The Minnesota Supreme Court’s decision in State v. City of Minneapolis addressed the application of the Minnesota Environmental Rights Act (MERA) to municipal land-use planning. The case involved a challenge to the City’s 2040 Comprehensive Plan, a framework for long-term urban development.
Under Minnesota law, municipalities are required to adopt comprehensive plans to guide land use and development. The City of Minneapolis’s 2040 Comprehensive Plan proposed eliminating single-family zoning and increasing permissible building density citywide. Smart Growth Minneapolis and other groups (Smart Growth) filed a complaint, arguing that the Plan violated MERA by likely causing materially adverse environmental effects.
The district court dismissed the complaint, concluding that comprehensive plans are exempt from environmental review under the Minnesota Environmental Policy Act (MEPA). The court of appeals affirmed. However, Smart Growth argued that MERA claims were independent of MEPA’s exemptions.
The Supreme Court addressed two key questions:
The Minnesota Supreme Court reversed the lower courts, holding that MERA claims are not barred by MEPA exemptions. Key findings included:
MERA’s Broad Scope: The court emphasized MERA’s “broad and comprehensive” language, which applies to “any conduct” likely to materially adversely affect the environment. The court clarified that administrative rules under MEPA do not limit MERA’s reach.
Causation Requirement: The court found that Smart Growth’s allegations, including increased stormwater runoff and reduced wildlife habitat, were sufficient to state a claim. It noted that MERA’s burden-shifting framework allows claims to proceed if plaintiffs plausibly allege a prima facie case of environmental harm.
Consistency Between MERA and MEPA: The court concluded that MERA and MEPA serve complementary purposes and can coexist without conflict. It rejected the argument that MERA claims undermine MEPA’s administrative framework.
The decision in State v. City of Minneapolis reaffirms MERA’s role in protecting Minnesota’s environment and clarifies its applicability to municipal land-use decisions. By allowing claims under MERA to proceed, the court ensures that environmental considerations remain integral to urban planning.
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