City of Brainerd v. Brainerd Investments Partnership
2013 Minn. LEXIS 140
| Minn. | 2013Background
- Brainerd City council expanded College Drive, funded partly by special assessments.
- CLC petitioned to fund the project, asserting it owned at least 35% of frontage.
- State cannot be bound by assessments, but petition threshold depends on ownership, not payment obligation.
- District court and court of appeals held CLC is an “owner” under 429.031(1)(f) and validly petitioned.
- Supreme Court held the State is an owner under the plain language, so the petition by CLC is valid.
- Dissent argued the State is not an owner and the petition was invalid.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State is an “owner” under 429.031(1)(f). | Anda: State cannot be an owner. | City/CLC: State is an owner under plain language. | Yes, State is an owner; petition valid. |
| If State is not an owner, is the petition valid and/or four-fifths vote required? | Anda: petition invalid; four-fifths required. | City/CLC: petition valid under 35% petition rule. | Not applicable since State deemed an owner; petition upheld. |
| Should extrinsic sources be used to interpret 429.031(1)(f)? | Anda: rely on extrinsic sources to show not an owner. | City/CLC: use plain language; no extrinsic intent. | Extrinsic sources not controlling; plain language governs. |
Key Cases Cited
- Premier Bank v. Becker Dev., LLC, 785 N.W.2d 753 (Minn. 2010) (agrees not to add words to statute; look to context)
- State v. Carufel, 783 N.W.2d 539 (Minn. 2010) (statutory ambiguity assessment in context)
- Am. Family Ins. Grp. v. Schroedl, 616 N.W.2d 273 (Minn. 2000) (interpretation when statute language clear; avoid extrinsic sources)