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<br />
<br />SERIES
<br />
<br />.f an ordinance 1\.... :
<br />. !Y!Inn Stat.
<br />s. 1-5 ~1988) (1987 ~,.
<br />10). This enabling statute.
<br />the problems and financial
<br />by the 1986 closing of an- '
<br />e park in the City, Lyndale ;
<br />
<br />sed the proposed ordinan
<br />cil. ce
<br />oun meetings in Septe ;
<br />m. -.
<br />989. Arcadia and its coun.f
<br />:;e.d the ordinance at each "
<br />'dinance nevertheless \Vas
<br />1e effective on December
<br />
<br />official purpose is stated '
<br />
<br />~culiar nature and prob-
<br />by the closure or conver_
<br />:n-ed home parks, the City
<br />.t the public health, safety
<br />tare will be promoted by
<br />nsation to displaced res i-
<br />rks. The purpose of this
<br />uire park owners to pay
<br />Its reasonable relocation
<br />'laSers of manufactured
<br />lay additional compensa-
<br />) the authority granted
<br />ta Statutes, Section
<br />
<br />City Ord. 89-57 (codified
<br />nn. City Code Art. VI,
<br />1ce generally requires a
<br />a displaced resident the
<br />elocating a mobile home
<br />cated within a 25-mile
<br />Jeing closed. If a resi-
<br />" the resident may ten-
<br />chaser of the park and
<br />
<br />arely moved once placed in
<br />igh cost and difficulty of
<br />nobile home owner wishes
<br />orne is usually sold in place
<br />ntinues to rent the pad on
<br />ated. When a park closes,
<br />1e and the ability to sell a
<br />: dramatically. Thus, resi.
<br />II or most of the value in
<br />oark owner chooses to sell
<br />different and likely more
<br />
<br />ARCADIA DEVELOP. v. CITY OF BLOOMINGTON
<br />. Cite as 552 N.W.2d 281 (MJun.App. 1996)
<br />.: . compensation equal to the amount of matter of law. Minn. R. Civ. P. 56.03.
<br />- ~; assessed value of the home. To Wh~. the material facts are not in disP.ute: a
<br />~J>cl:, a park owner's investment, the ordi- reVlewmg court need not defer to the district
<br />a-v---haS a "cap," which limits the "total court's application of the law. Hubred v.
<br />::nsation to be paid to displaced resi- Control Da1a Corp., 442 N.W.2d 308, 310
<br />dents by the park owner and purchaser" to (Minn.1989).
<br />" percent of the purchase price of the park. [1, 2] Statutes and local ordIDances are
<br />In May 1992, Arcadia entered into a pur- presumed valid and will not be declared un-
<br />chaSe agreement with Wal-Mart, Inc. The . constitutional unless clearly shown to be so.
<br />agreement was subject to several contingen- City of St. Paul v~ Kekedakis, 293 Minn. 334,
<br />des, including reduction in the purchase 336, 199 N.W.2d 151, 153 (1972); State v.
<br />price by the amount it would cost to comply EUis, 476 N.W.2d 662, 664 (Minn.App.1991),
<br />with the ordinance and approval of certain review denied (MinD. Dec. 13, 1991). The
<br />zoning changes that had been requested by party challenging a statute or ordinance's
<br />City staff. Those. zoning changes were sub- constitutionality has the burden of proof.
<br />sequently approved by the City council based EUis, 476 N.W.2d at 664.
<br />on Wal-Mart and Arcadia's agreement to
<br />abide by a number of conditions, including
<br />compliance with the relocation ordinance.
<br />Collins Park was closed on February 22,
<br />1994. Because there were ample vacancies
<br />within a 25-mile radius of the park, mobile
<br />homes that physically could be moved were
<br />moved. Only five of the 90 homes remaining
<br />in the park at the time of closing had to be
<br />acquired. Arcadia sold the property to Wal-
<br />Mart for $2,338,842.66" after deducting relo-
<br />cation expenses of $363,128.71.
<br />Arcadia brought this action in September
<br />1994. It claims that as a result of the City's
<br />adoption of the ordinance, it lost potential
<br />buyers and was forced to sell the property
<br />for substantially less than its market value.
<br />
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<br />ISSUES
<br />I. Did the district court err in granting
<br />summary judgment to the City on Arcadia's
<br />takings claim?
<br />II. Did the district court err in granting
<br />swmnary judgment to the City on Arcadia's
<br />substantive due process and equal protection
<br />claims?
<br />III. Did the district court err in granting
<br />summary judgment to the City on Mildred
<br />Collins's claim of intentional infliction of emo-
<br />tional distress?
<br />
<br />ANALYSIS
<br />Sununary judgment is proper when there
<br />are no genuine issues of material fact and
<br />either party is entitled to judgment as a
<br />
<br />Minn. 285
<br />
<br />.L
<br />
<br />Takings analyses often involve factual in-
<br />quiries that make summary judgment inap-
<br />propriate. Nevertheless, a court may eval-
<br />uate the legal significance of undisputed
<br />material facts without forcing parties to
<br />triaL See 767 Third Ave. Assocs. v. Unit-
<br />ed States, 48 F.3d - 1575, 1580 (Fed.Cir.
<br />1995) ("Even though a regulatory taking
<br />analysis is normally ad hoc and fact-inten-
<br />sive, the [defendant] may still be entitled
<br />to judgment as a matter of law."). Be-
<br />cause Arcadia's takings claim rests not on
<br />genuine issues of material fact, but on Ar-
<br />cadia's disagreement with the applicable Ie-
<br />.gal standards and analyses to apply, it is
<br />amenable to summary judgment. See Out-
<br />doOT Sys., Inc. v. City of Mesa, 997 F.2d
<br />604, 618 (9th Cir.1993); Chesapeake Out-
<br />doOT Enters., Inc. v. MayOT & City Coun-
<br />cil of Baltimore, 89 Md.App. 54, 597 A.2d
<br />503, 512-13 (1991).
<br />
<br />1. Takings Analysis Under the United
<br />States Constitution
<br />
<br />The Takings Clause states: "[N]or shall
<br />private property be taken for public use,
<br />without just compensation." U.S. Const.
<br />Amend. V. Its purpose is "to bar Govern-
<br />ment from forcing some people alone to bear
<br />public burdens which, in all fairness and
<br />justice, should be borne by the public as a
<br />whole." Armstrong v. United States, 364
<br />U.S. 40, 49, 80 S.Ct. 1563, 1569, 4 L.Ed.2d
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