A question legislative librarians are often asked in the waning days of legislative sessions is, "Can the Minnesota Legislature pass bills on the final day of a regular legislative session?". And each year, we research the question yet again to make sure we are providing the correct answer.
Minnesota's Constitution, Article 4, Section 21 states in part, "No bill shall be passed by either house upon the day prescribed for adjournment." When that section of the constitution was written, the constitution also established that the Minnesota Legislature would meet in regular session in odd-numbered years. With a single-year session, the "day prescribed for adjournment" was apparent.
Things changed in 1972 when Minnesota voters approved a proposed constitutional amendment to establish flexible, biennial sessions. (Minnesota House Public Information Services published an informative article in 1991 about the history of flexible sessions in Minnesota.) With the inaugural biennial legislative session in 1973/1974, for the first time in state history there was a "final" day in the first year and a "final" day in the second year. Were both days considered the "day prescribed for adjournment" per the state constitution? Or was the final day of the second year the official adjournment day? The question was answered by the Minnesota Supreme Court in its 1974 decision, State v. Hoppe: "... May 21, 1973 was not the day of final adjournment ... but was merely a temporary interim adjournment during the unitary biennial legislative session".
One final note. Since the advent of flexible sessions, the Legislature has met in regular session in each year of the biennium. But Article 4 Section 12 of the state's constitution does not mandate yearly sessions. It's possible that some future legislature will meet only one time during a biennium and that there will once again be a single, final "day prescribed for adjournment".