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In re the Appeal from the Final Order of the Board of Managers of the Bois De Sioux Watershed District
2012 Minn. App. LEXIS 75
Minn. Ct. App.
2012
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Background

  • Bois de Sioux Watershed District sought redetermination of benefits for Judicial Ditch No. 14 under Minn.Stat. § 103E.351.
  • Petition to circulate among landowners did not satisfy the petition prong of § 103E.351, subd. 1.
  • Minutes show a motion to appoint viewers but no record of a board motion, second, or vote on the statutory basis for redetermination.
  • The district court vacated the redetermination order after concluding the district lacked jurisdiction.
  • On appeal, the court affirmed, holding the district lacked jurisdiction because the board did not make the requisite determination.
  • The opinion notes the possibility of re-commencing redetermination proceedings if jurisdiction can be established.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Jurisdiction under §103E.351, subd. 1 Bois de Sioux asserts a board determination existed. Landowners argue no board action = no jurisdiction. Affirmed; district court did not err in vacating.
Remand vs. vacate Remand to district for further proceedings is appropriate. Remand unnecessary; jurisdiction must be established before proceeding. Not reached; affirmance confirms vacatur and notes reinitiation is possible after jurisdiction proves.

Key Cases Cited

  • State ex rel. Spurck v. Civil Serv. Bd., 226 Minn. 253 (1948) (void when decision lacks statutory power or exceeds it)
  • Johnson v. Steele Cnty., 240 Minn. 154 (1953) (jurisdictional prerequisites and strict compliance)
  • Hagen v. Cnty. of Martin, 253 Minn. 367 (1958) (validity depends on strict statutory compliance)
  • Robinette v. Price, 214 Minn. 521 (1943) (definition of jurisdiction and its limits)
  • Kulinski v. Medtronic Bio-Medicus, Inc., 577 N.W.2d 499 (Minn. 1998) (preclusive effect of void judgments due to lack of subject-matter jurisdiction)
  • Moore v. Moore, 734 N.W.2d 285 (Minn.App. 2007) (interpretation of jurisdiction-related concepts)
Read the full case

Case Details

Case Name: In re the Appeal from the Final Order of the Board of Managers of the Bois De Sioux Watershed District
Court Name: Court of Appeals of Minnesota
Date Published: Jul 23, 2012
Citation: 2012 Minn. App. LEXIS 75
Docket Number: No. A11-1875
Court Abbreviation: Minn. Ct. App.