Skyline Village Park Ass'n v. Skyline Village L.P., 786 N.W.2d 304 (2010)

Citation: Skyline Village Park Ass'n v. Skyline Village L.P., 786 N.W.2d 304 (2010)
Parent Document: Skyline Village Park Ass'n v. Skyline Village L.P., 786 N.W.2d 304 (2010)
Jurisdiction: Minnesota (state)
Effective Date: 2010-07-20
Original Source: https://www.courtlistener.com/opinion/1602295/skyline-village-park-assn-v-sky... ↗

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In August 2009, the parties moved for a declaratory judgment establishing whether manufactured-home-park-lot rent increases are subject to a reasonableness requirement under Minnesota statutes, and if so, how reasonableness is to be evaluated. The district court determined that any requirement for reasonableness set forth in Minn.Stat. § 327C.02 does not apply to increases in the rental rate for a manufae-tured-home-park lot and in the alternative, a determination of whether a rent increase is reasonable is limited to a comparison of market-comparable rents or rent increases. The district court further declared that (1) a determination of whether a manufactured-home-park-lot rent increase is reasonable may not include consideration of the factors set out in MinmStat. § 327C.01, subdivision 8 (2008); (2) a determination of whether a manufactured-home-park-lot rent increase is enforceable may not include consideration of whether it is substantial pursuant to Minn.Stat. § 327C.01, subd. 11 (2008); and (3) the prohibition under Minn.Stat. § 327C.05, subd. 1, against a manufactured-home-park owner’s course of conduct that is unreasonable does not apply to rent increases. The district court entered a final judgment in respondents’ favor, and this appeal followed. ISSUES

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