Jennissen v. City of Bloomington, 913 N.W.2d 456

In 2014–2015 Bloomington began transitioning from an "open collection" system (residents contract individually with licensed haulers) to "organized collection" (municipality contracts for collection by a single hauler or hauler group) and executed a contract for organized collection in December 2015.
Residents (appellants) proposed a charter amendment requiring voter approval before the City could implement organized solid-waste collection; the City refused to place it on the ballot, citing state-law preemption under Minn. Stat. § 115A.94.
Appellants sued; the district court and Minnesota Court of Appeals held § 115A.94 field-preempted the subject, so the charter amendment could not be submitted; the Minnesota Supreme Court granted review.
Section 115A.94 prescribes procedures for municipalities that choose to organize collection (notice, negotiation period with licensed collectors, or creation of an Organized Collection Options Committee (OCOC), public hearings, and a six-month delay before implementation), and includes subdivision 6 stating the authority is optional and “in addition to” other law, including home rule charters.
The sole legal question before the Court was whether § 115A.94 field-preempted municipal charter amendments regulating the process by which a city organizes solid-waste collection.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Minn. Stat. § 115A.94 field-preempts a charter amendment requiring voter approval before organized collection	Jennissen argued the charter amendment supplements local process and is permitted because § 115A.94 sets minimum procedures and preserves home-rule authority	City argued § 115A.94 occupied the field of regulating the process for organizing collection, leaving no room for charter changes	Court held no field preemption: § 115A.94 prescribes minimum procedures but does not exclusively occupy the field and expressly preserves other municipal authority

Bicking v. City of Minneapolis, 891 N.W.2d 304 (Minn. 2017) (framework on municipal preemption doctrines)
City of Morris v. Sax Invs., Inc., 749 N.W.2d 1 (Minn. 2008) (state law can limit municipal powers; preemption principles)
Mangold Midwest Co. v. Village of Richfield, 143 N.W.2d 813 (Minn. 1966) (articulated the "occupation of the field" / Mangold factors for field preemption)
Swanson v. Brewster, 784 N.W.2d 264 (Minn. 2010) (statutory interpretation principles; legislative intent)
Hegseth v. Am. Fam. Mut. Ins. Grp., 877 N.W.2d 191 (Minn. 2016) (court ordinarily will not consider arguments raised first by amicus)