## Facts

- Minnesota enacted the Metropolitan Fiscal Disparities Act, establishing a regional tax-base sharing system for commercial and industrial property in a seven-county metropolitan area.
- The Act required that 40% of the increase in commercial-industrial tax base be contributed to a regional pool and redistributed among local governments by a statutory formula.
- Under the formula, some municipalities would be net contributors in a given year and others net recipients.
- The Village of Burnsville and other local governments, joined by a taxpayer-resident who also served as a village planner, filed a declaratory judgment action asserting the Act would raise local tax burdens and impede local planning.
- The district court held the Act unconstitutional under Minn. Const. art. 9, § 1 (tax uniformity requirement) and invalidated the statute.
- County auditing/finance officials and the Metropolitan Council appealed.

## Issues

1. Whether a taxpayer-resident who is also a village planner had standing to challenge the Act based on alleged effects on personal property taxes and planning responsibilities in a matter of great public interest.
2. Whether the Act’s regional pooling and redistribution of commercial-industrial tax base violates Minn. Const. art. 9, § 1, requiring that taxes be uniform upon the same class of subjects.

## Decision

- The Minnesota Supreme Court held the taxpayer-planner and the municipal plaintiffs had standing because the challenged statute could affect individual taxes and local planning and raised issues of great public interest.
- The court reversed the district court and upheld the Act as consistent with Minn. Const. art. 9, § 1.
- The court concluded the Act conferred sufficiently substantial benefits on those bearing the tax burden to satisfy the state constitutional uniformity requirement.

## Legal Principles

- A taxpayer-resident may have standing to challenge a statute affecting taxation and governmental functions when the plaintiff alleges concrete potential impacts and the issues are of great public interest.
- Minnesota’s uniformity clause permits reasonable legislative classifications in taxation; a scheme will be sustained when classifications are not arbitrary and are related to legitimate governmental objectives.
- A regional tax-base sharing system does not violate tax uniformity merely because particular municipalities may contribute more than they receive in a given year; uniformity is assessed by whether the statutory class is treated evenhandedly under a common formula and whether the scheme provides substantial reciprocal public benefits to those taxed.

## Conclusion

The Minnesota Supreme Court held that the taxpayer-planner had standing and that the Metropolitan Fiscal Disparities Act’s metropolitan tax-base pooling and redistribution system satisfied the state constitutional uniformity requirement because it applied uniformly within a reasonable class and provided substantial benefits to those bearing its burdens.


Vill. of Burnsville v. Onischuk, 222 N.W.2d 523 (Minn. 1974)