City of North Oaks v. Sarpal, 797 N.W.2d 18

City of North Oaks sued Dr. Rajbir S. Sarpal and Dr. Carol L. Sarpal for violating the 30-foot side-yard setback and encroaching on a NOHOA trail easement.
Sarpals asserted equitable estoppel, alleging reliance on a City employee's misrepresentation and the City’s approval of a permit based on that misrepresentation.
District court found equitable estoppel and dismissed the City’s claims; court of appeals affirmed; Minnesota Supreme Court granted review and reversed.
Relevant restrictions: 30-foot setback codified in North Oaks, Minn., Code § 151.050, and a 15/15 foot trail easement over the northern and western property edges.
Sarpals obtained a City-supplied survey (dated 2003) used to depict a proposed house and 30-foot setback; shed location was plotted from the proposed house rather than lot lines.
After construction, the City notified encroachment on setback and trail easement; variance denied; extension to move the shed granted but not complied with; City filed suit in 2008.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper standard of review for equitable estoppel after a bench trial	Sarpal argues de novo review is appropriate under certain authorities for estoppel findings.	City argues abuse-of-discretion review governs equitable determinations after bench trials.	Abuse-of-discretion applies to district court’s equitable estoppel ruling after a bench trial.
Whether the City’s conduct was wrongful conduct for estoppel	Sarpal contends the City’s actions (providing/approving the flawed survey) were wrongful.	City asserts actions were simple mistakes, not wrongful conduct warranting estoppel.	City’s actions were not wrongful conduct; estoppel not established.
Four elements for equitable estoppel against government entities	Sarpal satisfies wrongful conduct, reasonable reliance, unique expenditure, and balancing equities.	City disputes wrongful conduct and proper reliance as to the first element.	First element not satisfied; estoppel not warranted, so other elements need not be addressed.
Whether the City could be equitably estopped from enforcing the zoning ordinance	Sarpal seeks relief based on reliance on the survey and permit.	City maintains no permissible estoppel against government here due to lack of culpable conduct.	District court abused its discretion in applying estoppel; estoppel reversed.

Mesaba Aviation Div. of Halvorson of Duluth, Inc. v. Cnty. of Itasca, 258 N.W.2d 877 (Minn. 1977) (wrongful conduct required for estoppel against government)
Kmart Corp. v. County of Stearns, 710 N.W.2d 761 (Minn. 2006) (good-faith but erroneous interpretation not enough for wrongful conduct)
Bond v. Comm’r of Revenue, 691 N.W.2d 831 (Minn. 2005) (inadvertence or simple error not sufficient for wrongful conduct)
L & H Transport, Inc. v. Drew Agency, Inc., 403 N.W.2d 223 (Minn. 1987) (estoppel factual vs. legal question framework; context for review standard)
Lilyerd v. Carlson, 499 N.W.2d 803 (Minn. 1993) (abuse-of-discretion standard applied to equitable determinations in bench trials)
Halla Nursery, Inc. v. City of Chanhassen, 781 N.W.2d 880 (Minn. 2010) (distinction on de novo vs. abuse-of-discretion in equitable decisions)