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Blaine/Atlantic Funding, LLC v. City of Blaine
0:23-cv-00172
D. Minnesota
Oct 18, 2024
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Background

  • Blaine/Atlantic Funding, LLC (B/A) sought to redevelop a commercially-zoned property in Blaine, Minnesota, into a 196-unit high-density apartment complex, requiring an amendment to the city's comprehensive plan and rezoning approval.
  • The City Council initially seemed supportive during planning workshops but ultimately denied the applications to amend the plan and rezone the property, citing incompatibility with surrounding uses, excessive size, negative neighborhood impacts, and traffic concerns.
  • B/A sold the property after litigation ensued, having been unable to proceed with its planned project.
  • B/A alleged disparate treatment, pointing to approval of similar projects by the City in recent years, and claimed an Equal Protection Clause violation as a class-of-one.
  • Both parties filed cross-motions for summary judgment on the constitutional claim; the City offered insufficient evidence supporting its motion, and the court found material disputed facts precluding summary judgment for B/A.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Did the City's denial of B/A's land-use applications violate the Equal Protection Clause as a class-of-one? City treated B/A differently from similarly situated developers without rational basis, as shown by approvals of comparably situated projects. Approved projects were not similarly situated; differences in location, neighborhood, required approvals, and public opposition justify the denial. Both parties' motions denied: City failed to present adequate evidence for summary judgment; disputed facts remain about comparability for B/A's claim.

Key Cases Cited

  • Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
  • Village of Willowbrook v. Olech, 528 U.S. 562 (established class-of-one theory under Equal Protection)
  • Barstad v. Murray Cnty., 420 F.3d 880 (class-of-one equal protection claims in zoning)
  • Krenik v. Cnty. of Le Sueur, 47 F.3d 953 (summary judgment evidentiary requirements)
  • Allegheny Pittsburgh Coal Co. v. Cnty. Comm’n of Webster Cnty., W.V., 488 U.S. 336 (similarly situated comparators in equal protection)
  • Anderson v. Douglas Cnty., 4 F.3d 574 (requirement for comparator similarity in equal protection claims)
Read the full case

Case Details

Case Name: Blaine/Atlantic Funding, LLC v. City of Blaine
Court Name: District Court, D. Minnesota
Date Published: Oct 18, 2024
Docket Number: 0:23-cv-00172
Court Abbreviation: D. Minnesota