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. | 2012Background
- 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)
