On May 18, 2026, the Minnesota Court of Appeals issued a significant decision in Minnesota Coalition on Government Information v. City of Minneapolis, et al., reversing the district court’s grant of summary judgment and holding that the phrase “disciplinary action” under section 13.43 of the Minnesota Government Data Practices Act (MGDPA) is not limited to measures that punish or penalize employees. Rather, the Court concluded that “disciplinary action” also encompasses corrective actions imposed by a government employer in response to a complaint or charge against an employee.
For Human Resources and Labor Relations professionals in Minnesota’s public sector, this ruling has an immediate and practical impact for how you classify, document, and disclose employee performance interventions, which includes the commonly used “coaching.” A coaching or corrective action of similar nature may now be subject to public disclosure under the MGDPA as the “final disposition of any disciplinary action” if proper precautions are not taken.
In Minnesota Coalition, the Court looked at Minneapolis’s own internal documents and determined that those undermined the City’s position that a coaching was not discipline. In fact, the coaching documents expressly told employees they were receiving the coaching “as discipline” for sustained violations of City policy. This spotlights the importance of consistency in corrective actions. Namely, that corrective actions contain the appropriate terminology and the presentation be in line with what the employer formally intends it to be.
This decision also highlights the importance of defining terms in a collective bargaining agreement. The collective bargaining agreement between Minneapolis and the Minneapolis Police Federation did not define “discipline” or “disciplinary action” leaving the Court with only the relatively ambiguous statutory definition to guide its decision.
Bottom Line
Updating corrective action documentation is of vital importance to ensure no corrective actions meant to be a coaching or reminder of your policies now turn to formal disciplinary action subject to disclosure under the MGDPA. The Court’s decision, your applicable collective bargaining agreements, and the unions you negotiate with can result in complicated hurdles to overcome in ensuring compliance. Accordingly, you should consult experienced labor counsel to ensure proper steps are taken. If you have questions regarding the recent decision and what your jurisdiction needs to do next, please contact our office for additional guidance.