OPINION
SHORT, Judge.
Loyd appeals from a decision by the Commissioner of the Minnesota Department of Agriculture reinstating a cease and desist order against Loyd's urban lawn care service. Loyd argues he is not subject to the licensing requirements of Minn.Stat. §§ 18B.33 and 18C.415, because he utilizes only nonrestricted-use pesticides and prepackaged fertilizers.
FACTS
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