William Mitchell Law Review

Publication Information

31 William Mitchell Law Review 1545 (2004-2005)


This note explores the Ramsey County District Court’s decision in Unity Church v. Minnesota recently affirmed by the Minnesota Court of Appeals. This note does not, however, debate the merits of Minnesota’s conceal-and-carry law. Part II traces the legislative path taken by both the natural resource and conceal-and-carry bills. Part II surveys the history of the single-subject and title clause of the Minnesota Constitution and the evolution of the Minnesota Supreme Court’s interpretation of the clause since its enactment. Part III summarizes the factual and procedural posture of the Unity Church decision. Part IV then contends that the legislature’s enactment of the amended natural resource law failed to comply with the single-subject provision of article IV, section 17 of the Minnesota Constitution. Moreover, this note asserts a contrary holding eviscerates the Blanch v. Suburban Hennepin Regional Park District “mere filament” test to a “mere figment” and renders the single-subject and title clause meaningless. In contrast to the law’s failure to comply with the single-subject provision, this note contends that the amended natural resource law’s title gave reasonable notice of its contents. Further, Part IV asserts that the proper sanction renders the entire law unconstitutional. This note concludes that the appellate courts should return to their proper role in interpreting the single-subject and title clause of the Minnesota Constitution, namely to give each part of the constitution the plain meaning and effect of its language.