Yang v. Univ. of Minnesota (Feb. 2, 2026)

Case details
Full caption
Yang v. University of Minnesota
Country
United States
Jurisdiction
Minnesota (MN)
Court
Minnesota Supreme Court
Decided
Feb. 2, 2026
Disposition
Affirmed
Yang v. University of Minnesota, Not Reported in N.W. Rptr. (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 350882Only the Westlaw citation is currently available.NOTICE: THIS DECISION IS NONPRECEDENTIALEXCEPT AS PROVIDED BY MINN. R. CIV. APP.P. 136.01(1)(C) AND MINN. ST. SEC. 480A.08(3).Court of Appeals of Minnesota.Haishan YANG, Relator,v.UNIVERSITY OF MINNESOTA, Respondent.A25-1019|Filed February 2, 2026Office of Administrative Hearings File No. 25-0305-40725Considered and decided by Wheelock, Presiding Judge;Larkin, Judge; and Reyes, Judge.ORDER OPINIONPeter M. Reyes, Jr., Judge*1 BASED ON THE FILE, RECORD, ANDPROCEEDINGS, AND BECAUSE:1. Relator Haishan Yang filed a data practices complaintwith the Office of Administrative Hearings (OAH)1 againstrespondent University of Minnesota. See Minn. Stat. §13.085, subd. 2 (2024). He claimed violations of theMinnesota Government Data Practices Act (MGDPA), Minn.Stat. §§ 13.01-.991 (2024 & Supp. 2025).2. Relator's complaint focused on respondent's conduct duringa disciplinary process, which culminated in relator's expulsionfor use of artificial intelligence (AI) on an exam for hisdoctoral program. Relator alleged that, during the disciplinaryprocess, respondent: disclosed his disciplinary record andgrades to faculty; entered his exam questions into a generativeAI program; entered his exam answers into AI-detectionsoftware; falsified evidence; entered false statements intoevidence; and “[f]ail[ed] to ensure [the] accuracy and integrityof student disciplinary records.” Relator requested relief inthe form of “fines, an order requiring the university to correct[relator's] record, and a referral of responsible officials to theAttorney General's Office for criminal charges.”3. In May 2025, an administrative-law judge (ALJ) entered anorder dismissing relator's complaint. The ALJ determined that(1) the OAH did not have jurisdiction to overturn respondent'sdisciplinary decision; (2) relator's accuracy and completenesschallenges were outside the scope of Minn. Stat. § 13.085;(3) relator's request for damages was outside the scope ofMinn. Stat. § 13.085; and (4) relator had “not establishedthat probable cause supports his claims that [respondent]violated the MGDPA.” See Minn. Stat. § 13.085, subd. 3(a)(1) (requiring dismissal of MGDPA complaints that “do notpresent sufficient facts to believe that a violation of [theMGDPA] occurred”).4. Relator timely filed a petition for reconsideration pursuantto Minn. Stat. § 13.085, subd. 3(c). The chief ALJ reviewedthe petition and determined that the originally assigned ALJdid not make “a clear material error.” See id. The chiefALJ denied the petition and adopted the findings of fact andconclusions of law contained in the original dismissal order.The chief ALJ determined that “the bulk of the relief [relator]seeks is outside the scope of the action before this tribunal.”As to any claims that might be within the OAH's jurisdiction,the chief ALJ stated that “neither [relator's] assertions offactual error nor those of legal error are persuasive” primarilybecause relator's “application of legal authority” relied onirrelevant and inaccurate caselaw citations.5. The scope of this court's review is governed by theMinnesota Administrative Procedure Act (MAPA), Minn.Stat. §§ 14.001-.69 (2024 & Supp. 2025). See Minn.Stat. § 13.085, subd. 5(d) (explaining that MAPA definesscope of judicial review for MGDPA claims). This courtaffords an administrative agency's decision a presumptionof correctness, but we “may reverse or modify the decisionif the substantial rights of the petitioners may have beenprejudiced” because, as relevant here, the decision was“arbitrary or capricious.” Minn. Stat. § 14.69; see AnokaCounty v. L. Enf't Lab. Servs., Inc., 3 N.W.3d 586, 591 (Minn.2024).*2 6. “An agency decision is arbitrary and capricious if thereis no rational connection between the facts found and thechoice made.” Minn. Internship Ctr. v. Minn. Dep't of Educ.,996 N.W.2d 34, 52 (Minn. App. 2023) (quotation omitted),aff'd, 10 N.W.3d 178 (Minn. 2024). When applying thisstandard, appellate courts “consider whether a combination of
Yang v. University of Minnesota, Not Reported in N.W. Rptr. (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2danger signals suggests that the agency has not taken a hardlook at the salient problems and has not genuinely engaged inreasoned decision-making.” In re Denial of Contested CaseHearing Requests, 993 N.W.2d 627, 646-47 (Minn. 2023)(quotation omitted). “The party seeking review on appeal hasthe burden of proving that the agency decision meets” thecriteria for reversal. Mattice v. Minn. Prop. Ins. Placement,655 N.W.2d 336, 340 (Minn. App. 2002), rev. denied (Minn.Mar. 18, 2003).7. Relator challenges the orders of both the ALJ and the chiefALJ, arguing that the OAH acted arbitrarily and capriciouslyby (1) characterizing part of his complaint as a request forreview of respondent's disciplinary decision; (2) determiningthat his accuracy and completeness challenges were outsidethe scope of Minn. Stat. § 13.085; (3) characterizing part ofhis requested relief as monetary damages; (4) misapplyingcertain MGDPA provisions; and (5) determining that theinitial facts did not establish probable cause of an MGDPAviolation. Relator fails to support his claim that the OAH actedarbitrarily or capriciously for any of the five issues raised.8. For the first issue, relator notes that the chief ALJ didnot explicitly acknowledge the caselaw analysis presentedin relator's petition for reconsideration. But relator pointsto no legal precedent to support the assertion that a chiefALJ's order must discuss every argument presented ina petition for reconsideration. The statute also does notsupport that assertion. Rather, when considering a petitionfor reconsideration, the chief ALJ “must review the petitionand make a final ruling” within a certain time. Minn. Stat.§ 13.085, subd. 3(c). “If the chief [ALJ] determines thatthe assigned [ALJ] made a clear material error, [they] mustschedule the matter for a hearing ....” Id. The chief ALJ hereconsidered relator's petition and determined that the assignedALJ did not make a clear material error. We conclude thatthere is no danger signal, let alone a combination of dangersignals, to suggest that the OAH “did not take a ‘hard look’at the salient problems and did not genuinely engage inreasoned decision-making.” Hearing Requests, 993 N.W.2dat 653 (quotation omitted). We therefore conclude that theOAH did not act arbitrarily or capriciously by determiningthat part of relator's complaint sought disciplinary review.8. As to the other four issues, relator makes no relevant legalargument and cites no relevant legal authority. “Minnesotaappellate courts decline to reach an issue in the absence ofadequate briefing.” In re Civ. Commitment of Kropp, 895N.W.2d 647, 653 (Minn. App. 2017), rev. denied (Minn.June 20, 2017). Because relator failed to properly raise thesearguments before this court, we decline to exercise permissivereview of these issues.IT IS HEREBY ORDERED:1. The administrative-law judge's order is affirmed.2. Pursuant to Minn. R. Civ. App. P. 136.01, subd. 1(c), thisorder opinion is nonprecedential, except as law of the case,res judicata, or collateral estoppel.BY THE COURTAll CitationsNot Reported in N.W. Rptr., 2026 WL 350882Footnotes1The Office of Administrative Hearings was renamed the Court of Administrative Hearings, effective August1, 2025. 2025 Minn. Laws ch. 39, art. 2, § 17, at 1219 (amending Minn. Stat. § 14.48, subd. 1 (2024)).End of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
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