Hamlin v. Ladd

9 Citing cases

  1. Schwartz v. Talmo

    295 Minn. 356 (Minn. 1973)   Cited 48 times
    Using the phrase "guiding principles" when listing factors to consider in equal protection challenges

    (3) the classification is germane or relevant to the purpose of the law; that is, there must be an evident connection between the distinctive needs peculiar to the class and the remedy or regulations therefor which the law purports to provide. Loew v. Hagerle Brothers, 226 Minn. 485, 33 N.W.2d 598 (1948); Hamlin v. Ladd, 217 Minn. 249, 14 N.W.2d 396 (1944); Eldred v. Division of Employment Security, 209 Minn. 58, 295 N.W. 412 (1940); Arens v. Village of Rogers, 240 Minn. 386, 61 N.W.2d 508 (1953), appeal dismissed, 347 U.S. 949, 74 S.Ct. 680, 98 L.ed. 1096 (1954); Kellerman v. City of St. Paul, 211 Minn. 351, 1 N.W.2d 378 (1941); Gardner v. County of Itasca, 280 Minn. 51, 157 N.W.2d 753 (1968). Another fundamental principle frequently stated is that one alone may constitute a class as well as a thousand, but the fewer there are in a class, the more closely the courts will scrutinize the act to see if its classification constitutes an evasion of the constitution.

  2. Loew v. Brothers

    226 Minn. 485 (Minn. 1948)   Cited 34 times
    In Loew, we applied equal protection principles to a claim brought under the Special Legislation clause of the Minnesota Constitution.

    1 Dunnell, Dig. Supp. §§ 1669 and 1679. Gunderson v. Williams, 175 Minn. 316, 221 N.W. 231; Hamlin v. Ladd, 217 Minn. 249, 14 N.W.2d 396. Gunderson v. Williams, supra; Eldred v. Division of Employment Security, 209 Minn. 58, 295 N.W. 412.

  3. Fletcher Props., Inc. v. City of Minneapolis

    947 N.W.2d 1 (Minn. 2020)   Cited 23 times
    Concluding that, in an equal protection challenge to a Minneapolis ordinance that regulated the circumstances under which a residential landlord could refuse to rent because of housing voucher requirements, the relevant group for the threshold similarly situated comparison was residential landlords

    To assemble the three-part test, Loew pulled together different "principles" and "fundamental rule[s]" that we had applied in even earlier cases to help courts assess whether legislative classifications passed constitutional muster in a variety of contexts. SeeHamlin v. Ladd , 217 Minn. 249, 14 N.W.2d 396, 399 (1944). The lesson is that the Loew/Talmo/Miller Brewing test is properly conceptualized as a compendium of principles of analysis—some or all of which may apply in a particular case depending on the type of equal protection challenge raised—rather than as a set of elements to establish a constitutional violation.

  4. Williams v. Rolfe

    262 Minn. 284 (Minn. 1962)   Cited 8 times

    "* * * When the classification made by the legislature is called in question, if any state of facts reasonably can be conceived that would sustain it, there is a presumption of the existence of that state of facts, and one who assails the classification must carry the burden of showing by a resort to common knowledge or other matters which may be judicially noticed, or to other legitimate proof, that the action is arbitrary." Plaintiff relies on Hamlin v. Ladd, 217 Minn. 249, 14 N.W.2d 396. The facts in that case are clearly distinguishable from those in the case now before us. L. 1943, c. 15, was involved, purporting to authorize county boards "in all counties of this state containing not less than 46 nor more than 49 full and fractional congressional townships and having a population of not less than 20,000 nor more than 27,500 to fix salaries."

  5. Visina v. Freeman

    252 Minn. 177 (Minn. 1958)   Cited 52 times
    Stating that “the right to amend the constitution rests with the people and should not be usurped by the courts in the guise of judicial interpretation” in order to achieve a desired result

    In that case we established certain rules to determine if a statute violated the above constitutional provision, which rules have since been followed. These rules were summarized in Hamlin v. Ladd, 217 Minn. 249, 252, 253, 14 N.W.2d 396, 399, as follows: (1) A law is general when it is uniform in its operation even though it divides the subjects of its operation into classes and applies different rules to different classes.

  6. Arens v. Village of Rogers

    240 Minn. 386 (Minn. 1953)   Cited 51 times
    Discussing Have-land, 223 Minn. 89, 25 N.W.2d 474, as stating that a taxpayer's constitutional challenge to a statute that exempts money from taxation is not a legally protectable interest but merely an academic interest

    This court has had frequent occasion to consider in detail the necessary requirements for a classification to be valid. See, Loew v. Hagerle Brothers, 226 Minn. 485, 33 N.W.2d 598; Hamlin v. Ladd, 217 Minn. 249, 14 N.W.2d 396. These requirements are well summarized in State ex rel. Youngquist v. Common School Dist. No. 78, 180 Minn. 44, 47, 230 N.W. 115, 116, as follows:

  7. Kaljuste v. Hennepin County Sanatorium Commission

    240 Minn. 407 (Minn. 1953)   Cited 20 times
    Stating that we will not "speculate upon the considerations which motivate the legislature" and noting that the question of classification "is primarily for the legislature"

    The only practical limitation to the power of the legislature to make any classification is that the classification shall be based upon some reason suggested by necessity or by some difference in the situation and circumstances of the subjects classified suggesting the necessity of different legislation with respect to them. State ex rel. Bd. of Commrs. v. Cooley, 56 Minn. 540, 58 N.W. 150; Hassler v. Engberg, 233 Minn. 487, 48 N.W.2d 343; Hamlin v. Ladd, 217 Minn. 249, 14 N.W.2d 396; 3 Dunnell, Dig. (3 ed.) §§ 1677, 1679. As stated in State ex rel. Douglas v. Westfall, 85 Minn. 437, 439, 89 N.W. 175, 176, 57 L.R.A. 297:

  8. State ex rel. Paff v. Kelley

    235 Minn. 350 (Minn. 1952)   Cited 2 times

    State ex rel. Douglas v. Ritt, 76 Minn. 531, 79 N.W. 535; Murray v. Board of Co. Commrs. 81. Minn. 359, 84 N.W. 103, 51 L.R.A. 828; State ex rel. Town of Sargeant v. County of Mower, 185 Minn. 390, 241 N.W. 60. On its facts, the instant case is similar to Hamlin v. Ladd, 217 Minn. 249, 14 N.W.2d 396. In that case, under an act of the legislature the board of county commissioners fixed the salary of the register of deeds of Pine county.

  9. George Benz Sons, Inc. v. Ericson

    227 Minn. 1 (Minn. 1948)   Cited 16 times
    Finding that controlling sales by manufacturers and wholesalers but not controlling sales by retailers was arbitrary

    "* * * it is to be remembered that one alone may constitute a class as well as a thousand; but, the fewer there are in a class, the more closely will courts scrutinize an act to see if its classification constitutes an evasion of the constitution." Hamlin v. Ladd, 217 Minn. 249, 253, 14 N.W.2d 396, 399 (cited in Loew v. Hagerle Brothers, 226 Minn. 485, 33 N.W. [2d] 598). (e) The separate clauses of the Fourteenth Amendment guaranteeing due process of law and equal protection of the laws refer to separate rights.