Butler v City of Saint Paul (1) - Laserfiche WebLink

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Butler v. City of Saint Paul, 936 N.W.2d 478 (2019) © 2022 Thomson Reuters. No claim to original U.S. Government Works.1 936 N.W.2d 478 Supreme Court of Minnesota. Peter K. BUTLER, Appellant, v. CITY OF SAINT PAUL, et al., Respondents. A18-0655 | Filed: December 18, 2019 Synopsis Background: Citizen filed petition claiming that city election officials erred in refusing to put his petition to amend the city's charter before voters. The District Court, Ramsey County, Jennifer Frisch, J., granted summary judgment for election officials. Citizen appealed. The Court of Appeals, Rodenberg, J., 923 N.W.2d 43, affirmed. Citizen appealed. Holdings: The Supreme Court, Gildea, C.J., held that: [1] election officials did not err in looking to statewide voter registration system to determine whether citizen collected signatures from the required number of voters and in rejecting signatures of those who were registered to vote at an address outside of city, and [2] citizen failed to carry his burden of demonstrating that city election officials committed an error, omission, or wrongful act in refusing to put his petition on ballot. Affirmed. Procedural Posture(s): On Appeal; Motion for Summary Judgment. West Headnotes (6) [1]Appeal and Error De novo review The Supreme Court's review of a district court's entry of summary judgment is de novo. [2]Municipal Corporations Amendment of charter or special act Although the Supreme Court is reluctant to exclude voter-circulated petitions to amend a city charter, it must adhere to mandatory statutory requirements, such as a voter's affidavit of residence and eligibility to vote, to ensure that only those who are qualified to participate do so. [3]Election Law Powers and duties of officers in general Municipal Corporations Amendment of charter or special act Statute giving secretary of state authority to adopt rules governing elections in the state applied to all elections held in the state, including filing petitions to place a charter amendment on the ballot. Minn. Stat. Ann. § 204B.071. [4]Municipal Corporations Amendment of charter or special act City election officials did not err in looking to statewide voter registration system (SVRS) to determine whether citizen collected signatures from the required number of voters to put petition to amend the city's charter on ballot, and in rejecting signatures of those who were registered to vote at an address outside of city; state law provided that only registered voters were eligible to sign a charter-amendment petition, SVRS was the official record of registered voters in the state, and a voter's registration to vote was tied to voter's current residence. Minn. Stat. Ann. § 410.12(1); Minn. R. 8205.1050. [5]Municipal Corporations Amendment of charter or special act Citizen failed to carry his burden of demonstrating that city election officials committed an error, omission, or wrongful act in refusing to put his petition to amend city's charter on ballot because he failed to obtain a sufficient number of signatures from registered voters in city on his petition, where city diligently