Harstad v. City of Woodbury

Summary

The Minnesota Supreme Court held that Minn. Stat. § 462.358, subd. 2a, does not authorize the City of Woodbury to condition subdivision approval on payment of an infrastructure charge for future roadway improvements. The court concluded that the charge was not permissible financial security and that the statute's authority to enter development contracts did not independently authorize the charge. The court affirmed the decision of the Minnesota Court of Appeals.

Holdings

1. Minn. Stat. § 462.358, subd. 2a, does not expressly authorize a statutory city to impose Woodbury's infrastructure charge as a condition of subdivision approval.
2. Woodbury's infrastructure charge is not a cash deposit or other financial security authorized by Minn. Stat. § 462.358, subd. 2a.
3. The authority to execute development contracts and impose other requirements reasonably related to subdivision regulations does not authorize a city to require an infrastructure charge that the statute otherwise does not permit.

Questions Presented

1. Whether Minn. Stat. § 462.358, subd. 2a, expressly authorizes a statutory city to condition subdivision approval on payment of an infrastructure charge for future roadway improvements.
2. Whether the statutory provisions authorizing financial security for required improvements permit Woodbury's nonrefundable infrastructure charge.
3. Whether the authority to execute development contracts and impose other requirements reasonably related to subdivision regulations authorizes the infrastructure charge.

Disposition

affirmed