## Facts

- Sheldon Pratt owned land in Crow Wing County, Minnesota, surrounding three shallow sloughs (Island Lake, Rice Lake, and Tamarack Lake) on which he harvested wild rice for about twenty years.
- In 1973, Minnesota amended Minn. Stat. §§ 105.37 and 105.38, expanding the definition of “public waters” so that Pratt’s sloughs fell within the reclassified category.
- In 1975, the state informed Pratt that on “public waters” he could no longer harvest wild rice using a mechanical picker and could harvest only by hand flailing.
- Mechanical harvesting made Pratt’s operation faster and more profitable; he alleged the restriction would materially reduce profitability and the property’s value.
- Pratt sought relief through a legislative claims process and was directed to obtain a declaratory judgment on whether the wild rice was being grown in “public waters.”
- Pratt sued for a declaration that the waters were private and not subject to statutory control; the state counterclaimed for a declaration that the waters were public and subject to regulation.
- The state acknowledged the sloughs’ principal economic value was wild-rice production and asserted the regulation served conservation and protection of a traditional harvest for Minnesota Indians.

## Issues

1. Whether the sloughs were properly classified as “public waters” under the post-1973 statutory scheme.
2. Whether reclassification as public waters and the associated ban on mechanical wild-rice harvesting constituted a compensable taking of Pratt’s property interests.
3. Whether a taking may be found based on a substantial diminution in the market value of the property that shifts an unfair share of public costs to one landowner.

## Decision

- The Minnesota Supreme Court held the waters met the statutory criteria for “public waters” under the amended law.
- The court ruled that reclassification and regulatory control, including the mechanical-harvesting prohibition, did not automatically constitute a taking.
- The court remanded for fact-finding on whether the combined effect of reclassification and the mechanical-harvesting ban caused a substantial diminution in the market value of Pratt’s property.
- The court directed the district court on remand to determine whether a taking occurred and, if so, whether compensation or equitable relief was appropriate.

## Legal Principles

- Classification of waters as “public” primarily subjects them to regulatory authority; it does not, by itself, establish state ownership of all related economic uses or resources.
- Regulation enacted under police power is not a per se taking; a compensable taking depends on the severity of the economic impact on the property interest affected.
- A regulatory taking may be established where governmental action substantially diminishes a property’s market value and imposes an unfair, disproportionate economic burden on a single landowner for a public benefit.
- Riparian and resource-use interests tied to a property’s economic value can be protected against uncompensated takings when materially impaired.

## Conclusion

The court affirmed the public-waters classification but rejected a per se takings rule, remanding for a determination whether the restrictions on mechanical wild-rice harvesting substantially reduced the property’s market value enough to require compensation or other relief.


Pratt v. State, Dep’t of Nat. Res., 309 N.W.2d 767 (Minn. 1981)