City of Moorhead v. Red River Valley Cooperative Power Ass'n, 830 N.W.2d 32

City of Moorhead annexed Americana Estates (65 metered RRVC electric accounts) and condemned the territory under Minn.Stat. § 216B.47 to provide municipal electric service.
RRVC previously served Americana Estates; the district court appointed a three-member commission which awarded RRVC $307,214; the parties then pursued a jury trial under condemnation procedures.
Initial expert reports were exchanged by deadline; City used fair market value (FMV) approach, claiming $164,456 in damages; RRVC used the four statutory factors under § 216B.47, valuing $385,188.
District court granted RRVC partial summary judgment, instructing damages to include four statutory factors and excluding FMV evidence; City later served a revised expert report with new loss-revenue credit for deferred capital investment, which RRVC moved to exclude.
RRVC successfully moved to exclude the revised sections of the City’s report; a jury trial then awarded RRVC $339,865 in loss of revenue, plus stipulated amounts for the other three factors, totaling $385,311.
Courts of appeal affirmed, and the Supreme Court granted review to decide whether FMV can be used and whether exclusion of revised report was proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Damages standard under 216B.47	RRVC contends four statutory factors govern damages, not FMV.	City argues FMV can be used alongside the four factors.	Fair market value is not the exclusive measure; four statutory factors govern damages.
Use of revised expert report	RRVC argues the late revised report altered the calculation and breached discovery deadlines.	City contends the additions were relevant and discovery-efficient there was no prejudice.	District court did not abuse discretion in excluding the untimely revised sections.
Role of FMV as an 'other appropriate factor'	FMV could be an appropriate factor if it does not undermine the four statutorily mandated categories.	FMV should not override the statutory four-factor framework.	FMV may not be used to override the four statutory factors; evidence must align with § 216B.47.

City of Rochester v. People’s Coop. Power Ass’n, Inc., 483 N.W.2d 477 (Minn. 1992) (identical considerations for damages under § 216B.44(b) and § 216B.47)
Anda, 789 N.W.2d 860 (Minn. 2010) (liberal interpretation of just compensation; four-factor approach)
Moorhead Econ. Dev. Auth. v. Anda, 789 N.W.2d 860 (Minn. 2010) (affirms liberal application of just compensation and valuation standards)
State by Humphrey v. Strom, 493 N.W.2d 554 (Minn. 1992) (evidence relevant to price considerations in eminent domain)
Kroning v. State Farm Auto. Ins. Co., 567 N.W.2d 42 (Minn. 1997) (prejudice standard for evidentiary rulings on expert testimony)
Olson v. United States, 292 U.S. 246 (1934) (just compensation standard and value expectations in takings)
Minneapolis-San Paulo Sanitary Dist. v. Fitzpatrick, 277 N.W. 394 (Minn. 1937) (market value as baseline for compensation, with flexibility)
State ex rel. Ryan v. Dist. Court of Ramsey Cnty., 91 N.W. 300 (Minn. 1902) (constitutional limits on just compensation)