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3 <br /> <br />disproportionate effect on residents of color. Id. at 9. A high percentage of those living in <br />manufactured homes are children. Id. at 10. Costs and harms caused by dislocation can be <br />disastrous. Contrary to the term “mobile home,” most of these units are very difficult, if not <br />impossible, to relocate because their structural integrity may not withstand removal and <br />relocation. Id. at 3. Thus, residents forced to move—who are already low- and moderate- <br />income—face severe monetary losses they cannot afford when a park closes. Id.2 <br />II. THE LOWRY GROVE MANUFACTURED HOME PARK. <br />The above issues are exemplified by the Lowry Grove community, located in St. <br />Anthony, Minnesota, within a mile of I-35W. Lowry Grove is minutes from Downtown <br />Minneapolis and many job and activity centers in the Metro Area that are accessible by mass <br />transit. It solicits applications for rent at $425 per month (plus metered water and sewer <br />payments). Lowry Grove, PLJ Realty, http://www.pljrealty.com/lowry-grove/. It is located in the <br />St. Anthony school district, which has high overall academic performance. (Compl. ¶¶ 5-6, Add. <br />83.) St. Anthony Village Senior High is ranked the third-best high school in Minnesota by U.S. <br />News & World Report. <br />Opportunities to attend such high-performing schools were a specific concern in the Met <br />Council’s report. The report found that children, “who represent nearly a quarter (23%) of park <br />residents, are well positioned to take advantage of good educational resources that can raise their <br />overall educational attainment levels. Manufactured home parks offer affordable housing options <br />in high-performing school districts. . . . Connecting school-age children to high-performing <br />                                                             <br />2 While the Legislature established a relocation trust fund to partially assist displaced residents, such <br />funds are limited to moving expenses up to $12,500 (as of 2016) and do not cover many costs or lost <br />investment, nor do they cover higher housing costs or intangible losses. Minn. Stat. § 327.095, subd. 4, 13 <br />(as amended by 2016 Minn. Laws ch. 189, art. 13, § 60). <br />27-CV-16-9809 Filed in Fourth Judicial District Court <br />8/5/2016 8:53:55 AM <br />Hennepin County, MN