County of Washington v. City of Oak Park Heights
818 N.W.2d 533
Minn.2012Background
- County sought reimbursement from City for alleged sewer and water overcharges for the Washington County Law Enforcement Center.
- City policy required a three-step appeal process culminating in City Council final determinations.
- County's appeal to City Council was denied; Council adopted findings and denied reimbursement in Oct. 2009.
- County filed district court action for unjust enrichment; City moved for summary judgment asserting exclusive certiorari review under ch. 606.
- District court denied summary judgment; court of appeals affirmed; this Court granted review.
- Court holds the City’s denial was a quasi-judicial decision and certiorari under ch. 606 is the exclusive review remedy; district court lacked jurisdiction to hear unjust enrichment claim and case is remanded to enter judgment for City.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether certiorari is the exclusive remedy for review of the City’s denial | County argues district court has jurisdiction; certiorari is exclusive for quasi-judicial decisions | City contends only certiorari under ch. 606 may review quasi-judicial municipal decisions | Yes; certiorari under ch. 606 is exclusive for quasi-judicial denials. |
| Whether the City Council’s denial was quasi-judicial | County asserts actions resemble private provision of services; not quasi-judicial | City asserts decision involved investigation, applied standards, and binding ruling | Yes; three-factor quasi-judicial test satisfied; decision subject to certiorari. |
| Whether the proprietary-governmental conduct distinction applies | County urges distinction to avoid certiorari review | City argues adherence to quasi-judicial framework, not enterprise type | Rejected; focus is on nature of decision, not enterprise; certiorari governs quasi-judicial decisions. |
Key Cases Cited
- State v. Bd. of Pub. Works of City of Red Wing, 134 Minn. 204, 158 N.W. 977 (Minn. 1916) (certiorari review for municipal quasi-judicial proceedings)
- Haymes, 444 N.W.2d 257 (Minn. 1989) (limits on judiciary reviewing municipal decisions; quasi-judicial standard)
- Dead Lake Ass'n, Inc., 695 N.W.2d 134 (Minn. 2005) (certiorari exclusive for county decisions in land-use/permits context)
- Willis v. County of Sherburne, 555 N.W.2d 277 (Minn. 1996) (certiorari is exclusive review for municipal termination, underlying claims reviewed for validity)
- City of Shorewood v. Metropolitan Waste Control Comm’n, 533 N.W.2d 402 (Minn. 1995) (certiorari exclusive mechanism for waste-control commission costs/estimates)