Posted by: Patricia Salkin | September 23, 2016

MN Supreme Court Holds District Court, Rather than Court of Appeals, Had Subject Matter Jurisdiction over § 1983 Claims Stemming from Zoning Decision

Mark Zweber owned a large parcel of undeveloped land in Credit River Township, located in Scott County. Zweber contacted County officials in April 2003 to develop a plan for the development of the parcel, which he named Liberty Creek. Among other things, Zweber and the County discussed where to locate roads within the subdivision and how to stem the flow of traffic into adjoining neighborhoods. The discussions resulted in the submission of Zweber’s 2006 preliminary plat application, which proposed to divide the parcel into 39 lots and 1 outlot. Despite the County Board’s approval of the final plat, Zweber did not proceed with the Liberty Creek development, and, in 2008, Zweber instead submitted to the County an application for a proposed re-subdivision of the parcel, then referred to as the Estates of Liberty Creek. However, based on the recommendation of the Planning Commission, the County Board denied the application.

Zweber brought a § 1983 civil rights action against County and Township, alleging that they had deprived him of his property without just compensation and had violated his equal protection rights. The District Court denied the summary judgment motion filed by County and Township, determining that it had subject matter jurisdiction over constitutional claims. The County and Township appealed, and the Court of Appeals reversed, finding Zweber was granted his petition for review. The Court concluded that it had exclusive jurisdiction over both of Zweber’s constitutional claims because the county’s decisions on the plat and re-subdivision applications were quasi-judicial and the constitutional claims were not “separate and distinct” from them. On appeal, the court noted that legislative decisions can be reviewed by filing a summons and complaint in district court; however, even if the decisions of the County were quasi-judicial, it was still possible that the district court would have jurisdiction to adjudicate the derivative constitutional claims pleaded in Zweber’s amended complaint.

The court further noted that while there was some overlap in the facts underlying Zweber’s constitutional claims and the County’s decisions on Zweber’s plat and re-subdivision applications, the presence of overlap was not enough; the claims themselves did not need to be completely separate and distinct for the district court to have jurisdiction over them. Here, the takings claim did not require an examination into the validity of the county’s decisions because it presupposed that the conditions placed on his plat application were valid. Similarly, Zweber’s equal-protection claim did not depend upon the validity of the County’s quasi-judicial decision. Here, Zweber was not seeking reversal or modification of the County’s quasi-judicial decisions, as the complaint stated that development of the parcel was no longer feasible and sought only money damages for the wrongs allegedly committed by the County.

Lastly, the court found that each of Zweber’s constitutional claims could be adjudicated without inquiring into the validity of the County’s decisions, since Zweber did not request injunctive relief seeking to “undo” the County’s decisions. Thus, the district court had jurisdiction to adjudicate Zweber’s constitutional claims. Accordingly, the court reversed the decision of the court of appeals.

Zweber v. Credit River Township, 882 NW2d 605 (MN 7/27/2016)

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