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Full Opinion
VILLAGE OF BURNSVILLE, et al., Respondents,
v.
Carl ONISCHUK, Auditor of Dakota County, Respondent,
Lou McKenna, Auditor of Ramsey County, Respondent,
Charles Lefebvre, Auditor of Anoka County, et al., Appellants-Respondents,
Thomas Greeder, Auditor of Washington County, Respondent,
Olaf Kaasa, Finance Director of Hennepin County, et al., Respondents,
Metropolitan Council, Intervenor, Respondent-Appellant.
Supreme Court of Minnesota.
*524 Weaver, Talle & Herrick, Anoka, Warren Spannaus, Atty. Gen., Curtis Forslund, Chief Deputy Atty. Gen., Patrick Murray, C. H. Luther, Deputy Attys. Gen., Dept. of Taxation, St. Paul, for Lefebvre.
Dorsey, Marquart, Windhorst, West & Halladay and John W. Windhorst, Jr., and William H. Hippee, Jr., Minneapolis, for Metropolitan Council.
Grannis & Grannis and Roger Knutson, So. St. Paul, for Burnsville and others.
John O. Sonsteng, County Atty., George May, Asst. County Atty., Hastings for Carl Onischuk.
William Randall, County Atty., St. Paul, for Lou McKenna.
John Jansen, County Atty., Stillwater, for Thomas Greeder.
George Scott, County Atty., Minneapolis, for Olaf Kaasa.
Allen I. Saeks, Minneapolis, Donald Lais, St. Paul, Robert Heacock, Jr., Bloomington, amicus curiae.
Considered and decided by the court en banc.
OTIS, Justice.
The issue raised by this appeal is the constitutionality of Ex.Sess.L.1971, c. 24, Minn.St. 473F, commonly referred to as the "Metropolitan Fiscal Disparities Act." The trial court held the statute to be in violation of Minn.Const. art. 9, § 1, and we reverse.
The action was initiated as a declaratory judgment suit by the village of Burnsville, located in Dakota County, against the auditors of Dakota County, Ramsey County, Anoka County, Carver County, Scott County, and Washington County, the finance director and auditor of Hennepin County, and the state treasurer. Subsequently, Glen Northrup joined as a party plaintiff, and the Metropolitan Council intervened as a party defendant. The auditors of Dakota County, Ramsey County, Washington County,and Hennepin County, and the finance *525 director of Hennepin County have not appealed.
In addition to the constitutional issue, the question of plaintiffs' standing is also before us.
The purposes of c. 24 are set forth in the act as follows:
Minn.St. 473F.01. "The legislature finds it desirable to improve the revenue raising and distribution system in the seven county Twin Cities area to accomplish the following objectives:
(1) To provide a way for local governments to share in the resources generated by the growth of the area, without removing any resources which local governments already have;
(2) To increase the likelihood of orderly urban development by reducing the impact of fiscal considerations on the location of business and residential growth and of highways, transit facilities and airports;
(3) To establish incentives for all parts of the area to work for the growth of the area as a whole;
(4) To provide a way whereby the area's resources can be made available within and through the existing system of local governments and local decision making;
(5) To help communities in different stages of development by making resources increasingly available to communities at those early stages of development and redevelopment when financial pressures on them are the greatest;
(6) To encourage protection of the environment by reducing the impact of fiscal considerations so that flood plains can be protected and land for parks and open space can be preserved; and
(7) To provide for the distribution to municipalities of additional revenues generated within the area or from outside sources pursuant to other legislation."
Under Minn.St. 473F.02, the area affected by the act consists of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington Counties, which includes Minneapolis and St. Paul and the suburban metropolitan municipalities immediately adjacent to them, numbering some 250 local units of government in all. Although the formulas for achieving the purposes of the act are complex in the extreme, the stated objectives are relatively simple. In order to prevent an ill-advised competitive scramble by individual units of government within the 7-county area for commercial-industrial development to improve their tax base, the act contemplates pooling 40 percent of the increase throughout the area of all commercial-industrial valuation subsequent to January 2, 1971. For the revenue needs of each unit of government, the county auditor will thereupon impose two separate levies, one on 60 percent of the increment in its commercial-industrial valuation, if it has contributed to the pool, plus all other taxable property in that particular unit of government, and a separate levy on the metropolitan pool, representing the 40-percent increment in commercial-industrial valuation. Under this scheme, all units of government receive some distribution of the area-wide tax base although from year to year, as conditions change, some units will contribute more to the pool than will be distributed to them.[1]
The effect of the system is to reallocate the area-wide tax base thus pooled to all municipalities in direct relation to need and inverse relation to fiscal capacity. Need is measured by population, and fiscal capacity is measured by the market value of taxable property per capita.[2] Consequently, the *526 units of government with large population and low fiscal capacity are favored in real-location over those with small population and high fiscal capacity.[3]
The local levy of each unit of government is divided by the local tax base to determine the local mill rate which is then applied to all commercial-industrial property which has not been pooled and to all other taxable property. The area-wide levies of all units of government are combined into a total levy against the area-wide tax base. The area-wide levy divided by area-wide tax base establishes an area-wide tax rate which is then applied to the value of each item of industrial-commercial property which has not been subjected to local tax rates. As previously noted, the value of commercial-industrial property to which the area-wide rate is applied varies from year to year, depending on its rate of growth in each municipality.
Since the amount a particular municipality will realize from the area-wide levy is always in direct proportion to the amount it will realize from its local tax levy, the opportunity for "raiding" the area-wide tax base is minimal or nonexistent.
When the area-wide tax levies have been collected, they are channeled through the county to the state treasurer and distributed to local units of government on the basis of the fiscal capacity of each.[4] The area-wide tax base distribution index which determines the amount of the area-wide levy to which each unit of government is entitled is computed by multiplying the population of the municipality by a fraction, the numerator of which is the average fiscal capacity of all the municipalities in the area for the preceding year, and the denominator of which is the fiscal capacity of that particular municipality, and multiplying the product by two.[5]
Standing of plaintiffs.
In their amended complaint, the village of Burnsville is described as a qualifying municipality under c. 24, and Northrup is described as a resident and taxpayer of Burnsville. He was also the planning director for the village. The complaint alleges that c. 24 violates the equal protection provisions of the Fourteenth Amendment and the uniformity provisions of Minn.Const. art. 9, § 1. Plaintiffs seek a declaratory judgment determining the validity of c. 24, enjoining defendants from enforcing it, and holding the statute to be unconstitutional. The trial court disposed of the question of standing by finding plaintiffs had an interest in the statute which was in jeopardy, and that "[p]ublic interest in the issues raised is of great importance to all taxpayers and governmental units affected by Chapter 24."
As to the village of Burnsville, we have difficulty understanding how the application of the statute adversely affects it. Apparently, in the first year at least, it will actually benefit from the statute. Furthermore, as far as the village itself is concerned, c. 24 will not in any way affect the *527 amount of revenue which the village will receive but only the manner in which taxes are levied. As to the village, Commissioner of Taxation v. Crow Wing County, 275 Minn. 9, 13, 144 N.W.2d 717, 719 (1966), governs. There, we held:
"* * * In our view the interest required to give standing to a political subdivision must be one predicated upon some adverse effect upon the governmental unit. * * * The county is not a proper party to represent the taxpayers in this situation because of its conflicting interests and duties."
In Mower County Board v. Board of Trustees of PERA, 271 Minn. 505, 513, 136 N.W.2d 671, 676 (1965), we had this to say on the subject of county boards attacking the validity of statutes governing their duties:
"* * * To permit public officials who have no duty to interpret or administer a law endowed with the presumption of constitutionality to assail that law as an excuse for their own failure or refusal to act under a statute clearly imposing only ministerial obligations would result in chaos."
Accordingly, we hold that the village of Burnsville had no standing to attack the validity of the statute.
With respect to the standing of Glen Northrup, a more difficult question is presented. We have held that declaratory judgment actions are not available to litigants who have other specific remedies, such as c. 278 dealing with real estate tax assessments. Land O'Lakes Dairy Co. v. Village of Sebeka, 225 Minn. 540, 547, 31 N.W.2d 660, 664, certiorari denied, 334 U.S. 844, 68 S.Ct. 1513, 92 L.Ed. 1768 (1948). See, Loew v. Hagerle Brothers, 226 Minn. 485, 488, 33 N.W.2d 598, 600 (1948); Larson v. Freeborn County, 267 Minn. 383, 126 N.W.2d 771 (1964). Nevertheless, we have recognized the standing of public officials who attack the constitutionality of legislation where the public interest is great. Loew v. Hagerle Brothers, supra; Port Authority of City of St. Paul v. Fisher, 269 Minn. 276, 292, 132 N.W.2d 183, 194 (1964).
Although the question is a close one, we hold that Glen Northrup's status as a taxpayer and village official is sufficient to give him standing in these proceedings. Clearly, the issues here are of unusual public concern. They have been exhaustively and vigorously litigated in an adversary manner by competent counsel, and we entertain no misgivings concerning the quality of the presentation. At this stage of the litigation it would be a great disservice to the public to decline jurisdiction because the plaintiffs' standing is somewhat doubtful. Accordingly, we affirm that part of the trial court's decision which recognizes the standing of plaintiff Glen Northrup.
The constitutionality of c. 24.
The trial court held that c. 24 violated Minn.Const. art. 9, § 1, the pertinent provisions of which are as follows:
"* * * Taxes shall be uniform upon the same class of subjects, and shall be levied and collected for public purposes * * *."
The court did not rely on the equal protection provisions of the Fourteenth Amendment. We have construed the uniformity clause to be no more restrictive than the equal protection clause. Reed v. Bjornson, 191 Minn. 254, 261, 253 N.W. 102, 105 (1934); Apartment Operators Assn. v. City of Minneapolis, 191 Minn. 365, 366, 254 N.W. 443 (1934); In re Taxes on Property of Cold Spring Granite Co., 271 Minn. 460, 466, 136 N.W.2d 782, 787 (1965). The judgment permanently enjoined the enforcement of c. 24.
In arriving at its decision, the trial court made the following findings, among others:
"10. Distribution under the Act permits and contemplates the use of such funds outside the seven counties in all taxing districts partially within and partially outside the seven county area.
*528 "11. The Act requires each taxing district within the metropolitan area to bear the burden of its own delinquent taxes.
"12. Chapter 24 does not specify nor does it establish the seven county metropolitan area as a `taxing district.'"
The court attached to its decision the following memorandum:
"The Minnesota Supreme Court has never defined what constitutes a `taxing district' throughout which valuation rates must be uniform. While cities, villages, towns and school districts are referred to as taxing districts in various statutes no where in Chapter 24 is the seven county metropolitan area referred to as such. Chapter 24 uses the presently existing taxing districts administrative facilities to process its procedures. It requires existing taxing districts within the area to assume the burden of their own tax delinquencies. It provides for no new additional services nor does it create new and specific obligations. It requires each taxing district affected to contribute towards the establishment of a base fund and distributes that fund on a formula having no reasonable relationship between that contribution made and the benefit derived by the segment of the population required to bear the financial burden. Its plan imposes a tax on some districts for the benefit of others. It establishes a non-uniform classification of property within a seven county area since it does not exempt that area from its existing statewide classification.
"In general the law fails to pass the test not only of practical and common sense equality but totally fails to pass the test of constitutional uniformity requiring that the burden of a tax must fall equally and impartially upon all persons and properties subject to it."
1. Nowhere in c. 24 does the legislature expressly create a new taxing district. As plaintiffs point out, one of the purposes enunciated in the act is "[t]o provide a way whereby the area's resources can be made available within and through the existing system of local governments and local decision making." (Italics supplied.) Plaintiffs rely on language in Johnson v. County of Ramsey, 290 Minn. 307, 313, 187 N.W.2d 675, 679 (1971):
"* * * Similarly, in the case before us, we believe that if the county is to be a single assessment district, this must be provided by legislative act."
The Johnson case, however, did not turn on that issue but simply decided that some disparity was justified where an entire county was being reassessed and the process could not be completed in any one taxing year.
Plaintiffs stress also the fact that a single taxing district is negated by the provisions of § 473F.08, subd. 9, which provides in part as follows:
"If the payment of any tax attributable to the area-wide tax base is delinquent, the county treasurer to whom said tax is payable shall promptly notify the state treasurer of the failure of payment. The state treasurer shall deduct the amount of the delinquency from his distributions to the county entitled to receive payment from the taxpayer."
The uniformity clause was invoked under similar circumstances in State ex rel. Smith v. Cronkhite, 28 Minn. 197, 9 N.W. 681 (1881), an opinion written by Mr. Justice Mitchell. There, the proceeds of delinquent tax sales by the county were paid to municipalities which were not obligated to reimburse the county if the tax sale was subsequently held invalid and the county was therefore required to repay the purchaser. The court found that this burden on the county did not result in a degree of inequality which would compel a holding that the statute was unconstitutional, stating (28 Minn. 200, 9 N.W. 682):
"* * * Absolute equality is neither required nor practicable. The legislature cannot be tied down to any narrow or technical rule."
*529 We agree with the position of defendants that the legislative policy of requiring each governmental unit to bear the loss of its own tax delinquency is simply an incentive for keeping such delinquencies to a minimum and that the municipality involved, having control of the collection process, may constitutionally be required to bear the loss.
Defendants cite Maltby v. Tautges, 50 Minn. 248, 252, 52 N.W. 858, 859 (1892), to support their contention that an area may be found to be a taxing district without the legislature expressly designating it as such. There, Mr. Justice Mitchell, again writing for the court, stated:
"The purpose to be accomplished by a tax must, of course, pertain to the district taxed. The purpose must be one which pertains in an especial manner to the district taxed, and which concerns the people of that district more particularly than it does others. Generally the nature of the case will itself conclusively fix the taxing district. For example, if the tax is to pay general state expenses, the whole state will be the taxing district. If it be to pay the general expenses of a county or city, the whole county or city, respectively, will be the taxing district. But, where the nature of the case does not conclusively fix it, the power to determine what shall be the taxing district for any particular burden is purely a legislative power, and not to be interfered with or controlled (except as it may be limited or restrained by constitutional provisions) unless in very extreme and hardly supposable cases, where it clearly appears that the tax in no way pertains to the district taxed, and that it was imposed and apportioned without any reference whatever to any special interest on the part of such district in the purpose to be accomplished."
2. Plaintiffs stress the language in Maltby and other cases which define uniformity in terms of a "special interest" to be enjoyed by those on whom the tax burden falls. The attack on c. 24 is based on the premise that taxes can only be levied to pay for debts incurred by the taxing district having the responsibility for providing goods and services to those who bear the tax. Here, it is argued, the district simply acts as a conduit for its constituent systems of government to redistribute revenues among those units which have the burden of providing services. Plaintiffs point out that the act specifies no new responsibilities for the metropolitan area to assume. They cite a rule adopted as early as 1864 in Sanborn v. Commrs. of Rice County, 9 Minn. 273, 278 (Gil. 258, 262), where we said:
"* * * [A] tax cannot be imposed exclusively on any subdivision of the state, to pay an indebtedness or claim which is not peculiarly the debt of such subdivision or to raise money for any purpose not peculiarly for the benefit of such subdivision."
In essence, the issue then is whether those units of government within the metropolitan area which in a given year contribute more of their tax base to the pool than is redistributed to them are sufficiently benefited to meet the constitutional requirement of uniformity. A number of Minnesota cases are cited by both parties for support of their positions. A brief discussion of them is in order. The Maltby case which we have quoted involved the construction by the county of a road and approach to a bridge in Burnsville, the expense of which under the statute was to be borne by adjacent communities in proportion to the benefits each realized from the project. We sustained the validity of the statutory authority for assessing individual units of government, notwithstanding the fact that the improvement was located in only one of them. The test of uniformity there applied was the particular unit's interest in the improvement, rather than the location of the improvement.
3. Two of our decisions have held that the uniformity clause applies to distribution of revenue as well as to the levy of taxes. *530 State ex rel. City of New Prague v. County of Scott, 195 Minn. 111, 261 N.W. 863 (1935); Village of Robbinsdale v. County of Hennepin, 199 Minn. 203, 271 N.W. 491 (1937). We are invited by defendants to reconsider and overrule those cases to the extent they hold that uniformity in distribution is required.
In New Prague, a statute was held to violate the uniformity clause where it authorized reimbursement to the city of New Prague of monies collected by Scott County for road and bridge purposes. We held it manifestly improper to relieve some taxing units of a burden imposed on others for services rendered both. The New Prague case is of little assistance to a resolution of the issues at hand since it appears to hold only that an arbitrary exemption of one unit of government receiving a benefit denies the other units, which bear the tax burden, the uniformity required by the constitution. In Hassler v. Engberg, 233 Minn. 487, 512, 48 N.W.2d 343, 358 (1951), we said that the statute in New Prague was held unconstitutional because there was no claim of difference in conditions between that city and other municipalities which would justify differences in treatment with respect to road and bridge taxes. Robbinsdale held unconstitutional a statute which permitted municipalities other than cities of the first and second class to recover from Hennepin County 75 percent of what the municipality spent for poor relief in excess of a 1-mill tax on municipal property. The city of Minneapolis paid 92 percent of the taxes levied by the county, but was excluded from participating in the reimbursement. Robbinsdale argued that since the levy was uniform, Minn.Const. art. 9, § 1, was satisfied notwithstanding the distribution was not uniform. This distinction we rejected, citing New Prague. We concluded by saying (199 Minn. 207, 271 N.W. 493):
"* * * It is settled law in this state that where it clearly appears that the tax imposed in no way pertains to the district taxed and that it was imposed and apportioned without any reference whatsoever to any special interest on the part of such district in the purpose to be accomplished, the tax so imposed is unconstitutional as in violation of the uniformity clause."
The distribution of the tax was of special interest only to municipalities other than cities of the first and second class, who received no benefit from it but paid substantially all of the tax.
Subsequently, in City of Jackson v. County of Jackson, 214 Minn. 244, 7 N.W.2d 753 (1943), we said that the purpose of a tax must pertain to the district taxed, that poor relief was not the obligation or concern of the county, and that to reimburse from county funds municipalities providing poor relief did not pertain to any purpose of the county, which was the district taxed. In other words, county funds could not be used to pay obligations imposed by law on its political subdivisions without violating the uniformity clause.
4. Plaintiffs argue with considerable force that these cases preclude the metropolitan area from disbursing area-wide tax revenues to individual municipalities. We agree that a literal reading of our prior opinions supports plaintiffs' position. Our decision to reverse therefore hinges on what we deem to be a developing concept of the meaning of the word "benefit." It seems to us that the phrase "special benefit" no longer adequately serves the constitutional requirement of uniformity. In a seven-county area which is heavily populated, we are of the opinion that it is no longer necessary for units of government providing tax revenue to receive the kind of tangible and specific benefits to which our court has previously referred in order to satisfy the uniformity clause. We moved away from the strict application of the "special benefits" rule in Visina v. Freeman, 252 Minn. 177, 195, 89 N.W.2d 635, 650 (1958). There, we sustained a statutory scheme which imposed taxes in varying amounts on separate units of government which received in different degrees general benefits from the establishment of the Port Authority of Duluth. *531 We there said (252 Minn. 193, 89 N.W.2d 648):
"While the plain meaning of language used in our fundamental law may not be tampered with to accomplish a desired result no matter how archaic it has become by virtue of social and economic changes which have occurred since its adoption, neither should the proper interpretation of constitutional provisions ignore such changes. In determining whether an act of the legislature contravenes a constitutional provision we should endeavor to interpret the provision in the light of existing conditions, particularly when those conditions could not have been foreseen at the time the constitution was adopted."
In disposing of the contention that the Port Authority Act was in violation of Minn.Const. art. 9, § 1, we observed that absolute equality of taxation has never been required or attained; that there are always those who must pay taxes from which they derive no direct benefit; and that the legislature may constitutionally apportion taxes among those who bear the financial burden if they have a reasonable relationship to the benefits to be derived. In sustaining the tax, we pointed out that the city of Duluth would bear the greatest burden and enjoy the greatest benefits and that, in descending order, the residents of St. Louis County and of the state as a whole would benefit from increased traffic and the availability of cheaper transportation for the products exported and imported. Visina foreshadowed the decision we here reach.
5. Without unduly protracting this opinion, it is appropriate to comment on San Antonio School District v. Rodriguez, 411 U.S. 1, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973). That case, in some respects, was the converse of this. There, in a class action parents of Texas school children sought and obtained a decision of the Federal District Court holding that disparities in school expenditures which prevailed in San Antonio and elsewhere denied poor districts equal protection of the law. The United States Supreme Court reversed. In so doing, the majority quoted the following with approval (411 U.S. 40, 93 S.Ct. 1300, 36 L.Ed.2d 47):
"`The broad discretion as to classification possessed by a legislature in the field of taxation has long been recognized * * *. [T]he passage of time has only served to underscore the wisdom of that recognition of the large area of discretion which is needed by a legislature in formulating sound tax policies. * * * It has * * * been pointed out that in taxation, even more than in other fields, legislatures possess the greatest freedom in classification. Since the members of a legislature necessarily enjoy a familiarity with local conditions which this Court cannot have, the presumption of constitutionality can be overcome only by the most explicit demonstration that a classification is a hostile and oppressive discrimination against particular persons and classes * * *.' Madden v. Kentucky, 309 U.S. 83, 87-88 [60 S.Ct. 406, 408, 84 L.Ed. 590, 593] (1940)."
The court went on to say (411 U.S. 41, 83 S.Ct. 1301, 36 L.Ed.2d 48):
"* * * No scheme of taxation, whether the tax is imposed on property, income, or purchases of goods and services, has yet been devised which is free of all discriminatory impact. In such a complex arena in which no perfect alternatives exist, the Court does well not to impose too rigorous a standard of scrutiny lest all local fiscal schemes become subjects of criticism under the Equal Protection Clause."[6]
*532 Finally, in upholding the reliance of Texas school authorities on local property taxes to finance the system, the United States Supreme Court encouraged "innovative new thinking" in school funding but left the ultimate solution to lawmakers and "the democratic pressures of those who elect them." 411 U.S. 58, 59, 93 S.Ct. 1310, 36 L.Ed.2d 58.
The broad principles in the Rodriguez decision to which we have alluded are pertinent to the resolution of the fiscal disparities problems to which the Minnesota legislature addressed itself in adopting c. 24. The fiscal disparities statute is a bold and imaginative departure from conventional devices for balancing the benefits and burdens of taxation. As we have suggested, we are quick to concede that a strict application of our prior decisions would require us to lean strongly for affirmance. The trial court cannot be faulted for reading those decisions as it did. Nevertheless, we are today dealing with a viable, fluid, transient society where traditional concepts of what confers a tax benefit may be too parochial.
We find the arguments of defendants persuasive. Under existing tax practices, in order to improve their fiscal capacity, local units of government vie for commerce and industry to improve the fiscal capacity of its residents without considering the resulting impact on long-range planning and the utilization of their resources. The seven-county metropolitan area, it is pointed out, has a high degree of mobility and political, social, and economic interdependence. There is an increasing use of facilities in one municipality by those who reside or work in a different municipality. The payment of taxes in a metropolitan area may have only slight relationship to the use and enjoyment which residents make of other areas in the district. Defendants argue effectively that the indiscriminate encouragement of commerce and industry in a particular municipality may detrimentally and irretrievably affect policies and plans for the development of parks and open spaces and frustrate well-considered housing policies for both low-income and moderate-income residences. The Fiscal Disparities Act recognizes that to some extent the location of commercial-industrial development may be irrelevant to the question of the cost of services which are added to a municipality's budget occasioned by the location of such a development within its boundaries. It should be borne in mind that all commercial-industrial property except 40 percent of its increment since January 1971 remains in the tax base for the municipality where it is located.
In other words, in terms of traditional balancing of benefits and burdens, the benefits conferred on residents of a particular municipality because of the location of commercial-industrial development within its boundaries may far exceed the burdens imposed on that municipality by virtue of the additional cost of servicing and policing the particular development which has located there. It is the theory of the Fiscal Disparities Act that the residents of highly developed commercial-industrial areas do enjoy direct benefits from the existence of adjacent municipalities which provide open spaces, lakes, parks, golf courses, zoos, fairgrounds, low-density housing areas, churches, schools, and hospitals.
We have concluded that the statutory scheme for revenue sharing embodied in c. 24 reaches a constitutional accommodation between the tax burdens imposed and the benefits derived therefrom to a degree which satisfies the requirements of the uniformity provisions of Minn.Const. art. 9, § 1. In reaching our decision, we echo and paraphrase what was said in Rodriguez. *533 The legislature enjoys a familiarity with the problems of fiscal disparities which is denied the courts. The presumption of constitutionality which the statute enjoys has not been overcome by any explicit demonstration that its application results in a "hostile and oppressive discrimination" against the residents of particular units of government. Accordingly, the judgment of the district court is reversed.
Reversed.
APPENDIX A
COMMERCIAL-INDUSTRIAL SEVEN COUNTY METROPOLITAN AREA-WIDE TAX BASE (40% OF COMMERCIAL-INDUSTRIAL ASSESSED VALUATION GROWTH; 1972 OVER 1971)
40% OF COMMERCIAL-INDUSTRIAL
ASSESSED VALUATION GROWTH
-----------------------------------------
Anoka County Contribution Distribution Net
Anoka $104,484 $391,469 $286,985
Bethel 6,760 23,026 16,266
Blaine (Pt) 681,625 1,045,962 364,337
Burns Twp. 11,451 35,949 24,498
Centerville 3,019 23,087 20,068
Circle Pines 8,728 176,570 167,842
Columbia Hts. 391,550 749,624 358,074
Columbia Twp. 10,195 72,337 62,142
Coon Rapids 1,172,864 1,163,631 9,233
East Bethel 41,240 111,116 69,876
Fridley 1,912,236 764,414 1,147,822
Grow Twp. 29,290 176,277 146,987
Ham Lake Twp. 75,819 124,356 48,537
Hilltop 27,353 60,561 33,208
Lexington 11,531 119,951 108,420
Lino Lakes 201,234 153,959 47,275
Linwood Twp. 1,348 31,995 30,647
Oak Grove Twp. 5,598 69,628 64,030
Ramsey Twp. 30,622 109,505 78,883
St. Francis 16,244 39,219 22,975
Spring Lake Park (Pt.) 0 250,005 250,005
Total 4,743,191 5,692,641 949,450
Carver County Contribution Distribution Net
Benton 48,442 15,424 33,018
Camden Twp. 0 19,353 19,353
Carver 3,817 39,390 35,573
Chanhassen (Pt.) 69,555 125,869 56,314
Chaska 254,694 181,537 73,157
Chaska Twp. 0 2,294 2,294
Cologne 15,352 22,916 7,564
Dahlgren Twp. 18,105 27,712 9,607
Hamburg 5,578 13,740 8,162
Hancock Twp. 258 6,602 6,344
Hollywood Twp. 0 25,406 25,406
Laketown Twp. 0 42,501 42,501
Mayer 6,615 16,559 9,944
New Germany 12,313 13,923 1,610
Norwood 17,259 55,216 37,957
San Francisco Twp. 1 11,336 11,335
Victoria 15,558 24,015 8,457
Waconia 57,972 85,454 27,482
Waconia Twp. 0 34,850 34,850
Watertown 70,371 70,226 145
Watertown Twp. 22,363 37,230 14,867
Young America 13,906 26,150 12,244
Young America Twp. 0 14,899 14,899
Total 632,159 912,602 280,443
*534
Dakota County Contribution Distribution Net
Apple Valley 287,847 303,415 15,586
Burnsville 0 417,741 417,741
Castle Rock Twp. 16,726 30,079 13,353
Coates 6,574 8,688 2,114
Douglas Twp. 685 8,237 7,552
Eagan 1,177,323 223,050 954,273
Empire Twp. 0 27,822 27,822
Eureka Twp. 0 17,218 17,218
Farmington 20,998 99,097 78,099
Greenvale Twp. 0 11,031 11,031
Hampton 0 16,364 16,364
Hampton Twp. 38 10,897 10,859
Hastings (Pt.) 0 457,399 457,399
Inver Grove Hts. 3,951,825 450,321 3,501,504
Lakeville 557,178 247,760 309,418
Lilydale 0 12,862 12,862
Maishan Twp. 19,879 30,994 11,115
Mendota 0 8,859 8,859
Mendota Heights 352,619 128,090 224,529
Meisville 0 5,577 5,577
New Tries 0 15,571 15,571
Nininger Twp. 0 14,118 14,118
Randolph 4,010 20,964 16,954
Randolph Twp. 19,856 3,734 16,122
Ravenna Twp. 0 22,282 22,282
Rosemount 0 53,410 53,410
Sciota Twp. 0 2,721 2,721
South St. Paul 0 712,968 712,968
Sunfish Lake 133 3,405 3,272
Vermillion 0 15,180 15,180
Vermillion Twp. 10,749 15,705 4,956
Waterford Twp. 0 11,946 11,946
West St. Paul 150,811 505,745 354,934
Total 6,577,251 3,913,250 2,664,001
Hennepin County Contribution Distribution Net
Bloomington 4,226,674 1,711,157 2,515,517
Brooklyn Center 717,898 1,046,096 328,198
Brooklyn Park 1,012,165 1,028,049 15,884
Champlin 31,818 174,191 142,373
Chanhassen (Pt.) 0 952 952
Corcoran 17,085 35,412 18,327
Crystal 0 988,110 988,110
Dayton (Pt.) 41,120 93,142 52,022
Deephaven 70,989 71,836 847
Eden Prairie 1,402,556 102,489 1,300,067
Edina 2,741,058 605,562 2