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I <br /> <br /> I <br /> I <br />I <br /> <br /> I <br /> I <br /> I <br /> <br /> I <br /> I <br /> I <br /> I <br /> I <br /> <br /> Page -g- <br /> <br />To relate Iuture growth in state aid to changes in population, <br /> <br /> inflation, and tax base capacity. <br /> <br /> 9. To provide an incentive for replacement ot aging capital <br /> facilities. <br /> <br /> 10. To resolve "special" fiscal problems, i.e. local pensions. <br /> <br /> See Plaintiffs' Answers to De~endants' Interrogatories, Answer No. 3. The <br />purposes recited above were contained in a proposal by the League of Minnesota <br />Cities who drafted the legislation which was adopted by the legislature in 1979. <br />(Gardner Deposition, at 23-25 and Gardner Deposition Exhibit No. 2.) <br /> <br /> De~endants, as evidenced by their memorandum, re~use to accept that the <br />statute has a purpose other than reducing reliance on locaI property taxes. As a <br />determination o~ purpose is essential to resolving the constitutional question of <br />equal protection, the resolution ol legislative purpose must be deemed a material <br />fact which is in dispute. <br /> <br /> E. Local Government Aid Does Not Achieve Its LeRislative Purposes. <br /> <br /> Once the issue ol the statutory "purposes" has been resolved, the central <br />factual issue still remains: how does the effect of the statute on government units <br />correspond to the purposes of the legislation. See, e.g., Price v. Amdal, 256 NW2d, <br />565 (Minn. 1977). <br /> <br /> Defendants have correctly stated that a law will survive an equal protection <br />challenge only il it is rationally related to a legitimate governmental purpose. <br />De~endants cl~,im, without any proo~ by affidavit or otherwise, that the aid ~ormula <br />provides a rational approach to the effectuation o~ its purpose. Defendants would <br />have the Court resolve this issue on the "assumption" stated by defendants counsel. <br /> <br /> The test o~ whether this or any statute provides a rational approach to the <br />ef~ectuation o~ its purpose is to determine whether the statute 'hchieves" its <br />purpose. De~[e~dants' themselves cite the court to McGowan v. Maryland, 366 U.S. <br /> <br /> <br />