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. . . spending decisions. In fact, the Court has made clear that "this presumption necessarily makes the seope of review of such governmental decision-making extremely narrow and a reviewing court should overrule a legislative determination that a particular expenditure is made for a public purpose only if that determination is manifestly arbitrary and capricious." Accordingly, as discussed above, the question of what constitutes a public purpose is largely a matter of eity council discretion. City authority With regard to the "authority test," a Minnesota municipal corporation has only such powers as are expressly conferred upon it by statute or its charter, or necessarily implied there from. In looking at the question of city authority, a distinction exists between eharter cities and statutory cities. Many home rule charter cities have an "all powers" provision, which reads something like "A city shall have all powers which may now or hereafter be possible for a municipal corporation in this state to exercise in harmony with the constitution of this state and of the United States," This broad grant of power under city charters has been interpreted as including "all those powers which are generally reeognized as powers which may properly be given to and be exercised by, munieipal corporations." State ex reI Zien v. City of Duluth. 134 Minn. 355, 159 N.W. 792 (1916). In eonstruing municipal charter authority, the Minnesota Supreme Court in City ofSt. Paul v. Whidby. 295 Minn, 129,136203 N.W.2d 823, 827 (1972) (citing Park v. City of Duluth 134 Minn. 296, 298,159 N.W. 627, 628 (1916)), enunciated the parameters of such authority: "Municipal corporations are ereated by state law. , , their legislative authority is conferred upon them by the constitution and the laws of the state and, as to matters of munieipal concem, they have all the legislative power possessed by the Legislature of the state, save as such power is expressly or implicitly withheld. . ." Aceordingly, for a charter city with an "all powers" clause, the scope of municipal authority is probably greater than that allowed for statutory cities. With regard to statutory cities, municipal authority has to be found in the statutes or be necessarily implied from that statutory authority. The question of what constitutes a valid implied power is the subject of some debate and ereates much of the "gray area" assoeiated with the analysis of particular expenditure practices. The remainder of this memorandum will not specifically differentiate between charter city authority and statutory city authority. However, individual cities should pay partieular attention to the fact that on the authority question, charter cities may be able to argue a greater levcl of municipal discretion, Employee Recognition Events The League of Minnesota Cities has often been asked whether it is valid to spend municipal funds on employee recognition events. The League has historieally taken the position that cities ean 8ponsor and pay for employee recognition programs if they are structured so that they 3