Smart Growth Minneapolis v. City of Minneapolis

The Minnesota Supreme Court reinstated claims that the City of Minneapolis’s adoption of a municipal comprehensive plan violated the Minnesota Environmental Rights Act (MERA). The court held that an administrative rule that exempted comprehensive plans from Minnesota Environmental Policy Act review did not bar claims under MERA. The Supreme Court also found that the district court should not have dismissed the MERA claim because the complaint adequately alleged a causal link between adoption of the comprehensive plan and purported materially adverse environmental effects. The plaintiffs’ complaint alleged, among other things, that there were questions regarding whether the “upzoning” for higher-density development proposed in the comprehensive plan would result in a reduced carbon footprint.