In the Matter of the Appeal by Souriyathay Adult Daycare Order of License Revocation License No.: 1108140 (Adult Day Care).

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-0689

In the Matter of the Appeal
by Souriyathay Adult Daycare Order of License Revocation
License No.: 1108140 (Adult Day Care).

Filed February 17, 2026
Affirmed
Florey, Judge*

Department of Human Services
File No. 39574

Sia Lo, Lo Law Firm, P.A., St. Paul, Minnesota (for relator Souriyathay Adult Daycare)

Keith Ellison, Attorney General, R.J. Detrick, Assistant Attorney General, St. Paul,
Minnesota (for respondent Commissioner of Human Services)

Considered and decided by Smith, Tracy M., Presiding Judge; Ross , Judge; and
Florey, Judge.
NONPRECEDENTIAL OPINION
FLOREY, Judge
In this certiorari appeal, relator Souriyathay Adult Daycare challenges an order by
respondent Commissioner of Human Services revoking relator’s license to provide adult
day care services. Relator argues that (1) the commissioner’s determination that relator
violated a conditional -license term is arbitrary and capricious and unsupported by

* Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
2
substantial evidence, (2) the commissioner’s determination that relator violated ten
licensing requirements is based on error of law and unsupported by substantial evidence,
and (3) the commissioner’s application of Minn. Stat. § 245A.07, subd. 1(a) (2024), is
affected by an error of law. Because we conclude that the commissioner’s decision to
revoke relator’s license is not arbitrary and capricious, is supported by substantial evidence,
and is not affected by an error of law, we affirm.
FACTS
Relator was an adult day care program licensed under Minnesota Statutes chapter
245A (2024 & Supp. 2025). Relator obtained a license in January 2022, but it began
operations several months later in October 2022. Relator’s program primarily served the
Laotian community. Relator had fewer than ten staff members who serve approximately
20 participants at a time.1
In January 2023, the Minnesota Department of Human Services (DHS) inspected
relator’s facilities. DHS identified “significant violations of health and safety standards”
at the program, including violations related to participant and staff record keeping.
In February, DHS placed relator on a two-year conditional license. The conditional
license required relator to adhere to several terms, including a term prohibiting the
admission of new participants for six months and only allowing new admissions upon
DHS’s approval after that time (participant term). The conditional license notified relator

1 Relator is licensed to serve approximately 48 people.
3
that noncompliance with licensing requirements or the conditional- license terms could
result in sanctions, including revocation of relator’s license.
Relator did not request reconsideration of the conditional license. It did, however,
request that DHS reconsider the participant term so that relator could admit new
participants to the program. DHS declined to remove or change the term, explaining via
email that it helps “ensure compliance has been achieved before more admissions are made
into the program.” DHS further explained that relator could not admit four individuals who
were transitioning into the program but had not yet been admitted.
DHS conducted another inspection of relator’s facility in May, after which it issued
a Notice of Noncompliance with the Terms of a Conditional License and Correction Order.
This notice identified six licensing violations and determined that relator had admitted
seven new participants in violation of the participant term. Relator did not request
reconsideration of the notice.
August Inspection and Revocation
DHS conducted another inspection of r elator’s program in August . During the
inspection, relator ask ed about the participant term and whether it could admit new
participants. DHS informed relator that it still could not admit new participants.
The day after the inspection, DHS received an email from a participant’s (P3) case
manager which informed DHS that P3 had been consistently attending relator’s program
since June 2023. The case manager had received a call from relator seeking an alternative
billing method for services provided to the participant.
4
DHS issued relator an Amended Order of License Revocation 2 based on relator’s
violation of two conditional-license terms and ten licensing requirements. DHS restated
its determination that relator had violated the participant term when it admitted seven new
participants following the issuance of the conditional license. DHS determined that relator
had violated the participant term again when it admitted P3 to the program. 3
Relator timely appealed the revocation order.
Contested Case Hearing and ALJ Recommendation
After an evidentiary hearing, the administrative-law judge (ALJ) issued Findings of
Fact, Conclusions of Law, and Recommendation. The ALJ concluded that both violations
of the conditional-license terms were supported by the record. 4 Regarding relator’s
violation of the participant term, the ALJ determined that relator “admitted new
participants despite the [DHS]’s prohibition pending a change in the Conditional License.”
The ALJ also concluded that DHS had substantiated seven of the ten violations. Regarding
the three violations that the ALJ concluded were unsubstantiated, the ALJ determined that

2 DHS originally issued relator an Order of License Revocation. It subsequently amended
this order to correct certain references to participants in the order.

3 DHS also determined that relator violated term 3 of the conditional license when it failed
to submit the date that all participant and personnel records would be brought into
compliance and failed to bring all participant and personnel records into compliance by
August 16, 2023. On appeal, relator does not contend that the commissioner erred in
determining that it violated this term of the conditional license.

4 Regarding term 3 of the conditional license, the ALJ determined that the “parties did not
offer any evidence demonstrating [that relator] provided the anticipated date of compliance
with” the conditional license to DHS.
5
relator corrected the deficiencies and merely failed to provide documentation of those
corrections to DHS during the August 2023 inspection.
Although the ALJ concluded that relator had violated the two conditional-license
terms and seven licensing requirements, the ALJ determined that because the number of
licensing violations had decreased from the issuance of the conditional license and that
many of the remaining violations related to “a few participants or employees,” those
violations “no longer represent a broad systemic problem.” The ALJ recognized, though,
that relator’s violation of the participant term was “the most serious violation.” The ALJ
characterized this violation as “a blatant disregard of the license term,” and noted that
relator “was not forthright in its communications with [DHS] about new participants.” The
ALJ stated that this violation was “severe and may, on its own, warrant the most severe
sanction.” However, t he ALJ noted that “other factors weigh against revocation,” and
applied a best-interests-of-the-community consideration and risk-of -harm factors. See
Minn. Stat. §§ 245A.04, subds. 6(b) (2024), 7(g) (Supp. 2025), 245C.16, subds. 1(b), 2
(2024). Based on the ALJ’s application of this consideration and these factors, the ALJ
ultimately recommended that relator continue to operate under the conditional license and
pay a fine of $1,400.
Commissioner’s Order and Reconsideration Decision
After DHS filed exceptions to the ALJ’s recommendation, the commissioner
concluded that relator violated both conditional-license terms and committed all ten
licensing violations and thus affirmed the revocation.
6
The commissioner agreed with the ALJ that relator violated the participant term,
stating that the violation was “chronic, severe, and of a nature that demonstrates, at best
(and as stated by the ALJ) a ‘feigned lack of understanding of who a participant is or when
they are admitted.’” The commissioner noted that although she must consider “the effect
of the violation on the health, safety, or rights of persons served by the program,” this
standard does not require a finding of actual harm or injury to participants. Instead, the
commissioner explained that “[a] program operating with too many participants creates a
myriad of dangers to health, safety, or rights of persons served by the program.” The
commissioner added that by “effectively operating its program over its allotted capacity,
and outside of the applicable laws and rules intended to provide appropriate services to
vulnerable adults and protect them from harm, participants were placed at a greater risk of
harm by [relator].”
5
The commissioner also struck the ALJ’s application of the best-interests-of-the-
community consideration and the risk-of- harm factors as erroneous. The commissioner
explained that the former applies only when the action is based on a prior revocation or

5 As to the three violations that the ALJ determined were unsubstantiated, the
commissioner concluded that relator was required to grant DHS access to the records
during the inspection and to store its records in a manner that allows the commissioner
access. Because relator did not produce documents to demonstrate its compliance at the
time of the inspection, the commissioner concluded that the violations were properly cited.
The commissioner further noted that “[r]ecord-keeping requirements protect health and
safety and are minimum standards for license holders” which “are essential to keeping
vulnerable adults safe at the licensed program and ensuring participants are receiving
appropriate services.”
7
prior license denial and the latter applies only when the matter involves a chapter 245C
background-study issue. Neither of these circumstances were present in relator’s case.
Relator requested reconsideration. The commissioner determined that relator
presented no evidence or arguments warranting reversal and upheld the revocation.
This appeal follows.
DECISION
I. The commissioner’s final decision revoking r elator’s license is not arbitrary
and capricious, is supported by substantial evidence, and is unaffected by error
of law.
The commissioner “may . . . revoke the license . . . of the program of a license
holder who does not comply with applicable law or rule.” Minn. Stat. § 245A.07, subds.
1(a), 3(a)(1) (Supp. 2025). The commissioner may also revoke a license for failure to
correct violations specified in a conditional license. Minn. Stat. § 245A.06, subd. 3 (2024).
When determining whether to revoke a license, the commissioner must consider “the
nature, chronicity, or severity of the violation of law or rule and the effect of the violation
on the health, safety, or rights of persons served by the program.” Minn. Stat. § 245A.07,
subd. 1(a).
Relator argues that we should reverse the commissioner’s decision to revoke its
license because (1) the commissioner’s determination that relator violated the participant
term is arbitrary and capricious and unsupported by substantial evidence, (2) the
commissioner’s determination that relator violated ten licensing requirements is based on
8
an error of law and unsupported by substantial evidence, and (3) the commissioner’s
application of Minn. Stat. § 245A.07, subd. 1(a), was affected by an error of law. 6
Our scope of review of agency decisions is narrow.
Indep. Sch. Dist. No. 281 v. Minn. Dep’t of Educ., 743 N.W.2d 315, 321 (Minn. App.
2008). Agency decisions “enjoy a presumption of correctness,” and we defer to agencies’
expertise and special knowledge in their field. Id. (quotation omitted). We may reverse
an agency decision if it violates a constitutional provision, is made in excess of an agency’s
statutory authority, is made upon unlawful procedure, reflects an error of law, is
unsupported by substantial evidence in view of the entire record, or is arbitrary or
capricious. See Minn. Stat. § 14.69 (2024); see also
Minn. Internship Ctr. v. Minn. Dep’t of Educ., 996 N.W.2d 34, 46 (Minn. App. 2023),

6 Relator also raises two due-process claims. First, relator argues that “the commissioner
deprived relator of fair notice and process by relying on matters outside the scope of the
licensing orders and statutory framework.” Relator highlights “broader ‘staff
qualifications,’” “management inexperience,” and the redefinition of “admit” as grounds
for revocation that the commissioner relied upon that relator did not have fair notice of.
But the commissioner must consider “information about the qualifications of the personnel
employed by the applicant or license holder” in determining whether to revoke a license.
Minn. Stat. § 245A.04, subd. 6(a)(4) (2024). The revocation order explained this
requirement and cited the applicable statute.
Second, relator argues that DHS ’s failure to provide language interpreters during
inspections and interviews violated due-process requirements. An assignment of error in
a brief based on “mere assertion” and not supported by argument or authority is forfeited
unless prejudicial error is obvious on mere inspection.
Schoepke v. Alexander Smith & Sons Carpet Co., 187 N.W.2d 133, 135 (Minn. 1971).
Relator offers no legal authority supporting this due-process claim and prejudicial error is
not obvious upon mere inspection. Notably, the violations that led to relator’s license
revocation were based on relator’s record keeping and failure to follow terms of the
conditional license and not any interviews with or statements given by participants. This
argument is therefore forfeited.
9
aff’d, 10 N.W.3d 178 (Minn. 2024). An agency decision is arbitrary and capricious if the
agency:
(a) relied on factors not intended by the legislature; (b) entirely
failed to consider an important aspect of the problem;
(c) offered an explanation that runs counter to the evidence; or
(d) the decision is so implausible that it could not be explained
as a difference in view or the result of the agency’s expertise.

Citizens Advocating Responsible Dev. v. Kandiyohi Cnty. Bd. of Comm’rs, 713 N.W.2d
817, 832 (Minn. 2006). An agency’s conclusions are not arbitrary and capricious if there
is a “rational connection between the facts found and the choice made.”
In re Excess Surplus Status of Blue Cross & Blue Shield of Minn., 624 N.W.2d 264, 277
(Minn. 2001) (quotation omitted); see also In re Denial of Contested Case Hearing
Requests, 993 N.W.2d 627, 646-47 (Minn. 2023) (stating that the arbitrary-or-capricious
standard considers whether the agency has not “genuinely engaged in reasoned decision-
making” (quotations omitted)).
“With respect to factual findings made by the agency in its judicial capacity, if the
record contains substantial evidence supporting a factual finding, the agency’s decision
must be affirmed.” In re Excelsior Energy , Inc., 782 N.W.2d 282, 290 (Minn. App.
2010) (quotation omitted). Appellate courts must not substitute their judgment for that of
the administrative body when the agency’s findings are properly supported by evidence in
the record. In re Denial of Eller Media Co.’s Applications for Outdoor Advert. Device
Permits, 664 N.W.2d 1, 7 (Minn. 2003). So long as an agency engages in reasoned
decision-making, an appellate court “will affirm, even though it may have reached a
10
different conclusion had it been the fact[-]finder.” Cable Commc’ns Bd. v. Nor-West Cable
Commc’ns P’ship, 356 N.W.2d 658, 669 (Minn. 1984).
“The substantial-evidence standard addresses the reasonableness of what the agency
did on the basis of the evidence before it.” In re Expulsion of A.D., 883 N.W.2d 251, 259
(Minn. 2016) (quotation omitted); see also In re NorthMet Project Permit to Mine
Application, 959 N.W.2d 731, 749 (Minn. 2021) (describing that the substantial-evidence
analysis determines “whether the agency has adequately explained how it derived its
conclusion and whether that conclusion is reasonable” (quotation omitted)). A decision is
supported by substantial evidence when it is supported by “(1) such relevant evidence as a
reasonable mind might accept as adequate to support a conclusion; (2) more than a scintilla
of evidence; (3) more than some evidence; (4) more than any evidence; or (5) the evidence
considered in its entirety.” Cannon v. Minneapolis Police Dep’t, 783 N.W.2d 182, 189
(Minn. App. 2010) (quotation omitted). “The substantial evidence test requires a reviewing
court to evaluate the evidence relied upon by the agency in view of the entire record as
submitted.” Cable Commc’ns Bd., 356 N.W.2d at 668. Appellate courts defer to the
agency’s findings “regarding conflicts in testimony, the weight given to expert testimony
and the inferences to be drawn from testimony.” Cannon, 783 N.W.2d at 189 (quotation
omitted).
A. The commissioner’s determination that relator violated the participant
term is not arbitrary and capricious and is supported by substantial
evidence.

Relator first argues that the commissioner’s determination that relator violated the
participant term of the conditional license is arbitrary and capricious and not supported by
11
substantial evidence in the record. Relator contends that “admission” is an undefined term
and that the record reflects that relator merely “screened” new participants rather than
“admitting” them.7 Relator argues that the proper remedy for this alleged error is reversal
of the commissioner’s final decision.
The conditional license included a term that prohibited relator from admitting new
participants for a period of time. It stated:
You may not admit new participants to your program from the
date of this order until you have successfully demonstrated to
DHS compliance with the terms of the conditional license and
have maintained substantial compliance with all licensing
standards. At a minimum, you may not admit new participants
to your program for a period of six months from the date of this
conditional license. Prior to admitting any new participant
during the duration of the conditional license, you must notify
your licensor of the name and admission date of the new
participant.

7 To the extent that relator seeks to challenge the order of conditional license, that issue is
not properly before us . A conditional license must state the following in plain language:
“(1) the conditions that constitute a violation of the law or rule; (2) the specific law or rule
violated; (3) the time allowed to correct each violation; and (4) . . . the length and terms of
the conditional license, and the reasons for making the license conditional.”
Minn. Stat. § 245A.06, subd. 1 (2024). The license holder may request reconsideration of
the order of conditional license by notifying the commissioner in writing within ten
calendar days after the license holder receives the order, or ten calendar days after the
commissioner issues the order if it is issued through the provider hub. Id., subd. 4 (2024).
Although relator requested reconsideration of the participant term to have it removed from
the conditional license, it did not request further definition of the term within the
conditional license. Relator had the opportunity to challenge the terms when DHS issued,
and relator received, the conditional license. Accordingly, relator’s apparent challenge to
aspects of terms in the conditional license is not properly before us. Cf. In re Serenity Adult
Day Ctr., No. A23-0860, 2024 WL 1714237, at *4 (Minn. App. Apr. 17, 2024) (holding
that relator’s claim that conditional-license terms were not written in “plain language” was
not properly before the court).
12
Both the ALJ and the commissioner determined that relator violated this term.
Finding 34 of the ALJ ’s recommendation states, “The record also demonstrates [relator]
admitted new participants despite [DHS]’s prohibition pending a change in the Conditional
License. A new participant . . . was admitted June 1 and continued attending the facility
following the June Order.” The commissioner amended this finding by adding “[t]he
record further reflects that the [relator] repeatedly asked [DHS] about admitting new
participants to its program and [DHS] repeatedly told the [ relator] that adding new
participants was not permitted under the conditional license.” The commissioner also
amended one of the ALJ’s conclusions to say:
The most serious violation is [relator’s] failure to comply with
the term of the Conditional License which prohibited admitting
new participants. The significance of this violation is two-fold:
it was a blatant disregard of the license term, and [relator] was
not forthright in its communications with [DHS] about new
participants. Thus, [relator’s] behavior in relation to the new
participant issue is severe and, on its own, warrants the most
severe sanction.
(Emphasis added.)
DHS has promulgated a rule that governs “intake screening” for adult day care
centers like relator’s program.8 Minnesota Rule 9555.9700, subpart 1 (2023), states:

8 Relator relies on inapplicable law to support its argument that it was merely “screening”
prospective participants rather than admitting them. Relator relies on
Minn. Stat. § 245A.143, subds. 4-5 (2024), which governs the admission screening and
evaluation process for “family adult day service[]” facilities. These licenses are
“only . . . issued when the services are provided in the license holder’s primary residence,”
and “[t]he license holder may not serve more than eight adults at one time.” Id., subd. 1
(2024). Relator did not provide family adult day services but instead provided out-of-home
adult day care services to approximately 20-48 individuals.
13
Before admitting a participant, the center shall conduct an
intake screening to determine how or whether the center can
serve the individual, based on the center’s licensure, the
center’s policies and services, and the individual’s needs and
condition. If possible, the screening shall include an interview
with the participant and with the participant’ s caregiver. The
center shall notify the individual of the outcome no more than
five working days after the screening process begins.
This rule only contemplates that the adult day care service provider will conduct a
screening process “to determine how or whether the center can serve [an] individual.”
Minn. R. 9555.9700, subp. 1. It does not include actual provision s of services in the
screening process. Here, relator went beyond screening by providing services to P3
between June 1 and August 17. Additionally, evidence that relator sought to bill P3 for
services provided suggests that this person had passed any screening phase and had been
admitted. And as the commissioner notes in its brief to our court, Minn. R. 9555.9700,
subp. 1, requires the center to “notify the individual of the outcome no more than five
working days after the screening process begins.” Nothing in the record reflects that relator
provided such notification, and even if it did, P3 continued to receive services as if he had
been admitted. This evidence supports the commissioner’s determination that relator
admitted P3 in violation of the participant term.
DHS had also previously cited relator for admitting seven participants to the
program in violation of the participant term, and relator did not exercise its right to request
reconsideration of that determination. See Minn. Stat. § 245A.06, subd. 2(a) (Supp. 2025).
This evidence also supports the commissioner’s determination that relator violated the
participant term.
14
Ultimately, the commissioner concluded that DHS justifiably revoked the license
because relator violated the participant term of the conditional license. The
commissioner’s findings are supported by substantial evidence in the record and
demonstrate that relator failed to satisfy the requirements of the conditional license. The
record also reflects that the commissioner’s decision was neither arbitrary nor capricious.
Because we conclude that the commissioner’s decision is not arbitrary or capricious
and is supported by substantial evidence, we need not reach relator’s second argument that
the commissioner’s decision that relator violated ten licensing requirements is based on an
error of law and unsupported by substantial evidence. As described above, the
commissioner determined that violation of the participant term alone warranted revocation.
“[O]n appeal error is never presumed. It must be made to appear affirmatively before there
can be reversal. . . . [and] the burden of showing error rests upon the one who relies upon
it.” Waters v. Fiebelkorn, 13 N.W.2d 461, 464-65 (Minn. 1944); see also
In re Decision to Deny Petitions for a Contested Case Hearing, 924 N.W.2d 638, 643
(Minn. App. 2019) (applying Waters in the administrative-law context), rev. denied (Minn.
Apr. 24, 2019). Relator does not dispute the commissioner’s amended conclusion of law
addressing the participant term. Nor does relator offer any legal authority establishing that
violation of a conditional-license term, like the participant term, is insufficient grounds to
support revocation. Although the commissioner had multiple reasons for revoking relator’s
license, we need only address and affirm on one of those grounds if it is sufficient to support
the commissioner’s final decision. Cf. Minn. Stat. § 245A.07, subd. 1(a) (authorizing the
commissioner to revoke a license when a “license holder does not comply with applicable
15
law or rule”); Cable Commc’ns Bd., 356 N.W.2d at 669 (“If an administrative agency
engages in reasoned decision-making, [appellate courts] will affirm . . . .”). Because we
conclude that the commissioner’s determination that relator violated the participant term
was not error, that is sufficient grounds for us to affirm the commissioner’s decision such
that we need not address relator’s second argument.
B. The commissioner’s nature, severity, chronicity, and effect analysis
under Minn. Stat. § 245A.07, subd. 1(a), was not affected by an error of
law.
Relator next argues that the commissioner did not conduct a nature, severity, and
chronicity, and effect analysis sufficient to satisfy the requirements of
Minn. Stat. § 245A.07, subd. 1(a). Specifically, relator contends that the statute requires
the commissioner to make a finding of actual harm or an “imminent risk” of harm.
Minnesota Statutes section 245A.07, subdivision 1(a), requires the commissioner to
“consider the nature, chronicity, or severity of the violation of law or rule and the effect of
the violation on the health, safety, or rights of persons served by the program” when
imposing sanctions under this chapter. Because relator disputes the commissioner’s
application of the statute, this issue poses a question of law which we review de novo.
Yaggie v. Schmidt, 855 N.W.2d 769, 771 (Minn. App. 2014).
The commissioner recognized her duty under Minn. Stat. § 245A.07, subd. 1(a).
The commissioner struck the ALJ’s conclusion that DHS overstated the nature, chronicity,
and severity of relator’s violations. The commissioner then noted that the statute “does not
require a showing from [DHS] proving that persons served in a licensed facility were
harmed or injured.” The commissioner explained that “[a] program operating with too
16
many participants creates a myriad of dangers to the health, safety, or rights of persons
served by the program.” Further elaborating this point, the commissioner stated that relator
placed its participants “at a greater risk of harm” by ignoring the participant term, operating
its program over its allotted capacity, and acting “outside of the applicable laws and rules
intended to provide appropriate services to vulnerable adults and protect them from harm.”
Neither the Minnesota Supreme Court nor our court has ever decided whether
Minn. Stat. § 245A.07, subd. 1(a), requires a court to make a finding of actual harm. We
have stated, although in a nonprecedential decision, that “[i]t is not necessary that one or
more residents actually suffers harm because of relators’ non-compliance.”
In re Leon Hanson–GaMacann, Inc., No. A12-2253, 2013 WL 5508250, at *4 (Minn. App.
Oct. 7, 2013) (emphasis added) (applying Minn. Stat. § 245A.07, subd. 1(a)), rev. denied
(Minn. Dec. 17, 2023).9 We acknowledged that procedural and record-keeping violations
“may make it impossible to know whether residents are receiving proper care.” Id.
Although not binding on our decision, we find the reasoning persuasive here. The
participant term in relator’s conditional license related to the health, safety, and rights of
participants because it helped ensure r elator corrected issues in the program and met the
needs of current participants before it added new ones.
Similarly supporting this conclusion is an appellate court’s practice of extending
“judicial deference . . . to an agency decision-maker in the interpretation of statutes that the
agency is charged with administering and enforcing.”

9 We may cite nonprecedential opinions of this court for their persuasive value. See Minn.
R. Civ. App. P. 136.01, subd. 1(c).
17
Mattice v. Minn. Prop. Ins. Placement, 655 N.W.2d 336, 340 (Minn. App. 2002)
(quotation omitted); see also Minn. Stat. §§ 245A.01, .02, subd. 5 (2024) (identifying
chapter 245A as the “Human Services Licensing Act” and defining “commissioner” to
mean the commissioner of human services). An appellate court may defer to an agency’s
reasonable interpretation of a statute when its language is ambiguous.
Denial of Contested Case Hearing Requests, 993 N.W.2d at 646. To the extent the statute
is ambiguous, we defer. Based on our decision in Leon and our deference to agency
interpretation of certain statutes, we conclude that the commissioner did not misapply
Minn. Stat. § 245A.07, subd. 1(a), when it determined that relator’s violation of the
participant term had a negative effect on the “health, safety, or rights of persons served in
the program” without finding actual harm or an “imminent risk” of harm. This
determination is also supported by substantial evidence in the record.
Affirmed.