County of Dakota v. Cameron
2013 Minn. LEXIS 708
| Minn. | 2013Background
- Dakota County condemned Cameron's commercial property in Inver Grove Heights for a highway-reconstruction project.
- Cameron sought minimum compensation under Minn.Stat. § 117.187 to purchase a comparable property in the community, potentially exceeding appraised value.
- District court used the Robert Trail property in Inver Grove Heights as the comparable property and computed damages by adjusting for building size.
- The district court awarded Cameron $997,055.84 in damages and $161,964.50 in attorney fees under Minn.Stat. § 117.031(a).
- Court of Appeals affirmed the district court’s ruling; Cameron petitioned for Supreme Court review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Robert Trail property is a comparable property | Cameron: Robert Trail is comparable in the community. | County: Robert Trail is comparable and located in Inver Grove Heights. | Robert Trail is a comparable property in the same community. |
| Definition of 'community' under § 117.187 | Cameron urges a narrow trade-area definition. | County urges broader city/town-based scope. | Community means an identifiable locality with social/governmental identity; Inver Grove Heights qualifies. |
| Requirement that a comparable be available for purchase at the time of taking | Comparable must be available for purchase at the time of taking. | Availability is not required; comparables are evaluated by likeness for valuation. | No availability-at-taking requirement; existing comparable properties suffice. |
| How to calculate damages when comparables differ in size | Damages may reflect cost to construct a new building of comparable size. | Use value-based adjustment of the comparable; avoid new-construction surcharges. | District court’s size-adjusted, value-based approach reasonable; upheld. |
| Appropriate standard for attorney-fee award under § 117.031(a) | Lodestar-based review should apply to determine reasonableness. | Partial reliance on results obtained; discretionary adjustments allowed. | Lodestar method governs; district court did not abuse discretion in fee award. |
Key Cases Cited
- Premier Bank v. Becker Dev., LLC, 785 N.W.2d 753 (Minn. 2010) (interpretation of statutory plain language and ambiguity)
- Lietz v. N. States Power Co., 718 N.W.2d 865 (Minn. 2006) (statutory construction when multiple interpretations exist)
- Larson v. State, 790 N.W.2d 700 (Minn. 2010) (plain meaning when only one reasonable interpretation exists)
- McNeilus Truck & Mfg., Inc. v. Cnty. of Dodge, 705 N.W.2d 410 (Minn. 2005) (use of comparable properties in valuation)
- Cont’l Retail, LLC v. Cnty. of Hennepin, 801 N.W.2d 395 (Minn. 2011) (treatment of actual market transactions in valuation)