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Cities are engaged in quasi-judicial action when they designate buildings for heritage preservation. Because they are quasi-judicial acts, an appellate court affirms decisions to designate property as historic unless it makes an independent determination that the decisions are unreasonable, arbitrary, or capricious.
The City of Minneapolis designated an area near downtown Minneapolis as an historic preservation district. Respondent, Billy Graham Evangelistic Association, owner of four buildings in the designated district, challenged the designation, claiming that the City acted arbitrarily, capriciously, or unreasonably. The Court of Appeals granted relied to the respondent and reversed the City's designation of the northeast portion of the district as historic. The City appealed, claiming that the court of appeals substantially departed from the usual course of justice in its standard of review of quasi-judicial decisions.
Did the City act arbitrarily or capriciously in designating the district as historic?
The court reversed the decision, and held that the City did not act arbitrarily or capriciously in designating the district as historic. Because the City made contemporaneous findings to support its decision, the association bore the burden of proving that the City acted arbitrarily, capriciously, or unreasonably. The court's decision was constrained by the significant deference it accorded the quasi-judicial actions of local governments and the broad and subjective criteria for historic designation set out in the ordinance. The historic designation met the criteria in the ordinance, as the City made findings in favor of its decision that were supported by the record.