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. Cable Communications Bd. v. Nor-West Cable Communications P'ship, 356 N.W.2d 658, 668 (Minn. 1984). II.

We have said that a substantial basis in the record to support an agency's determination exists where, considering the evidence in its entirety, there is relevant evidence that a reasonable person would accept as adequate to support a conclusion; the substantial-evidence standard requires more than “a scintilla of evidence” and more than “some” or “any” evidence. Cable Commc'ns Bd. v. Nor–West Cable Commc'ns P'ship, 356 N.W.2d 658, 668 (Minn.1984) (citing Reserve Mining Co. v. Herbst, 256 N.W.2d 808, 825 (Minn.1977) ).

This broad definition generally requires an agency to use MAPA's notice-and-comment procedures to promulgate "interpretive rules[,]" meaning "those that ‘make specific the law enforced or administered by the agency.’ " In re PERA , 820 N.W.2d at 570 (quoting Cable Comms. Bd. v. Nor-West Cable Comms. P'ship , 356 N.W.2d 658, 667 (Minn. 1984) ). The board argues that the March 2019 emails were not rules, but case-by-case determinations.

Appellate courts will reverse agency decisions "only when they reflect an error of law, the findings are arbitrary and capricious, or the findings are unsupported by substantial evidence." Cable Commc'ns Bd. v. Nor-W. Cable Commc'ns P'ship, 356 N.W.2d 658, 668 (Minn. 1984). Ordinarily, agency decisions receive a presumption of correctness, and appellate courts defer to the agency's expertise and special knowledge in its field.

In setting forth the standard for reviewing agency decisions, both the Minnesota Supreme Court and this court have applied a "hard look" analysis borrowed from federal caselaw. See, e.g. , CARD , 713 N.W.2d at 831-32 ; Cable Commc'ns Bd. v. Nor-W. Cable Commc'ns P’ship , 356 N.W.2d 658, 669 (Minn. 1984) ; Herbst , 256 N.W.2d at 825 (quoting Greater Bos. Tel. Corp. v. F.C.C. , 444 F.2d 841, 851-52 (D.C. Cir. 1970) ); In re Reissuance of NPDES/SDS Permit to U.S. Steel Corp. , 937 N.W.2d 770, 786-87 (Minn. App. 2019) ( U.S. Steel) ; In re Enbridge Energy, Ltd. P’ship , 930 N.W.2d 12, 22 (Minn. App. 2019). Under that analysis, a court inquires whether there is a "combination of danger signals which suggest the agency has not taken a ‘hard look’ at the salient problems and the decision lacks articulated standards and reflective findings."

"Agency decisions are reversed only when they reflect an error of law, the findings are arbitrary and capricious, or the findings are unsupported by substantial evidence." Cable Commc'ns Bd. v. Nor-West Cable Commc'ns P'ship, 356 N.W.2d 658, 668 (Minn. 1984); see also Rodne v. Comm'r of Human Servs., 547 N.W.2d 440, 444-45 (Minn. App. 1996) ("On certiorari appeal from a quasi-judicial agency decision that is not subject to the administrative procedure act, we inspect the record to review '. . . whether the order or determination in a particular case was arbitrary, oppressive, unreasonable, fraudulent, under an erroneous theory of law, or without any evidence to support it.'" (quoting Dietz v. Dodge Cty., 487 N.W.2d 237, 239 (Minn. 1992))).

Rather, they provide a procedure to be followed when another statute grants such a right. Cable Communications Board v. Nor-West Cable Communications Partnership, 356 N.W.2d 658, 665 (Minn. 1984). Relators cite Minn.Stat. §§ 141.25 and 141.29 as statutory authority requiring a contested case hearing.

Rather it provides the procedure to be followed when another statute grants such a right. Cable Communications Board v. Nor-West Cable Communications Partnership, 356 N.W.2d 658, 665 (Minn. 1984). A contested case proceeding may also be required by the constitution.

Rostamkhani v. City of St. Paul, 645 N.W.2d 479, 483 (Minn.App. 2002) (citing Cable Commc'ns Bd. v. Nor-West Cable Commc'ns P'ship, 356 N.W.2d 658, 668 (Minn. 1984)). Generally, "[a]dministrative agency decisions enjoy a presumption of correctness."

An agency decision is unsupported by substantial evidence if, in view of the entire record, "there is a combination of danger signals which suggest the agency has not taken a hard look at the salient problems and the decision lacks articulated standards and reflective findings." Cable Commc'ns Bd. v. Nor-West Cable Commc'ns P’ship , 356 N.W.2d 658, 669 (Minn. 1984) (quotations and citations omitted). Here, the parties agree that Pfoser was qualified to receive MA-LTC, that the LSS pooled trust is a qualified trust under 42 U.S.C. § 1396p(d)(4)(C), and that Pfoser transferred funds to the LSS pooled trust at the age of 65.