Save Lake Calhoun v. StrommenAnnotate this Case
The Supreme Court held that the Commissioner of the Department of Natural Resources had the statutory authority to change the official name of a well-known Minneapolis lake from Lake Calhoun to Bde Maka Ska because the forty-year limitation on lake name changes in Minn. Stat. 83A.05, subd. 1 applies only to county boards, not to the Commissioner.
In 2018, the Commissioner invoked his authority under Minn. Stat. 83A.02(1), (3) to change the name of Lake Calhoun to Bde Maka Ska. Respondent argued that section 83A.05's provision prohibiting changing a body of water's name "which has existed for 40 years" applied to the Commissioner's statutory authority to change the lake's name. Respondent petitioned for a writ of quo warranto challenging the Commissioner's authority. The district court denied the petition, concluding that ongoing action was necessary to obtain the writ and that there was no such action here. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) a writ of quo warranto was an appropriate method to challenge the Commissioner's authority in this case; but (2) the Commissioner's authority under section 83A.02(1), (3) to change the name of a lake is not limited by section 83A.05, subd. 1.