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10 <br /> <br />manufactured housing communities. This creates stability for those homeowners <br />and promotes continued existence of affordable housing. It is difficult to imagine <br />a more appropriate and close-fitting method to further the legitimate interest of <br />the Commonwealth. <br />Greenfield Country Estates Tenants Ass’n v. Deep, 666 N.E.2d 988, 990 (Mass. 1996) (citations <br />omitted); see also McQuillan v. Engelman, No. X06CV 990153482S, 2000 WL 805225, *2 <br />(Conn. Super. Ct. May 15, 2000) (“The clear intent of the law is to provide specific rights and <br />afford certain protections to mobile manufactured homeowners. . . . [L]egislative intent [is] to <br />avoid the severe consequence of dislocating mobile manufactured homeowners by an owner <br />unilaterally closing a park.”); Keeney v. Olio, No. 82-2567, 2001 WL 770946, *4 (R.I. Super. Ct. <br />June 25, 2001) (“The Legislature’s intent is to protect mobile home owners from being displaced <br />and forced to relocate to an already limited number of mobile home parks throughout the state.”). <br />The Minnesota Supreme Court elaborated on the intent behind ch. 327C when it reviewed <br />§ 327C.13, which guaranteed residents’ right to expression and found clear purpose in correcting <br />“the imbalance of power between manufactured home owners and park residents.” APAC v. <br />Uniprop Manuf. Hous. Cmty. Income Fund, 732 N.W.2d 189, 197 (Minn. 2007); accord Arcadia <br />Dev. Corp. v. City of Bloomington, 552 N.W.2d 281, 286-87 (Minn. App. 1996) (finding purpose <br />of ordinance mandating relocation payments as “protecting mobile home park residents from <br />severe or complete losses of substantial investments in their homes when the park owner decides <br />to close their park by selling the land or changing its use”). Moreover, the Minnesota Court of <br />Appeals interpreted an analogous statutory right of first refusal within § 500.24—providing the <br />right to farmers facing a foreclosure sale—as the Legislature “clearly express[ing] its preference <br />that foreclosed property remain in the possession of its former owner whenever possible.” <br />Harbal v. Fed. Land Bank of St. Paul, 449 N.W.2d 442, 446-47 (Minn. App. 1989); see also Ag <br />27-CV-16-9809 Filed in Fourth Judicial District Court <br />8/5/2016 8:53:55 AM <br />Hennepin County, MN