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6 forth a hearing procedure in which the City Manager or designee is the impartial hearing officer. St. Louis Park Mun. Code § 4-88(a), (g). The ordinance also provides for notice and a hearing of a designation of a potentially dangerous dog, and requires owners of potentially dangerous dogs to register and license the dog as potentially dangerous and have a microchip implanted. St. Louis Park Mun. Code § 4-89(b)-(c). The applicable fees are not specified. E. Plymouth The Plymouth ordinance does not adopt the entire state statute by reference like Edina, but it does refer to provisions of the state law repeatedly. The Plymouth ordinance expressly provides for notice and opportunity for a hearing for a “potentially dangerous” designation, which is not provided for in the state law. Plymouth Mun. Code § 915.25, subd. 2. The ordinance does not, however, impose any registration or other restrictions on potentially dangerous dogs. V. Analysis and Recommendations A. Potential Liability In certain extreme circumstances, a City can be held liable for failure to enforce its dangerous dogs ordinance. In Hansen v. City of St. Paul, 214 N.W.2d 346 (Minn. 1974), St. Paul was found liable for injuries caused by two dogs that had bitten seven other people in the previous 13 months and were known to city officials to be vicious and prone to unprovoked attacks on sidewalk pedestrians. The court held that this was a narrow extension of the city’s common- law duty to maintain its streets and sidewalks, when (1) vicious dogs prowl the public sidewalks, (2) the appropriate municipal officials have knowledge, (3) the officials know that the owner is failing in its duty to restrain, and (4) confinement and impoundment are reasonably achievable. While the Supreme Court made sure to specify that it was only narrowly expanding liability to this extreme situation, this case does demonstrate that cities can be held liable for failure to properly regulate dangerous dogs when the city is on notice. Thus it is important that the City have an ordinance that is enforceable and enforced. B. Preemption of Existing Ordinance The residents that requested this review argued that City Code § 91.36 conflicts with the state dangerous dog statute and is thus preempted. The state law expressly provides local jurisdictions with broad authority to regulate dangerous dogs: Any statutory or home rule charter city, or any county, may regulate potentially dangerous and dangerous dogs. Except as provided in section 347.51, subdivision 8, nothing in sections 347.50 to 347.565 limits any restrictions that the local jurisdictions may place on owners of potentially dangerous or dangerous dogs. Minn. Stat. § 347.53. The only limitation on this authority, referenced in the above provision, provides: A statutory or home rule charter city, or a county, may not adopt an ordinance regulating dangerous or potentially dangerous dogs based solely on the specific breed of the dog. Ordinances inconsistent with this subdivision are void. Thus the only restriction on local regulations of dangerous dogs under the state law is that the local jurisdiction cannot discriminate by breed of dog. Other than this limitation, the state law