Great River Energy v. David D. Swedzinski, 2015 Minn. LEXIS 108

Great River Energy sought to condemn an 8.86-acre easement across the Tauers’ 218.85-acre parcel for a high-voltage transmission line under Minn. Stat. § 216E.12.4; Tauers elected to compel a fee purchase of their entire contiguous, commercially viable land under the Buy-the-Farm statute.
District court limited its analysis to the statute’s requirements (contiguity, commercial viability, ownership) and did not conduct a broader reasonableness review.
Great River argued for a totality-of-the-circumstances reasonableness analysis, including the relative size of the election to the easement and other factors not in the statute.
Tauers’ election satisfied the statute’s explicit criteria: the land is contiguous, commercially viable, and wholly owned in an undivided fee.
Court of Appeals affirmed; Supreme Court granted review and held that the statute forecloses extra-statutory considerations and affirmed the district court’s analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Buy-the-Farm requires a totality-of-circumstances reasonableness review.	Great River argues for additional factors beyond statute.	Tauers argue statute controls; no extra factors allowed.	No totality review; statute governs.
Whether prior cases require reasonableness analysis beyond statute.	Great River cites Aasand and Williams for broader review.	Statutory language supersedes broader tests; those dicta do not apply.	Past cases do not require extra-statutory analysis.

Cooperative Power Ass’n v. Aasand, 288 N.W.2d 697 (Minn. 1980) (reasonableness tied to commercial viability under then-current statute)
Northern States Power Co. v. Williams, 343 N.W.2d 627 (Minn. 1984) ( dicta on reasonableness; timber exclusion shown not to impose broader test)
Minn. West Nat. Gas? (no—use Aleckson), 831 N.W.2d 303 (Minn. 2013) (related to minimum compensation; not directly governing election reasonableness)