmberg was not an indispensible fact witness, but rather a labor cost estimator; presumably not unlike other similarly-trained professionals in his field.  Moreover, it was represented to the Administrative Law Judge that Mr. Holmberg has been outside of the United States, working in central Africa, since the dismissal of Comstock’s certiorari appeal.  At such a distance he was beyond the reach of Comstock, its counsel and subpoenas from this Office.  Lastly, as noted during the May 24, 2009 Pre-Hearing Conference, MnDOT-OCIC had known for some time the special challenges of communicating with its expert in the Congo; because its own communications with him were spotty, indirect and difficult. 

 

Without a stipulated agreement among the parties permitting telephonic testimony of this expert, and no procedural rule guaranteeing MnDOT-OCIC such a convenience as a matter of right, the agency should not have presumed that it could dial its expert in central Africa at the start of the evidentiary hearing.  Under these circumstances, receiving Mr. Holmberg’s testimony over the objection of Comstock would have been prejudicial and unfair.

 

          B.       Exclusion of the Second Round of Revisions to Exhibit 200

 

As noted above, on May 20, 2009, MnDOT-OCIC served Comstock with a near-complete set of its proposed exhibits; a set that included Exhibit 200.  MnDOT-OCIC later filed and served a copy of its proposed supplement to Exhibit 200 – marked as Exhibit 200-A – out of time on Tuesday, May 26, 2009.

 

In the Seventh Pre-Hearing Order, the Administrative Law Judge permitted MnDOT-OCIC to submit the supplemental exhibit, out of time, notwithstanding the deadline for filing hearing exhibits.  As the Administrative Law Judge reasoned: 

 

[B]ecause the supplementary Exhibit 200-A summarizes data that is found elsewhere in the evidentiary record, and Comstock will have eight working days (and twelve calendar days) in advance of the evidentiary hearing to review this summary with its trial team, the balancing of interests lies in favor of receiving this item upon the presentment of a proper foundation.[233]

 

Notwithstanding this largesse, on the fourth day of the evidentiary hearing, MnDOT-OCIC offered two further supplements to Exhibit 200 – marked for identification as Exhibits 200-B and 200-C.  MnDOT-OCIC proposed that these supplemental exhibits overlay part of Exhibit 200-A, although the calculations in the proposed combination of documents did not match or reconcile with each other.  Receiving these supplements, which detail new factual claims and new rationales for the agency’s position, and were disclosed for the first time in the middle of the evidentiary hearing, would have been unduly prejudicial.

 

          C.       Receipt of the Deposition Transcript of Erik Oelcker

 

          On the second day of the evidentiary hearing, Comstock, in lieu of calling Mr. Oelcker as a witness during the proceedings, offered certified copies of Mr. Oelcker’s July 10, 2007 and October 4, 2007 depositions for inclusion in the hearing record.[234] 

 

          Mr. Oelcker has suffered a traumatic brain injury and, in the judgment of his physicians, is medically unavailable for trial.

 

MnDOT-OCIC objected to the receipt of the depositions into the hearing record.  Counsel for MnDOT-OCIC asserted that because he did not foresee either Mr. Oelcker’s injuries or later unavailability, he did not ask questions of Mr. Oelcker during either deposition.  As Counsel argued, the depositions of July 10, 2007 and October 4, 2007 were “discovery depositions,” and not intended to preserve the witness’ testimony for the later evidentiary hearing. 

 

The Administrative Law Judge disagrees.  As the United States District Court for the District of Minnesota wrote in a similar context:

 

Depositions are a discovery device governed by Rules 26 through 32 of the Federal Rules of Civil Procedure. Depositions also serve to preserve relevant testimony when the deponent might be unavailable to testify at trial. Neither the Rules of Civil Procedure nor the Rules of Evidence make any distinction between discovery depositions and depositions for use at trial. The court concludes there is no difference.  A party who makes the tactical decision during a deposition to refrain from examining a witness who is beyond the subpoena power of the court, takes the risk that the testimony could be admitted at trial if the witness will not or cannot appear voluntarily.[235]

 

MnDOT-OCIC had a full opportunity to develop the record at Mr. Oelcker’s depositions on July 10, 2007 and October 4, 2007 and a motive to do so that was identical to that on the first day of the evidentiary hearing.[236]  Yet, for whatever tactical reason, it did not do so.  Given Mr. Oelcker’s unavailability as a witness, the certified copies of the earlier deposition transcripts were properly received into the hearing record.[237]

 

VII.           CONCLUSION

         

          When it is all packed together in one place, the hearing record in this case consumes more than six bankers boxes. 

 

          Yet, for all of the reams of documents in the record, the equities can be described with a handful of words:  Would any person wish to be treated by his government as Comstock was treated in this case?  Would anyone be content to have her own earnings set through the methods used by the government in this case? 

 

          And so, from a case that has presented a long string of difficult questions, the last one in the series has an easy answer:  No one with an ounce of sense would be content to switch places with Comstock.

 

          Government officials acknowledge that it is reasonable for a contractor to expect that any claimed violations of the law will be set forth specifically in a demand for compliance.[238]  In this case, however, the specifics of the claimed shortcomings and the bases for the claims were never explained. 

 

Indeed, after disclaiming the accuracy of the demand for back wages it made in the Notice and Order for Hearing, MnDOT-OCIC only made its claim known on the fourth day of the evidentiary hearing; and then only in response to a direct question from the Administrative Law Judge on this point.[239]  Thus, notwithstanding years of correspondence, pre-hearing discovery and litigation, MnDOT-OCIC did not commit to a particular stance in this case until well after the evidentiary hearing was underway. 

 

          The record likewise includes the testimony of government officials to the effect that it is reasonable for a contractor to expect timely and responsive replies to inquiries on compliance issues.  Yet, despite these general admonitions, meaningful guidance as to the meaning and scope of the major job classifications was not rendered by MnDOT-OCIC’s labor compliance unit or DOLI’s labor standards unit.  A description of what the various labor classifications mean was not available at the time of contract formation; it did not exist during performance under the contract; and it does not exist today.

         

          The administrators of the labor classification program at DOLI concede, as they must, that the distinctions between various job classifications are not well-defined and that the very same work can reasonably be attributed to different major job classifications.  Neither the contractors that employ tradesmen, or the trade unions themselves, can say with any precision where the boundaries of particular job classifications begin or end.  Beyond the most general descriptions of the different trades, no one knows what the various classifications mean.

 

          Despite these gaps, MnDOT-OCIC’s labor compliance unit administered the contract as if the unknown was in fact known.  It held on to sums that were otherwise due and owning to Comstock for work performed; and when the contractor inquired as to the shortcomings in its classification of workers, the labor compliance investigator replied that the “classification descriptions include general information and are not specific ….”  For all intents and purposes, the MnDOT-OCIC said: “Guess.” 

 

No one would want to face government officials who withheld one’s earnings, for a period of nine years, on the claim that one failed to act in accordance with provisions of the law that do not exist.  In this case, MnDOT-OCIC acted far below the standard of fair dealing.

 

          The best result is for the Commissioner to do what lower-level officials did not:  Wipe this slate clean.  The Commissioner should abandon MnDOT-OCIC’s claim for back wages and release the contract amounts that the Department has retained.

 

                                                            E. L. L.



[1]  Exhibit 3 at DLI 573.

[2]  Ex. 2 at DLI 502; Ex. 203; Evidentiary Hearing Transcript (“Tr.”) at 837-38.

[3]  Tr. at 41-50.

[4]  Tr. at 166-69.

[5]  See, Ex. 2, Section 00800 at DLI 536.

[6]  Ex. 2 at DLI 553– 58; compare also, Minn. R. 5200.1040.

[7]  Ex. 2 at DLI 551-58; Tr. at 159-60, 262-64 and 1845-46.

[8]  Ex. 2 at DLI 550.

[9]  See, Ex. 2 at DLI 550-52.

[10]  Id.

[11]  Tr. at 908 and 1364.

[12]  Tr. at 1045, 1180, 1231, 1757-58, 1814 and 2050.

[13]  Tr. at 1045, 1180, 1757-58, 1795, 1814 and 2050.

[14]  Tr. at 178-79, 230 and 1757-58.

[15]  See, Tr. at 545.

[16]  Tr. at 1186, 1189, 1191-92, 1216 and 1249-50; compare also, Ex. 718 (“Defined and undefined jurisdiction may vary by area of the United States and of the State of Minnesota”).

[17]  Minn. R. 5200.1040.

[18]  Minn. R. 5200.1040 (E).

[19]  Minn. R. 5200.1100; Ex. 721; Tr. at 1277.

[20]  Tr. at 176-77, 230, 665-67, 670, 674-75, 698-700, 708, 772-73, 7898-802, 1027, 1045, 1212-13, 1218-19, and 1602-04; compare also, Ex. 718 (“each specific trade wants to have jurisdiction over as many tasks as possible”).

[21]  Tr. at 1062-63.

[22]  Tr. at 672-74, 1061-61

[23]  Tr. at 223-24, 280, 724, 762, 1603, 1763-64 and 1796.

[24]  Tr. at 177, 1920-22 and 2091; see also, 1622 and 1729.

[25]  Ex. 718; Tr. at 206-08 and 213-15; see also, Tr. 545-46 and 1114.  In some of the documents in the hearing record, Ms. Wilder is listed by her former name, Roxanne Farnham.  See, Tr. at 526.

[26]  Tr. at 206-08, 213-15, 546, 799-801, 812, 1212-13, 1218-19, 1604-05, 1796 and 2093-94.

[27]  Tr. at 2046-67.

[28]  Tr. at 1098-99 and 1278-79.

[29]  See, Tr. at 2089 and 2113-15.

[30]  Ex. 2, Section 00810, Paragraphs 1.23 (F), 1.24 (B)(3) and 1.24 (B)(5) at DLI 550-51; Ex. 750; see also, Tr. at 267-70, 1071 and 1277.

[31]  Compare, Ex. 721 with Exs. 719, 727, 732, 750, 758 and Tr. at 1071, 1092-93, 1277 and 2133-34.

[32]  Ex. 750; see also, Tr. at 1092-93 and 1277.

[33]  Compare, Exs. 719, 727, 732, 750, 758, Tr. at 533-43, 577-78 1092-93 and 1277 with Minn. Stat. § 14.02, subd. 4 (2008).

[34]  Tr. at 302.

[35]  Tr. at 303.

[36]  Tr. at 356; see also, Tr. 528 and 2149; Ex. 731 (“[M]any of the contractors are just wanting to pay what you are saying, without challenging any decision, just to get this project behind them and closed out”).

[37]  Tr. at 160, 203-06 and 438.

[38]  Tr. at 526-27, 435-37.

[39]  Tr. at 441; compare generally, Ex. 792-A.

[40]  See, Ex. 6.

[41]  Tr. at 45.

[42]  Tr. at 48-50.

[43]  Id.

[44]  Tr. at 132 and 2170.

[45]  Tr. at 840-50 and 1326-29.

[46]  Tr. at 848-49.

[47]  Tr. at 1325.

[48]  Tr. at 1325 and 1392-93.

[49]  Ex. 792-A; Tr. at 161-62.

[50]  Ex. 7 (Construction Meeting No. 1); Tr. at 324, 326, 455-56 and 555-56.

[51]  Ex. 705; Tr. at 1257 and 1420-21; see also, Tr. 1146-47.

[52]  Exs. 704 and 705; Tr. at 361.

[53]  Exs. 6 and 705; Tr. at 1420-21; see also, Ex. 7 (Minutes of Construction Meetings 17, 18 and 19).

[54]  See, Tr. 1420-21.

[55]  Tr. at 1266-67.

[56]  Ex. 706.

[57]  Ex. 706; see also, Ex. 731.

[58]  Id.

[59]  Exs. 704 and 705.

[60]  Tr. at 369-70.

[61]  Ex. 706.

[62]  Ex. 707; Tr. at 1423-24.

[63]  Exs. 707 and 712; Tr. at 1163-64, 1294-99 and 1429.

[64]  Id.

[65]  Exs. 711, 716, 715, 717, 718, 719, 720, 721; see also, 722, 724, 734, 735, 736, 743 and 744.

[66]  Ex. 714.

[67]  Exs. 715 and 716.

[68]  Ex. 733.

[69]  Ex. 718.

[70]  Ex. 719.

[71]  Ex. 720; Tr. at 1651-55.

[72]  Ex. 721.

[73]  Tr. at 1879.

[74]  Exs. 725 and 726; Tr. at 180-82.

[75]  Ex. 733; Tr. at 577.

[76]  Ex. 734.

[77]  Exs. 735 and 736.

[78]  Ex. 737.

[79]  Ex. 711; Tr. at 1992; see also, Tr. at 369-70.

[80]  Ex. 738; Tr. at 1267, 1432-33, 1435, 1438-39, 1659 and 1666-67.

[81]  Ex. 745.

[82]  Exs. 746, 749, 751, 752, 754, 755 and 759.

[83]  See, Exs. 752 and 753.

[84]  Ex. 756.

[85]  Ex. 760.

[86]  Ex. 760; Tr. at 2155.

[87]  See, id.

[88]  Ex. 716; Tr. at 162. 

[89]  Notice of and Order for Hearing, at 3.

[90]  Tr. at 630; see also, Tr. at 1115-17.

[91]  Ex. 2 at DLI 535-36; Ex. 737; Ex. 742.

[92]  Tr. at 438 and 530.

[93]  See, Ex. 200-A (analysis of Mike Pittman’s duties on September 15, 2000), 719 and 769; Ex. 792-A (Mike Pittman’s Time Card of September 15, 2000); see also, Tr. at 1899.

[94]  Exs. 200-A and 768; Tr. at 769 and 1196-97.

[95]  Exs. 745, 753, 766 and 768; Tr. at 494 and 1070.

[96]  Ex. 766; Tr. at 1154-61.

[97]  See, id.

[98]  Compare, Exs. 200-A, 743, 744, 745, 756, 760, 763 and 764.

[99]  Tr. at 529 and 531.

[100]  Tr. at 531 and 1072-73.

[101]  Tr. at 1135-36.

[102]  Tr. at 529 and 1146.

[103]  Tr. at 1375-91.

[104]  See, Tr. at 529 and 1146.

[105]  Compare, Tr. at 528 with Tr. at 2089 and 2113-15.

[106]  Tr. at 1135-35 and 1153-54; compare also Tr. at 2113.

[107]  See, Tr. at 1146; see also, Tr. at 1153, 1899-1903, 1992 and 2113-15.

[108]  Ex. 765 at 3; Tr. at 1033-34, 1182-83, 1792-93, 1607-08, 1542, 1545 and 1797; see also, 2102-04 and 2132.

[109]  Compare, Tr. at 1146 with Ex. 765 at 3; Exs. 800-A, 800-B and 800-C; Tr. at 1418-20, 1517-18, 1555, 1607-08, 1792 and 1798.

[110]  Ex. 800-C; Tr. at 1141-42.

[111]  Tr. at 1947-48; see also, Tr. at 1902-04.

[112]  Exs. 200-A, 719 and 768; Tr. at 1137-39 and 1680.

[113]  Ex. 790; Tr. at 550-52.

[114]  Ex. 200-A; Tr. at 1693-96.

[115]  Ex. 2 at DLI 557-58; Ex. 782 – Photographs B and C; Tr. at 1127 and 1409.

[116]  Ex. 200-A; Tr. at 1691-92.

[117]  Ex. 200-A; Tr. at 1691.  

[118]  Ex. 200-A; Tr. at 1700.

[119]  Exs. 200-A.

[120]  Exs. 200-A; Ex. 701-B; (Hanson Time Card of September 20, 2001); compare also, 701-E (Siemenewski Time Card of April 23, 2001); Tr. 1677 and 1701-02.

[121]  Tr. at 415; compare also, Tr. at 547, 2081-82 and 2089 and 24 State Register 396 (September 20, 1999). 

[122]  Tr. at 1566, 1807-08, 1879, 2081 and 2089.

[123]  Tr. at 1845; compare also, Tr. at 1790-91 and 1823. 

[124]  See, L&D Trucking v. Minnesota Dep’t. of Transp., 600 N.W.2d 734, 737 (Minn. App. 1999).

[125]  See, AAA Striping Service Co. v. Minnesota Dep’t of Transp., 681 N.W.2d 706, 717 (Minn. App. 2004) (emphasis added and footnote omitted).

[126]  See, Ex. 784 at 63.

[127]  Tr. at 1857, 1871-73, 1894-95 and 1939.

[128]  Tr. at 1852-53 and 1869-70.

[129]  Ex. 793; Tr. at 1852-53 and 2081.

[130]  See, Tr. at 1869-72; 24 State Register 396 (September 20, 1999); see also, AAA Striping Service Co. 681 N.W.2d 717-18 ("We have already noted that DOLI has actually commenced a rulemaking proceeding to consider changes to the Master Job Classifications used in the MnPWL for several types of work including ‘new classes or altering the classifications applying to painting and striping of roads’ …. In any event, almost three years later this rulemaking process is unfinished and possibly dormant") and In the Matter of the Proposed Amendments to the Rules of the Department of Labor and Industry, Labor Standards Unit, Relating to Prevailing Wage Determinations, Master Job Classifications, Minnesota Rules Parts 5200.1030 to 5200.1100, OAH Docket No. 8-1900-19710-1 at 3 and 7 (September 28, 2008) (http://www.oah.state.mn.us/aljBase/190019710.final.rr.htm).

[131]  See, In the Matter of the Proposed Amendments to the Rules of the Department of Labor and Industry, Labor Standards Unit, Relating to Prevailing Wage Determinations, Master Job Classifications, Minnesota Rules Parts 5200.1030 to 5200.1100, OAH 8-1900-19710-1 at 3.

[132]  Exs. 150, 151, 152 and 793; Tr. at 282, 329-31, 793 and 806-07.

[133]  Tr. at 204, 547, 548 and 1054-55.

[134]  Ex. 151; compare also, Tr. at 345-46, 667-68, 707, 1015, 1017-18, 1027-28, 1037 and 1054.

[135]  Ex. 151; Tr. at 708, 1041 and 1048.

[136]  Tr. at 1037 and 2096.

[137]  Notice of and Order for Hearing, at 5.

[138]  Exhibit A to the Affidavit of Michael L. McCain (May 27, 2009); compare also, Minn. R. 1400.6700 (2007).

[139]  See, Exs. B and F to the Affidavit of Michael L. McCain.

[140]  See, Exs. C and D to the Affidavit of Michael L. McCain.

[141]  Third Pre-Hearing Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 (September 14, 2007).

[142]  See, Ex. F to the Affidavit of Michael L. McCain.

[143]  Recommendation on Motion for Summary Disposition, supra, at 1 and 10.

[144]  Affidavits were received from Gerhard P. Bergmann, Jim P. Gustafson, John McDowall, Steve R. Newby, John W. Quarnstrom, Rob Snider and Charles B. Witt.

[145]  See, Ex. I to the Affidavit of Michael L. McCain.

[146]  Seventh Pre-Hearing Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 at 3 (June 3, 2009)..

[147]  Recommendation on Motion for Summary Disposition, supra, at, at 8.

[148]  In the Matter of the MnDOT Detroit Lakes Regional Headquarters, Findings of Fact, Conclusions and Order of the Commissioner of Transportation, OAH Docket No. 8-3001-17706-2, at 2 (October 10, 2008).

[149]  Id., at 8.

[150]  In the Matter of the MnDOT Detroit Lakes Regional Headquarters, A08-1931 (Minn. App. 2008).

[151]  Fourth Pre-Hearing Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 (December 19, 2008).

[152]  Fifth Pre-Hearing Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 (February 25, 2009).

[153]  Stipulation and Amended Scheduling Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 (March 19, 2009).

[154]  Id.

[155]  Recommendation on Motion for Summary Disposition, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 (February 7, 2008).

[156]  Seventh Pre-Hearing Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 at 9 (June 3, 2009); Tr. at 510-11.

[157]  Digital Recording, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 (May 26, 2009); But compare, Tr. at 109-12.

[158]  Seventh Pre-Hearing Order, at 8-9; see also, Tr. at 105-119.

[159]  Tr. at 98-108.

[160]  Tr. at 513 and 1077.

[161]  Seventh Pre-Hearing Order, at 9; Ex. 200-A; Tr. 510-11.

[162]  Tr. at 513, 1077, 1141 and 1235.

[163]  Tr. at 515-21, 628-30 and 1077.

[164]  Tr. at 515-21 and 625-30.

[165]  Tr. at 245-46.

[166]  Tr. at 244-45.

[167]  Exs. 791-A and 791-B; Tr. at 244-49.  

[168]  Minn. Stat. § 177.41.

[169]  Minn. Stat. § 177.44, subds. 3 and 4.

[170]  Minn. Stat. §§ 161.32 (1)(d) and 177.44 (6) (2008).

[171]  See, Exs. 711, 716, 715, 717, 718, 719, 720, 721, 722, 724, 734, 735, 736, 743 and 744; Tr. 368-72, 1647, 1649-55, 1807-08 and 1879.

[172]  Tr. at 798-99 and 1308-09.

[173]  Minn. Stat. § 177.44, subd. 7.

[174]  Minn. Stat. § 177.44 (1) (2008) (emphasis added).

[175]  Compare generally, Minn. Stat. § 645.08 (3) (“general words are construed to be restricted in their meaning by preceding particular words”); Minn. Stat. § 645.17 (2) (“the legislature intends the entire statute to be effective and certain”); Minn. Stat. § 645.19 (“Provisos shall be construed to limit rather than to extend the operation of the clauses to which they refer”) (2008).

[176]  Watson Constr. Co. v. City of St. Paul, 109 N.W.2d 332, 335 (Minn. 1961).

[177]  Compare, State ex rel. Spannus v. McGuire Architects-Planners, Inc., 245 N.W.2d 218, 221-22 (Minn. 1976) (statutory authorization for arbitration of disputes in state highway contracts was not a prohibition of a state agency obtaining an arbitration clause in a contract for the construction of a state building); compare also, Lucus v. Am. Family Mut. Ins., 403 N.W.2d 646, 648-49 (Minn. 1987) (there being no “negative terms importing a plain legislative intent that acts authorized therein are to be performed in a prescribed manner,” the contracting parties were permitted to set the terms of arbitration by mutual agreement).

[178]  Ex. 2, Section 00810 at DLI 551 (emphasis added).

[179]  Ex. 2, Section 00800 at DLI 533.

[180]  Florida State Bd. of Admin. v. Law Eng’g and Environ. Servs., Inc., 262 F.Supp.2d 1004, 1010 (D.Minn. 2003) (citations omitted).

[181]  Dunne v. Libbra, 330 F.3d 1062, 1064 (8th Cir. 2003) (a forum selection clause that provided “the parties consent to [the jurisdiction of] the state courts of the State of Illinois,” and did not use the words “exclusive,” “only,” “must,” or any other terms that might suggest exclusivity, “[t]he forum selection clause is permissive”); see also, State ex rel. Spannus, 245 N.W.2d at 222 (“We are not persuaded that the fact that the legislature in Minn. Stat. § 3.751 gave private parties a right of action in district court for disputes arising from state contracts necessarily means that the legislature in-tended to preclude the state from attempting to settle contract disputes through arbitration”); Cargill, Inc. v. Lone Star Technologies, Inc., 2003 WESTLAW 230749 (Minn. App. 2003) (unpublished) (where the contract between the parties stated that “Delaware courts 'are to have' jurisdiction ... [t]he plain meaning of the forum-selection clause supports the district court's conclusion that Delaware is a proper forum but not necessarily the sole forum”).

[182]  Ex. 2 at DLI 551 (Section 810, Page 9, at Clauses A (1) and B (5)).

[183]  See, Southern Minn. Constr. Co. Inc. v. Minn. Dep't of Transp., 637 N.W.2d 339, 344 (Minn. App) review denied (Minn. 2002) ("Before MinnDOT instituted administrative proceedings, [the contractor] could have brought a declaratory judgment action, but once administrative proceedings had begun, [the contractor's] right to bring a declaratory action to arrest those proceedings was foreclosed. Once “enforcement” begins, the proper judicial review is by certiorari of the commissioner's final determination").

[184]  Compare, Minn. Stat. § 177.44 (4) (2008) (A person aggrieved by a decision of the commissioner [as to prevailing wage rates] after reconsideration may within 20 days after the decision petition the commissioner for a public hearing as in a contested case under sections 14.57 to 14.61”).

[185]  See, Ex. 760; Digital Recording of the Pre-Hearing Status Conference of May 20, 2009, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2; In the Matter of Bauerly Bros., Inc., OAH Docket No. 12-3000-11993-2 (2002) ("Because of [its failure to pay prevailing wages, or to assure that its subcontractors paid prevailing wages], it is appropriate to require Bauerly Brothers to comply with Minn. Stat. § 177.44 in this matter by paying the identified drivers the shortfall in their wages identified by Mn/DOT, and by other appropriate sanctions determined by the Commissioner").

[186]  See, e.g., AAA Striping Service Co. v. Minn. Dep’t of Transp., 681 N.W.2d 706, 719-20 (Minn. App. 2004) ("In this proceeding, AAA clearly called into question whether and how DOLI made any classification decision [as to striper and striper tender employees]. In this situation, the state had the responsibility of establishing the existence of the actual classification decision and the circumstances of its adoption by clear evidence"); In the Matter of the Order to Comply, Labor Law Violation and Penalty Assessment for Failure to Make and Keep Records of Budget Towing, Inc., OAH Docket No. 61-1900-17654-2 (2008) (http://www.oah.state.mn.us/aljBase/190017654%20report.htm) (in an enforcement action against an employer for improper record-keeping and deductions relating to the wages of its employees, “the burden is on the Department to prove by a preponderance of the evidence that Budget Towing has violated a law, rule, or order related to the Commissioner’s duties and responsibilities").

[187]  See, Donovan v. Tony and Susan Alamo Foundation, 722 F.2d 397, 404 (8th Cir. 1983) (in a suit under the Fair Labor Standards Act "an employee has carried out his burden if he proves that he has in fact performed work for which he was improperly compensated and if he produces sufficient evidence to show the amount and extent of that work as a matter of just and reasonable inference[; t]he burden then shifts to the employer to come forward with evidence of the precise amount of work performed or with evidence to negative the reasonableness of the inference to be drawn from the employee's evidence").

[188]  See, In the Matter of the Truck Rental Rate Effective December 20, 2004, OAH Docket No. 12-1900-16601-2 (2005) (http://www.oah.state.mn.us/aljBase/190016601.pho2.htm) (“Because Petitioners are challenging the correctness of the truck rental rates established by DLI, the burden is upon Petitioners to prove the facts at issue by a preponderance of the evidence”).

[189]  See, MnDOT-OCIC’s Initial Post-Hearing Brief at 23; see also, Tr. 537.

[190]  Compare, Minn. Stat. § 177.41 (2008) (“It is in the public interest that … persons working on public works be compensated according to the real value of services they perform”) and Ex. 2 at DLI 551 (Section 00810, Page 9, at Clause A (1) with Tr. 1114 (Ms. Wilder testifies “I don’t do crew mix … I do task”).

[191]  See, MnDOT-OCIC’s Initial Post-Hearing Brief, at 15-17.

[192]  Compare, id., with Exs. 4 and 151 at DLI 233-35.

[193]  See, Tr. at 645, 683-84, 723-24, 759 and 785-86.

[194]  Compare, MnDOT-OCIC’s Initial Post-Hearing Brief, at 15-17 with Ex. 4; Ex.151 at DLI 233-35; Ex. 791 at 121-22; Tr. at 533-34, 577-78, 889, 943-49, 975, 1002, 1004, 1030-35, 1049, 1182-83, 1186, 1193-94, 1195-96, 1207, 1217-18, 1224-27, 1244-45, 1345, 1417, 1542, 1547, 1771, 1779, 1790, 1792-98, 1823-24, 1845, 1899 and 2183-85.

[195]  Exs. 704, 705 and 760; Tr. at 560 and 2155.

[196]  Compare, MnDOT-OCIC’s Initial Post-Hearing Brief, at 7 with Ex. 2 at DLI 533-38.

[197]  See, Tr. at 166-69.

[198]  See, Benson v. City of Little Falls, 379 N.W.2d 711, 713 (Minn. App. 1986) ("When a contract bears more than one reasonable interpretation, any ambiguity should generally be resolved against the party who drew the contract"); accord, U.S. v. Standard Rice Co., 323 U.S. 106, 111 (1944) ("We will treat [the federal government] like any other contractor and not revise the contract which it draws on the ground that a more prudent one might have been made"); Corso v. Creighton University, 731 F.2d 529, 533 (8th Cir. 1984) ("[w]here, as here, the contract is on a printed form prepared by one party, and adhered to by another who has little or no bargaining power, ambiguities must be construed against the drafting party"); Drainage Dist. No. 1 of Lincoln County, Neb., v. Rude, 21 F.2d 257, 261 (8th Cir. 1927) ("[W]hen a written contract is entirely prepared by one of the parties, and accepted, as thus prepared, by the other, any doubt as to the meaning of its provisions is to be resolved against the party preparing it").

[199]  See, Ex. 151.

[200]  See, MnDOT-OCIC’s Initial Post Hearing Brief, at 8 (“the words carpenter, laborer, ironworker, sheet metal worker, cement mason and roofer … are commonly used and have common meanings”); Tr. at 645, 683-84, 723-24, 759 and 785-86.

[201]  See, Ex. 151 at 1 (the representatives of the affected Building Trades unions “brought their practical experience to the table when it came time to define the work of their crafts….  Consensus over an issue like trade definitions is not easy to reach”).

[202]  See, e.g., Tr. at 708-09, 1041 and 1048.

[203]  Id.

[204]  Exs. 150 and 793.

[205]  Ex. 151.

[206]  See, Markwardt v. Water Resources Bd., 254 N.W.2d 371, 374-75 (Minn. 1977); People’s Natural Gas Co. v. Minnesota Pub. Utils. Comm’n, 342 N.W.2d 348, 353 (Minn. App. 1983).

[207]  In re Space Center Transport, 444 N.W.2d 575, 581 (Minn. App. 1989) (citing Motor Vehicle Mfgrs. Ass’n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983)) (emphasis added).

[208]  See, Findings 55 – 59, 83 and 86 – 87, supra.

[209]  See, Findings 93 – 94 and 97 – 112, supra.

[210]  See, Findings 50, 51, 52, 61 – 64, 75 – 76, 86 – 88 and 114 – 122, supra.

[211]  See, Findings 69, 70, 79, 81, 84, 85 – 87, 90, 95 – 112 and 114 – 122, supra.

[212]  See, e.g., MnDOT-OCIC’s Initial Post Hearing Brief, at 13-14.

[213]  See, Minn. Stat. § 14.381 (b) (2008); Bunge Corp. v. Commissioner or Revenue, 305 N.W.2d 779, 785 (Minn. 1981). 

[214]  See, AAA Striping Service Co. v. Minnesota Dep’t. of Transp, 681 N.W.2d 706, 717-18 (Minn. 2004); compare also, L&D Trucking v. Minnesota Dep’t. of Transp., 600 N.W.2d 734, 736 (Minn. App. 1999);  In re Hibbing Taconite Co., 431 N.W.2d 885, 894-95 (Minn. App. 1988). 

[215]  See, Exs. 718 and 719.

[216]  See, Dullard v. Minn. Dep’t of Human Servs., 529 N.W.2d 438, 445-46 (Minn. App. 1995); In the Matter of the Appeal of Donald Jongquist, 460 N.W.2d 915, 917 (Minn. App. 1990); In the Matter of the Application of Crown CoCo, 458 N.W.2d 132, 138 (Minn. App. 1990); __.

[217]  See, In the Matter of the Application of Crown CoCo, 458 N.W.2d at 138; Hibbing Taconite, 431 N.W.2d at 894.

[218]  See, In the Matter of the Proposed Amendments to the Rules of the Department of Labor and Industry, Labor Standards Unit, Relating to Prevailing Wage Determinations, Master Job Classifications, Minnesota Rules Parts 5200.1030 to 5200.1100, OAH 8-1900-19710-1 at 8 (September 28, 2008) (http://www.oah.state.mn.us/aljBase/190019710.final.rr.htm).

[219]  See, In the Matter of Proposed Amendments to Rules Governing Apprenticeship Wages, OAH Docket No. 7-1900-17022-1 at 2 and 6 (http://www.oah.state.mn.us/aljBase/190017022.rr.htm).

[220]  Compare, Exs. 719, 726, 750, 758 and Tr. at 1071, 1092-93, 1277 and 2133-34 with Minn. Stat. § 14.06 (a) and (b) (2008) and Minn. Stat. § 15.17 (1) (2008).

[221]  See, Monk & Excelsior, Inc. v. Minn. State Board of Health, 225 N.W.2d 821, 825 (Minn. 1975); accord, Jongquist, 460 N.W.2d at 917.

[222]  Compare, Comstock’s Initial Post-Hearing Brief, at 57-59, 63 and 69-70 with Hard Times Café, Inc. v. City of Minneapolis, 625 N.W.2d 165, 171 (Minn. App. 2001) (an ordinance "is void due to vagueness if it defines an act in a manner that encourages arbitrary and discriminatory enforcement, or the law is so indefinite that people must guess at its meaning"); compare also, State v. Robinson, 539 N.W.2d 231, 236-37 (Minn. 1995).

[223]  See, id.

[224]  Minn. Chamber of Commerce v. Minn. Pollution Control Agency, 469 N.W.2d 100, 107 (Minn. App.), review denied (Minn. 1991).

[225]  Grayned v. City of Rockford, 408 U.S. 104, 108-09 (1972); In re N.P., 361 N.W.2d 386, 394 (Minn. 1985) appeal dismissed 106 S.Ct. 375 (1985).

[226]  See, Hard Times Café, Inc., 625 N.W.2d at 171; Humenansky v. Minnesota Bd. of Md. Exam’rs, 525 N.W.2d 559, 564 (Minn. App. 1994), review denied (Minn. 1995).

[227]  See, Neeland v. Clearwater Memorial Hosp., 257 N.W.2d 366, 368 (Minn. 1977); In the Matter of Rochester Ambulance Serv., 500 N.W.2d 495, 499-500 (Minn. App. 1993). 

[228]  See, Pine County v. State Dep't. of Natural Resources, 280 N.W.2d 625, 629 (Minn. 1979) (“If ... the challenge relates only to the constitutionality of the ordinance, as applied, the aggrieved party must first exhaust available remedies before we will consider the constitutional claims ripe for our review”) (citing State Dept. of Nat. Resources v. Olson, 275 N.W.2d 585 (Minn. 1979)); Minnesota Educ. Ass'n v. Minnesota State Bd. of Educ., 499 N.W.2d 846, 849 (Minn. App. 1993) (“in a pre-enforcement constitutional challenge, the challenge is to the constitutionality of the rule on its face; in a contested enforcement action, the challenge is more to the constitutionality of the rule as applied”).

[229]  See, e.g., State v. Bourke, 718 N.W.2d 922, 926 (Minn. 2006) (“We generally avoid ruling under the constitution if there is another basis upon which a case can be resolved”); Erlandson v. Kiffmeyer, 659 N.W.2d 724, 732 n.7 (Minn. 2003) (“Our general practice is to avoid a constitutional ruling if there is another basis on which a case can be decided”); In re Senty-Haugen, 583 N.W.2d 266, 269 n.3 (Minn. 1998) (“It is well-settled law that courts should not reach constitutional issues if matters can be resolved otherwise”).

[230]  Stipulation and Amended Scheduling Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 (March 19, 2009).

[231]  See, Minn. R. 1400.6700, subpart 3 (2007) (“Upon the failure of a party to reasonably comply with an order of the judge made pursuant to subpart 2, the judge may make a further order as follows ... an order refusing to allow the party failing to comply to support or oppose designated claims or defenses, or prohibiting that party from introducing designated matters in evidence).

[232]  Compare, Tr. at 107-08 with Beaty v. Minnesota Board of Teaching, 354 N.W.2d 466, 472 (Minn. App. 1984) (the Minnesota Supreme Court outlines the care that agency heads should take when rejecting or revising the determinations of hearing examiners in contested case proceedings).

[233]  Seventh Pre-hearing Order, In the Matter of the MnDOT Detroit Lakes Regional Headquarters, OAH Docket No. 8-3001-17706-2 at 9.

[234]  Ex. 791.

[235]  Henkel v. XIM Products, Inc., 133 F.R.D. 556, 557 (D. Minn. 1991) (emphasis added and citations omitted).

[236]  See, McKnight By and Through Ludwig v. Johnson Controls, Inc., 36 F.3d 1396, 1410 (8th Cir. 1994); DeLuryea v. Winthrop Laboratories, a Div. of Sterling Drug, Inc., 697 F.2d 222, 226-27 (8th Cir. 1983).

[237]  Minn. R. Evid. 801(b)(1); see also, Finnes v. Selover, Bates & Co., 131 N.W. 371, 371-72 (Minn. 1911); Stein v. Swensen, 49 N.W. 55, 57 (Minn. 1891); Slingerland v. Slingerland, 48 N.W. 605, 606 (Minn. 1891).

[238]  See, Tr. at 184.

[239]  See, Tr. at 11 and 629-30; compare also, Tr. at 67-68.