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5.4. SR 05-17-2010
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5.4. SR 05-17-2010
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5/26/2010 3:05:21 PM
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5/14/2010 2:29:55 PM
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5/17/2010
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The Minnesota Supreme Court addressed the analogous issue 40 years ago in <br />deciding that a writ of mandamus to challenge a city zoning determination was <br />appropriate because certiorari relief would not result in an order compelling the city to <br />take the requested zoning action. See Curry v. Young, 285 Minn. 3 87, 394-96, 173 <br />N.W.2d 410, 414 (1969). In Curry, the district court issued a writ of mandamus <br />compelling the city to approve the applicant's request for a variance from the city's <br />setback requirements. Id. at 388, 173 N.W.2d at 411. On appeal, the city argued that the <br />mandamus relief was inappropriate because the applicant was required to proceed by <br />certiorari. Id. at 392, 173 N.W.2d at 413. The Minnesota Supreme Court disagreed. The <br />Court held that, because the issuance of a writ of certiorari -like the declaratory <br />judgment ruling here -could not compel the city to grant the requested setback <br />variance, mandamus relief was appropriate. The Court reasoned as follows: <br />A review by certiorari mi ht lead to a decision that the city was wrong, but <br />it would not provide the relief plaintiffs seek. An example of the evils <br />that can exist in review by certiorari and the multiplicity of suits it creates is <br />found in State ex rel. Spurck v. Civil Service Board, 226 Minn. 240, 32 <br />N.W.2d 574. In that case...we held that mandamus is a proper remedy to <br />compel an administrative agency to perform duties required under a <br />decision in a case reviewed by certiorari. See, also, State ex rel. Jenkins v. <br />Ernest, 197 Minn. 599, 600, 268 N.W. 208, 209, where we said: <br />'It is, of course, well settled that a writ of Mandamus brought <br />against the proper appointing authority or authorities is the <br />~~ropriate remedy to compel reinstatement when an officer <br />or appointee has been discharged; and if it is shown that his <br />dismissal was in violation of the civil service laws he will be <br />restored to his former position. <br />'* * * Mandamus cannot be used for the purpose of reviewing <br />the decision of an officer, board, or tribunal which acted <br />within the jurisdiction conferred upon it by law. It can <br />properly be issued only to compel the performance of a duty <br />4 <br />
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