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Agenda Packets - 1999/04/05
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Agenda Packets - 1999/04/05
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Last modified
1/28/2025 4:47:16 PM
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MV Commission Documents
Commission Name
City Council
Commission Doc Type
Agenda Packets
MEETINGDATE
4/5/1999
Supplemental fields
City Council Document Type
City Council Packets
Date
4/5/1999
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Mar-31-99 01:09pm From-KENNEDY & GRAVEN +6123379310 T-098 P.06/08 F-823 <br /> c09819g9 Court of Appeals Page 3 of 3 <br /> expended in administrauve hearings,even where the agency may be exceeding its <br /> jurisdiction, do not amount to irreparable injury justifying intervention by a court of <br /> equity. * * * En the absence of a showing of irreparable injury, we must hold that,in the <br /> interest of orderly and uninterrupted administrative action an injunction should not <br /> issue to interfere with the commission's administrative proceedings. <br /> Id. at 7, 60 N.W.2d at 21-22. Like the employer in Thomas, City showed no injury other than <br /> "[p]roblematical damages based on speculation" when it argued that taxpayers' funds might be spent <br /> unnecessarily if eventually the court were to decide against extending the runway.See also Sheehan <br /> v. Hennepin County District Court, 253 Minn 462,93 N.W.2d 1 (1958) (upholding a writ of <br /> prohibition to stop the court issuing a temporary order restraining the commissioner of insurance <br /> from proceeding against an insurance company). <br /> The mere fact that a party might be saved the time and expense of defending himself at <br /> an administrative proceeding would not be sufficient to justify equitable relief by means <br /> of injunction 's * *. <br /> * * * The temporary restraining order issued by the court below prevented relator <br /> [commissioner of insurance] from carrying out his administrative duties. The statute <br /> having made it plain that the exercise of such power by the court at the time was <br /> unauthorized,it becomes manifest that the remedy of appeal was and is plainly <br /> inadequate and the writ should not be denied. <br /> !d. at 467-68, 93 N.W.2d at 5-6. Both Thomas and Sheehan solidly hold that an entity may not <br /> enjoin commissions from their legitimate activities because the expense the entity incurs as a result <br /> of those activities could prove unnecessary it'the activities are subsequently disallowed by a court. <br /> The district court's finding that City would experience "irreparable harm" if MC were allowed to <br /> consider MAC's recommendation that the runway be extended is erroneous as a matter of law, and <br /> absent a showing of irreparable harm,the injunction interfering with the proceedings of MC and <br /> MAC was an abuse of discretion. <br /> Moreover, even if City had met the threshhold showing of irreparable harm, it did not make an <br /> adequate showing on the factors a court is to consider in granting injunctive relief.Dahlberg Bros., <br /> Inc. v. Ford Motor Co.,272 Minn. 264,274-75, 137 N.W.2d 314, 321-22 (1965), enumerates the <br /> factors: (1) the parties'relationship prior to the dispute; (2) the weight of the irreparable harm alleged <br /> by the party seeking the injunction compared to the weight of the harm suffered by the other party if <br /> the injunction is granted; (3)the likelihood that the party seeking the injunction will prevail on the <br /> merits; (4)public policy considerations; and (5) administrative burden on the court. <br /> 1.Prior Relationship of the Parties <br /> City and MAC were in litigation concerning Airport's development during the 1980s. That litigation <br /> culminated in a July 1986 stipulation and court order that the runway be extended to 4,000 feet. The <br /> district court's finding on the parties'prior relationship implies that the 1986 order permanently <br /> restricts the length of the runway and prohibits MAC and MC from further planning_ <br /> The 1986 order, however,provided that Airport was to be developed "consistent with requirements <br /> of state law and the Metropolitan Development Guide, as of the date of this Agreement, as a'minor <br /> hup://www.courts.state.mn.us/opinions/coakurrent/c0981989.hunl 3/31/99 <br />
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