## Facts

- Minnesota law authorizes municipalities to designate historic districts and establishes a policy favoring preservation of historical, architectural, and cultural assets.
- Minneapolis created a Heritage Preservation Commission (HPC) under its ordinances to evaluate and recommend historic designations using specified criteria.
- A neighborhood group requested study of the Harmon Place area near downtown Minneapolis for possible historic-district designation.
- The City retained a preservation consultant to prepare a designation study concluding the area satisfied multiple ordinance criteria, emphasizing its long association with Minneapolis’s automotive industry and related architecture.
- After public hearings and multi-level administrative review, the HPC recommended designation, and the City Council formally designated the Harmon Place Historic District (HPHD).
- The Billy Graham Evangelistic Association (BGEA) owned four buildings within the designated boundaries and objected to inclusion, asserting its properties were “noncontributing” and that the designation was arbitrary and capricious.
- BGEA sought certiorari review; the court of appeals reversed as arbitrary and capricious; the Minnesota Supreme Court granted further review.

## Issues

1. Whether the City acted unreasonably, arbitrarily, or capriciously in designating the HPHD.
2. Whether inclusion of allegedly noncontributing BGEA properties rendered the district designation arbitrary or capricious.
3. Whether the City’s reliance on its expert study, despite conflicting expert evidence, lacked a rational basis.

## Decision

- The Minnesota Supreme Court reversed the court of appeals and reinstated the City’s designation of the HPHD.
- The Court held the City did not act unreasonably, arbitrarily, or capriciously because the record showed reasoned decisionmaking and a rational basis for the designation.
- The Court rejected the claim that inclusion of some noncontributing properties invalidated the designation, treating the district’s significance as the relevant focus.
- The Court held that conflicting expert opinions did not make the City’s decision arbitrary where the City reasonably relied on an expert study and applied ordinance criteria through established procedures.

## Legal Principles

- Quasi-legislative municipal land-use and preservation decisions receive substantial judicial deference; the challenger bears the burden to show arbitrariness or caprice.
- A designation is upheld when the administrative record reflects reasoned decisionmaking supported by evidence and contemporaneous findings applying governing criteria.
- Historic-district significance may be assessed on a district-wide basis; inclusion of some noncontributing parcels does not, by itself, defeat a rational basis for district boundaries.
- A municipality may choose between competing expert views without acting arbitrarily, so long as its chosen basis is reasonable and supported by the record.
- Alleged inconsistency with other preservation actions does not establish arbitrariness where the challenged decision is supported by its own record and applicable procedures.

## Conclusion

The court upheld Minneapolis’s historic-district designation because the City followed required procedures, relied on a detailed expert study applying ordinance criteria, and made findings supporting the district’s collective historical and architectural significance, making the inclusion of BGEA’s properties within the district neither arbitrary nor capricious.


Billy Graham Evangelistic Ass’n v. City of Minneapolis, 667 N.W.2d 117 (Minn. 2003)