Minnesota Duty Disabled Association (MNDDA), a Minnesota nonprofit corporation v. State of Minnesota Public Employees Retirement Association (PERA)

This opinion is nonprecedential except as provided by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
A25-2076

Minnesota Duty Disabled Association (MNDDA),
a Minnesota nonprofit corporation,
Appellant,

vs.

State of Minnesota Public Employees Retirement Association (PERA),
Respondent.

Filed August 24, 2026
Affirmed
Beane, Judge

Ramsey County District Court
File No. 62-CV-23-5420

Marshall H. Tanick, Meyer Njus Tanick Linder Robbins, P.A., Minneapolis, Minnesota
(for appellant)

Keith Ellison, Attorney General, Frank Langan, Assistant Attorney General, St. Paul,
Minnesota (for respondent)

Considered and decided by Beane, Presiding Judge; Smith, Tracy M., Judge; and
Schmidt, Judge.
NONPRECEDENTIAL OPINION
BEANE, Judge
Appellant Minnesota Duty Disabled Association (MNDDA) challenges the district
court’s summary-judgment dismissal of its claims against respondent Minnesota Public

2
Employees Retirement Association (PERA), arguing that the district court made various
errors of law. Because we discern no error in the district court’s decision, we affirm.
FACTS
PERA is a state agency that administers several public-sector employee retirement
plans, including the police and fire plan, which provides for payment of disability benefits
to police officers and firefighters who become occupationally disabled. See Minn. Stat.
§§ 353.01-.95 (2024). A plan member who is injured in the line of duty may be entitled to
receive duty-disability benefits while they remain occupationally disabled. Minn. Stat.
§§ 353.031, .656, subd. 1. A duty disability is defined as a condition that is the direct result
of “the performance of inherently dangerous duties that are specific to the positions covered
by” the police and fire plan and that is expected to prevent a member from performing the
normal duties of their position for at least 12 months. Minn. Stat. § 353.01, subd. 41.
As relevant here, to qualify for duty-disability benefits, a plan member must not be
covered by a separate plan,
1 must meet the statutory definition of duty disability, and must
have their application approved by the police and fire plan’s executive director. Minn. Stat.
§ 353.656, subd. 1(a). Eligibility for duty-disability benefits is not subject to a minimum
years-of-service requirement. See id. (b). Those receiving duty -disability benefits receive
60% of their salary and an additional 3% for each year of service beyond 20. Id. (a). A
person receiving duty- disability benefits must reapply for those benefits periodically—

1 Those separate plans are addressed under Minnesota Statutes sections 353.6511 and
353.6512, respectively, and are not at issue in this appeal.

3
every year for the first five years they receive benefits, and every three years thereafter. 2
Minn. Stat. § 353.031, subd. 8.
By definition, individuals receiving duty- disability benefits are unable to perform
the normal duties of a police officer or firefighter, see Minn. Stat. § 353.01, subd. 41, but
they may be capable of being otherwise employed and may continue receiving benefits
while also earning income from other employment. The income a person receiving duty-
disability benefits earns from other employment may offset the amount of their benefit
payment if that income exceeds certain thresholds. See Minn. Stat. § 353.656, subd. 4.
Duty-disability benefits were originally not subject to offset requirements, but the
legislature added an offset provision in 1971. See Minn. Stat. § 353.57 (1957); 1971 Minn.
Laws ch. 297, § 3, at 532-33. The legislature then amended the offset provision in 1994
and again in 2023. See 1994 Minn. Laws ch. 463, § 1, at 311-12; 2023 Minn. Laws ch. 48,
§ 27, at 702. The 2023 amendments are the subject of this dispute. Under the amended
offset provisions, now found in Minnesota Statutes section 353.656, subdivision 4(c)(1)
and (2), all duty-disability-benefit recipients who are required to reapply for benefits on or
after July 1, 2023, are potentially subject to two offsets.
3 Minn. Stat. § 353.656, subd. 4(c).

2 The reapplication requirement —like the offset provisions described below —was
amended in 2023. 2023 Minn. Laws ch. 48, § 17, at 690. The previous version of the statute
authorized PERA’s executive director, “at reasonable times,” to require duty-disability
recipients to “submit proof of the continuance of the disability claimed.” Minn. Stat.
§ 353.031, subd. 8(b) (2022). In the district court, MNDDA argued that PERA could not
require MNDDA’s members to comply with the amended reapplication requirement, but
MNDDA has not raised that argument on appeal.

3 The first offset, applied to duty-disability recipients who have served fewer than 20 years,
reduces their benefit payment based on the member’s contribution rate to the fund and that

4
The effect of the amendments to these offset provisions is to increase the amount by which
a recipient’s reemployment income reduces their duty-disability benefit.
In October 2023, MNDDA, an organization comprising individuals currently
receiving duty-disability benefits (members), sued PERA seeking to enjoin enforcement of
several of the 2023 amendments , including the offset provisions in section 353.656
described above and certain other amendments to section 353.031 that are not pertinent to
this appeal. MNDDA alleged that the amendments unconstitutionally impair the
contractual relationship between PERA and MNDDA’s members, that promissory estoppel
precludes PERA from enforcing the new provisions, and that the new provisions violate its
members’ constitutional rights to procedural and substantive due process.
MNDDA moved for a temporary injunction, seeking a stay of enforcement of the
amended provisions pending the lawsuit. The district court granted MNDDA’s motion as
to the offset provisions in section 353.656. This court reversed the injunction and remanded
the case to the district court. Minn. Duty Disabled Ass’n (MNDDA) v. Pub. Emps. Ret.
Ass’n, No. A23-1924, 2024 WL 4113102, at *1 (Minn. App. Sep. 9, 2024), rev. denied
(Minn. Nov. 27, 2024).

member’s length of service or 50% of their yearly reemployment earnings, whichever is
less. Minn. Stat. § 353.656, subd. 4(c)(1). The second offset takes effect when the
combined total of a disabled plan member’s duty-disability benefits and reemployment
earnings exceeds 100% of an active member’s salary in a similar position. Id. ,
subd. 4(c)(2). In that circumstance, the second offset reduces the member’s benefit
payment by “one dollar for every two dollars” that their total monthly earnings exceed the
base monthly salary, up to 125% of the base monthly salary, and “one dollar for each dollar
by which the sum exceeds 125 percent of the base monthly salary.” Id.

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After completing discovery, the parties filed cross-motions for summary judgment.
The district court granted PERA’s motion and dismissed all of MNDDA’s claims.
MNDDA appeals.
DECISION
We review a district court’s summary-judgment decision to “determine whether the
district court properly applied the law and whether there are genuine issues of material fact
that preclude summary judgment.” Riverview Muir Doran, LLC v. JADT Dev. Grp., LLC,
790 N.W.2d 167, 170 (Minn. 2010). We review a district court’s application of the law
de novo. Dykes v. Sukup Mfg. Co., 781 N.W.2d 578, 581 (Minn. 2010). “The party that
asserts a constitutional challenge to the exercise of legislative authority bears a heavy
burden to prevail on that claim.” Clark v. City of St. Paul, 934 N.W.2d 334, 345 (Minn.
2019).
MNDDA’s arguments on appeal focus on the enforceability of the amended offset
provisions against its members. To that end, MNDDA argues that the district court should
have denied PERA’s motion for summary judgment, and instead granted MNDDA’s
motion, because (1) the 2023 amendments to the offset provisions unconstitutionally
impair the contractual relationship between PERA and MNDDA’s members;
(2) promissory estoppel precludes PERA from enforcing the amended offset provisions
against MNDDA’s members; and (3) the 2023 amendments are unconstitutional as applied
to MNDDA’s members because the y violate its members’ rights to procedural and
substantive due process.

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I.
We first address MNDDA’s argument that the district court erred by dismissing its
contract-impairment claim rather than granting summary judgment in MNDDA’s favor.
Under both the federal and state constitutions, the state is “prohibited from passing laws
that impair contractual obligations.” Id. (citing U.S. Const. art. I, § 10; Minn. Const. art. I,
§ 11). Appellate courts analyze a contract- impairment claim using a three-part test. First,
we “consider whether the challenged legislation operates ‘as a substantial impairment of a
contractual obligation.’” Id. (quoting Christensen v. Minneapolis Mun. Emps. Ret. Bd., 331
N.W.2d 740, 750 (Minn. 1983)). If no contractual right exists, then we need not address
whether the legislation would impair such a right. AFSCME Councils 6, 14, 65 & 96,
AFL-CIO v. Sundquist, 338 N.W.2d 560, 567 (Minn. 1983). Second, if the legislation is
found to substantially impair a contractual obligation, we “consider whether there is ‘a
significant and legitimate public purpose behind the legislation.’” Clark, 934 N.W.2d at
345 (quoting Jacobsen v. Anheuser-Busch, Inc., 392 N.W.2d 868, 872 (Minn. 1986)). And
third, we “review the legislation in light of the identified public purpose ‘to see whether
the adjustment of the rights and liabilities of the contracting parties is based upon
reasonable conditions and is of a character appropriate to the public purpose justifying the
law’s adoption.’” Id. (quoting Jacobsen, 392 N.W.2d at 872).
To prevail on its contract-impairment claim, MNDDA therefore must first establish
the existence of a contractual obligation between its members and PERA. MNDDA relies
on two theories to support its argument that such an obligation exists here: first, that the
language of the statute itself creates a vested right to the calculation of reemployment-

7
income offsets under the version of the statute in effect when a recipient of duty-disability
benefits became disabled, and second, that PERA has an implied-in-law obligation created
by promissory estoppel not to reduce the amount of a recipient’s duty-disability benefit.
We address each of these theories in turn.
A.
MNDDA contends that the “benefits of duty disabled members vested when they
became disabled” and that, by virtue of that vesting, its members have a contractual right
to have their benefits calculated according to the pre-2023-amendment version of the
statute. “A contractual obligation may be created by a state statute when the language and
circumstances evince a legislative intent to create private rights of a contractual nature
enforceable against the State.” Meriwether Minn. Land & Timber, LLC v. State, 818
N.W.2d 557, 564 (Minn. App. 2012) (quotation omitted), rev. denied (Minn. Sep. 25,
2012). But “[a] party asserting the creation of a contract must overcome the well-
established presumption that ‘a law is not intended to create private contractual or vested
rights but merely declares a policy to be pursued until the legislature shall ordain
otherwise.’” Peterson v. Humphrey, 381 N.W.2d 472, 475 (Minn. App. 1986) (quoting
Nat’l R.R. Passenger Corp. v. Atchison, Topeka & Santa Fe Ry. Co., 470 U.S. 451, 466
(1985)), rev. denied (Minn. Apr. 11, 1986). We require a “clear indication that the
legislature intends to bind itself contractually.” Meriwether Minn. Land & Timber, 818
N.W.2d at 564 (quoting Nat’l R.R. Passenger Corp., 470 U.S. at 465-66).
The district court concluded, and we agree, that MNDDA’s members do not possess
a contractual right created by statute to a specific formula for calculating reemployment-

8
income offsets. MNDDA has not directed us to any language of the relevant statutory
provisions from which we could conclude that the legislature intended to create a contract
that would entitle individuals who receive duty-disability benefits to have their
reemployment-income offsets calculated according to a particular formula. Our review of
the statute also has not identified any language that would overcome the well-established
presumption that laws are not intended to create vested private rights.
The only language in Minnesota Statutes chapter 353 that bears specifically on
whether the benefits it creates—including duty-disability benefits—are “vested” does not
support MNDDA’s position. Minnesota Statutes section 353.01 provides a list of
definitions that apply to the entirety of chapter 353, which includes the provisions
governing duty-disability benefits generally and the reemployment-income offset
calculations in particular. Minn. Stat. § 353.01, subd. 1. The statute defines “vesting” as
“obtaining a nonforfeitable entitlement to an annuity or benefit from a retirement plan
administered by the association by having credit for sufficient allowable service.” Id.,
subd. 47(a). And “benefit” refers to a survivorship benefit or “a monthly disability benefit
paid or payable by the fund to a member who is totally and permanently disabled.” Id.,
subd. 27. A “total and permanent disability” is one that prevents a person from “engag[ing]
in any substantial gainful activity.” Id. , subd. 19 (emphasis added) . Under the plan, an
eligible member may receive duty-disability benefits “during the period of disability,”
whereas a member who has a “total and permanent” duty disability is entitled to receive a
disability benefit “for life.” Minn. Stat. § 353.656, subds. 1(a), 1a(a). Thus, the legislature
expressly included retirement and total-and-permanent-disability benefits, but not duty -

9
disability benefits, in the statutory definition of vesting. We presume such omissions to be
intentional. See State v. Caldwell, 803 N.W.2d 373, 383 (Minn. 2011) (stating the
“inference that any omissions in a statute are intentional”). We therefore see nothing in this
statutory language that could overcome the presumption that the legislature did not intend
to create a vested right for duty-disability-benefit recipients to have their reemployment-
income offsets calculated according to a particular formula.
To convince us otherwise, MNDDA contends that we should reject two aspects of
the district court’s analysis of the statute. First, the district court explained that the
legislature’s inclusion in chapter 353 of a definition of “vesting” that expressly references
categories of benefits other than duty-disability benefits cuts against MNDDA’s argument
that its members’ benefits are vested . And second, the district court reasoned that the
statutory requirement for recipients of duty- disability benefits to reapply periodically
indicates that those benefits are not a permanent entitlement and are therefore not vested.
MNDDA argues that the district court’s analysis was wrong because neither of these
aspects of the statute should prevent a conclusion that its members’ duty-disability benefits
are vested. But MNDDA’s argument is unavailing. It is not enough to say that these aspects
of the statute do not preclude a determination that MNDDA’s members have a statutorily
created contractual right to have their reemployment-income offsets calculated based on
the pre-2023 version of the statute. MNDDA has the burden to point to something in the
statute sufficient to overcome the well-established presumption against the creation of such
rights, and it has not done so.

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B.
MNDDA alternatively argues that its members have a n implied-in-law contractual
right, based on the doctrine of promissory estoppel, to have their reemployment-income
offsets calculated according to the pre- 2023-amendment version of the statute.
“Promissory estoppel is an equitable doctrine that implies a contract in law where
none exists in fact.” Martens v. Minn. Mining & Mfg. Co., 616 N.W.2d 732, 746 (Minn.
2000) (quotation omitted). Promissory estoppel “may be applied against the state to the
extent that justice requires.” Christensen, 331 N.W.2d at 749. But “it is an extraordinarily
rare case in which the equitable remedy of promissory estoppel should preclude state
action.” Meriwether Minn. Land & Timber , 818 N.W.2d at 565. For promissory estoppel
to apply, the plaintiff bears “a heavy burden of proof” to show that its interest in justice
outweighs “the public interest frustrated by estoppel.” Brown v. Minn. Dep’t of Pub.
Welfare, 368 N.W.2d 906, 910 (Minn. 1985).
Promissory estoppel requires the party asserting its application to prove that (1) “a
clear and definite promise was made,” (2) “the promisor intended to induce reliance and
the promisee in fact relied to his or her detriment,” and (3) “the promise must be enforced
to prevent injustice.” Martens, 616 N.W.2d at 746. “In applying promissory estoppel, two
factors must be kept in mind: (1) What has been promised by the state? and (2) to what
degree and to what aspects of the promise has there been reasonable reliance on the part of
the employee?” Christensen, 331 N.W.2d at 749.
Here, MNDDA has not established that a clear and definite promise was made to its
members that the statutory provision governing the calculation of reemployment-income

11
offsets would remain unchanged. As an initial matter, the enforceability of such a promise,
if it were made, would necessarily be cast into doubt by the “well-established presumption
that a law is not intended to create private contractual or vested rights but merely declares
a policy to be pursued until the legislature shall ordain otherwise.” Anderson v. State, 435
N.W.2d 74, 80 (Minn. App. 1989) (quotation omitted). For the same reasons explained in
our analysis above, we are not persuaded that MNDDA has overcome the presumption that
statutes should generally not be read to constitute promises that are enforceable under
principles of contract law.
Rather than pointing to a clear and definite promise in support of its claim, MNDDA
contends that “no such ‘clear and definite’ promise was found in Christensen, but the
estoppel doctrine nonetheless applied there.” But that is not quite true. Christensen
involved a challenge to the legislature’s decision to establish an age at which employees
retiring from city service were eligible to receive their pensions. 331 N.W.2d at 742-43.
Christensen, who had already retired and was receiving pension benefits, was rendered
ineligible for those benefits because he had not yet attained the new retirement-eligibility
age. Id. at 743. The supreme court concluded, based on promissory estoppel, that
Christensen had a protectable entitlement to continue receiving his pension benefits. Id. at
749. In doing so, the Christensen court observed that promissory estoppel requires
considering “[w]hat has been promised by the state.” Id. The court then went on to explain
that “[w]hat [the state] has promised and what its employees have relied on, and what,
therefore, the law will enforce, is a pension program, the terms of which are protectable
subject to reasonable legislative modification from time to time.” Id. In other words, the

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promise was the existence of the pension program, and Christensen’s pension benefits
could not be eliminated once he had retired and started receiving those benefits.
Christensen therefore does not relieve MNDDA of its obligation to identify an enforceable
promise in support of its promissory-estoppel theory.
We also conclude that Christensen is distinguishable from the circumstances
presented here, in part because it involved the wholesale elimination of Christensen’s
promised pension benefit. Here, the legislature did not terminate duty-disability benefits
for individuals who were already determined to be eligible and are receiving those benefits.
It also did not reduce the duty-disability benefit amount that was being paid to any recipient
at the time the amended statute went into effect. Instead, the legislature has modified the
reemployment-income offset calculation prospectively by providing that it will affect the
amount of a recipient’s duty-disability benefit beginning when they are next required to
reapply for those benefits. See Minn. Stat. § 353.031, subd. 8; 2023 Minn. Laws ch. 48,
§ 17, at 690.
In its reply brief, MNDDA contends that its members received letters from PERA
regarding their eligibility for duty- disability benefits containing the “clear and definite”
language that “[t]his is the actual monthly amount that will be paid for the duration of your
disability.” But this language is not a clear and definite promise enforceable by promissory
estoppel. For one thing, nothing in the letters containing this language states the amount of
the duty-disability-benefit payment the recipient can expect. That information is provided
in a second, separate letter that also instructs the recipient to notify PERA if they are
employed because failing to report income “can result in substantial benefit overpayments”

13
and advises the recipient that “[t]he Minnesota Legislature or the federal government may
change the statutes, rules and regulations governing PERA at any time.” We discern no
clear and definite promise in these letters that the amount of a recipient’s duty-disability
benefit subject to a reemployment-income offset will never change.
Even if we were persuaded that MNDDA’s members were promised that the
reemployment-income offset calculation would not change, MNDDA also cannot establish
reliance. The reliance element of a promissory-estoppel claim has two components:
(1) whether “the promisor intended to induce reliance” on the promise, and (2) whether
“the promisee in fact relied [on the promise] to his or her detriment.” Meriwether Minn.
Land & Timber, 818 N.W.2d at 565 (quotation omitted). The promisee’s reliance on the
alleged promise must be reasonable. Nicollet Restoration, Inc. v. City of St. Paul, 533
N.W.2d 845, 848 (Minn. 1995).
MNDDA’s sole argument regarding the state’s intent to induce reliance, relying
again on Christensen, is that we should presume that the state offered duty-disability
benefits to induce people to accept employment as police officers and firefighters. The
Christensen court reasoned that “[i]n the realities of the modern employment marketplace,
the state reasonably expects its promise of a retirement program to induce persons to accept
and remain in public employment, and persons are so induced, and injustice can be avoided
only by enforcement of that promise.” 331 N.W.2d at 749. But even in concluding that the
state’s promise of a “retirement program” was enforceable by promissory estoppel, the
Christensen court acknowledged that the specific terms of the program must be “subject to
reasonable legislative modification from time to time.” Id. ; see also id. (stating that the

14
enforceable promise of a retirement program “contains an implied condition that the terms
are subject to modification under the state’s police power”). For this reason, the logic of
Christensen cannot bear the weight MNDDA seeks to place on it. Assuming for argument’s
sake that the duty-disability-benefit program is analogous to the retirement program
considered in Christensen, the analysis in that case does not support a conclusion that the
state is estopped from modifying the terms of the program, such as the formula for
calculating reemployment-income offsets that MNDDA challenges here. And MNDDA
has not identified any other basis on which we could conclude that the state intended to
induce duty-disability-benefit recipients to rely on specific reemployment-income offset
calculations to their detriment.
Moreover, even if MNDDA could show that PERA intended to induce reliance on
a specific reemployment-income offset calculation, MNDDA would also need to establish
that its members actually relied on that calculation to their detriment and that such reliance
was reasonable. MNDDA’s reliance argument emphasizes evidence in the summary-
judgment record that its members relied on the availability of disability benefits generally
in deciding to become police officers and firefighters. Even assuming all that evidence is
true, it does not establish that MNDDA members relied on any specific calculation of
reemployment-income offsets. And if MNDDA could show that its members relied on
PERA’s continued use of a specific statutory offset-calculation formula, MNDDA has not
established the reasonableness of such reliance, particularly given the letters its members
received from PERA explaining that the statutes governing duty-disability benefits could
change at any time.

15
Because MNDDA’s promissory-estoppel theory fails on both the clear-and-definite-
promise and reliance elements, we conclude MNDDA cannot rely on a contractual
obligation implied by operation of promissory estoppel to establish the first element of its
contract-impairment claim.4
Thus, having concluded that MNDDA has not established the existence of a
contractual obligation that could be impaired by the 2023 amendments to the statutory
provisions governing the calculation of reemployment-income offsets, we need not address
the remaining elements of MNDDA’s contract-impairment claim. See Jennissen v. City of
Bloomington, 938 N.W.2d 808, 817 (Minn. 2020); Sundquist, 338 N.W.2d at 567.
II.
We next consider MNDDA’s claim s that the 2023 amendments to the statutory
provisions governing the calculation of reemployment-income offsets violate its members’
constitutional rights to procedural and substantive due process. Both procedural and
substantive due-process claims present issues of law we review de novo. Sawh v. City of
Lino Lakes, 823 N.W.2d 627, 632 (Minn. 2012); In re Individual 35W Bridge Litig., 806
N.W.2d 820, 829 (Minn. 2011).

4 MNDDA also contends—separate from its contract-impairment theory—that promissory
estoppel bars PERA from decreasing the amounts of the duty-disability benefits paid to
MNDDA’s members. MNDDA’s arguments as to these theories overlap significantly, and
it relies heavily on Christensen in support of both. Because our promissory-estoppel
analysis is the same under either theory, we do not separately address MNDDA’s argument
that the district court erred by dismissing its promissory-estoppel claim.

16
A.
MNDDA argues that PERA violated its members’ rights to procedural due process
by “creating legislation that would reduce their benefits through increased offsets” without
inviting them to join the “stakeholder” group. To determine whether a challenged
government action violated an individual’s procedural-due-process rights, we must first
consider “whether the government has deprived the individual of a protected life, liberty,
or property interest.” Sawh, 823 N.W.2d at 632. If so, we then consider whether the
government followed a constitutionally sufficient procedure, which requires notice and an
opportunity to be heard. Id.
MNDDA’s argument here fails at the first step of this test. For one thing, MNDDA’s
members were not deprived of a protected property interest. To have a protected property
interest in a statutory right, that right must be “vested.” Schatz v. Interfaith Care Ctr., 811
N.W.2d 643, 657-58 (Minn. 2012); see also Christensen, 331 N.W.2d at 747-48 (declining
invitation to characterize statutorily created pension as a “property interest”). For reasons
we have already explained, MNDDA has not established the existence of a vested statutory
right here. Moreover, PERA’s actions in proposing certain statutory amendments to the
legislature did not deprive MNDDA’s members of anything. PERA did not amend the
statute; the legislature did. To the extent MNDDA has asserted its members were deprived
of their interest in continuing to receive duty- disability benefits without being subject to
the amended reemployment-income offset calculations, that deprivation was the result of
the legislative process . Even if MNDDA’s members were entitled to notice and an
opportunity to be heard, they had the opportunity to participate in the legislative process,

17
and the record presented here establishes that some MNDDA members actually did so .
Consequently, we conclude, as the district court did, that MNDDA’s procedural-due-
process claim fails as a matter of law.
B.
MNDDA also contends that the 2023 amendments to the statutory provisions
governing the calculation of reemployment-income offsets violate its members’
substantive due-process rights. The doctrine of substantive due process “protects
individuals from certain arbitrary, wrongful government actions regardless of the fairness
of the procedures used to implement them.” In re Linehan, 594 N.W.2d 867, 872 (Minn.
1999) (quotations omitted). “When analyzing whether legislation violates substantive due
process rights, we apply the rational basis test unless a fundamental right is involved.” See
Individual 35W Bridge Litig., 806 N.W.2d at 830. Legislation will be upheld on rational-
basis review if (1) “the objective of the law is permissible,” (2) “the means chosen to
achieve that objective are reasonable,” and (3) “the legislative body did not act arbitrarily
or capriciously in enacting the law.” Fletcher Props., Inc. v. City of Minneapolis, 9 47
N.W.2d 1, 10 (Minn. 2020) (citing Boutin v. LaFleur, 591 N.W.2d 711, 717-18 (Minn.
1999)). In an as- applied challenge to the constitutionality of a statute, appellate courts
“presume statutes to be constitutional and exercise the power to declare a statute
unconstitutional with extreme caution and only when absolutely necessary.” Individual
35W Bridge Litig., 806 N.W.2d at 829 (quotation omitted). “The party challenging the
constitutionality of a statute must demonstrate that the statute is unconstitutional beyond a
reasonable doubt.” Id.

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MNDDA rests its argument on the alleged arbitrariness of the legislature’s decision
to subject MNDDA’s members to the amended reemployment-income offset calculations
as of the next time they are required to reapply for their duty-disability benefits. MNDDA
emphasizes its position that the resulting loss of income to its members will unfairly burden
its members for the benefit of other participants in the police and fire plan. But although
MNDDA is adamant that the legislature should have taken a different approach, it does not
appear to question that the legislature had a legitimate purpose in seeking to ensure the
fiscal health of the police and fire plan. MNDDA has not demonstrated that the legislature’s
decision to adjust reemployment-income offsets was an unreasonable means of supporting
the fiscal health of the police and fire plan. We therefore conclude that MNDDA has not
carried its heavy burden to establish that the 2023 amendments to the statutory provisions
governing the calculation of reemployment-income offsets are unconstitutional as applied
to its members.
Affirmed.