Anderson et al. v. City of Minneapolis

Plaintiffs are tenants who allege that Minneapolis is discriminating based on race in allocating housing inspectors, in violation of the Minnesota Human Rights Act (“MHRA”)—leaving serious housing code violations unaddressed. Plaintiffs sued the City in state court alleging, as relevant here, violations of the Minneapolis Housing Code, and the MHRA. They asked the Court for what is termed “equitable relief,” including a declaration that the City was acting unlawfully and an order enjoining the City from further discrimination. The trial court dismissed their housing code and MHRA claims based on Minnesota’s common-law doctrine of official immunity, ruling that official immunity barred their claims for injunctive and declaratory relief. The Court of Appeals affirmed.

The State Supreme Court Initiative and the ACLU of Minnesota filed an amicus brief urging the Minnesota Supreme Court to reverse the Court of Appeals ruling. As amici argue, the Court of Appeals’ view, if upheld, would make it all but impossible, absent willful or malicious wrongdoing, for individuals to secure injunctions requiring local governments to follow the law, even when public officials are blatantly violating it. Amici first provide national context, writing that doctrines like official immunity are designed to shield officials from private financial liability and that no other state supreme court has extended official or governmental immunity to all claims for equitable relief. Accordingly, amici urge the Court to join the vast majority of its peers in allowing prospective injunctive and declaratory relief when a government actor violates a valid statute. Second, amici argue that if the Court becomes the first high court to extend official immunity to claims for equitable relief, it should interpret the MHRA to necessarily waive official immunity with respect to injunctive and declaratory relief based on fundamental principles of statutory construction and the Minnesota Constitution’s Remedies Clause.