Laserfiche WebLink
I <br /> <br /> I <br /> <br /> i <br /> I <br /> I <br /> I <br /> I <br /> I <br /> I <br /> I <br />! <br />i <br />I <br />! <br /> <br />I <br />! <br />I <br /> <br />adjustment was made for the cities receiving their minimum aid <br />amounts because the legislature limited the funds available for this <br />"grandfathering" to $6,400,000.21/ <br /> <br /> ARGUMENT <br /> <br />I. Because There Is No Genuine Issue A.s.To A~.~; Material Fact, This <br /> Case Is Ri'~e ~or Summary J.udgment. <br /> <br /> This case is before the court on defendants' motion for <br />summary judgment pursuant to Minn. R. Civ. P. 56. It is elementary <br />that the first requirement for an award of summary judgment is that <br />no material facts be in dispute. Although plaintiffs may contend <br />otherwise, that requirement is satisfied in the instant case. <br /> <br /> Plaintiffs seek a declaratory judgment that the local <br />government aid formula is unconstitutional. All the facts necessary <br />to the determination of that~ legal issue are known and cannot be <br /> <br />disputed. The statutory formula that is challenged is a given. It <br />is found at 1983 Minn. Laws, ch. 342, art. 5.22/ Although the <br /> <br />(Footnote continued) <br /> <br />figure did not change. Ramsey's final local government aid <br />figure for 1984 was $171,311. See Ex. 3, lines 32-37. <br /> <br />21/ <br /> <br />Because it does not appear that plaintiffs challenge this <br />aspect of the aid determination process, the method of making <br />these adjustments is not described in detail. Since Ramsey's <br />aid amount is not based on its minimum factor, this adjustment <br />(Ex. 3, lines 38-42) does not apply. <br /> <br />22/ <br /> <br />As described above, the local government aid formula was <br />amended by the 1983 Legislature and is now different in several <br />significant respects from the formula that was in existence at <br />the time plaintiffs initiated this lawsuit. Because plaintiffs <br />seek only declaratory and injunctive relief, their challenge to <br />the constitutionality of the formula that existed prior to the <br />1983 amendments is necessarily moot. To the extent that their <br /> <br />(Footnote ~ontinued <br /> <br />-14- <br /> <br /> <br />