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Charter Cable Partners, LLC v. City of Lakeville

Citations: 43 F. Supp. 3d 943; 2014 U.S. Dist. LEXIS 128173; 2014 WL 4450458Docket: Civ. No. 13-3111 (RHK/JSM)

Court: District Court, D. Minnesota; September 2, 2014; Federal District Court

Narrative Opinion Summary

The case arises from a dispute over a 1998 Cable Television Franchise Agreement between Charter Cable Partners, LLC and the City of Lakeville, Minnesota. The Agreement granted Charter exclusive rights to provide cable services in exchange for a 5% franchise fee and an additional $0.50 per subscriber per month to fund educational and governmental access, which Charter did not collect upon alleged city instruction. In 2013, as the Agreement approached renewal, the City demanded Charter collect the fees and sought nearly $1 million in arrears, leading Charter to seek a declaratory judgment of no obligation and asserting estoppel or waiver. The City counterclaimed for breach but later withdrew its findings and sought to dismiss its counterclaim as moot. The court agreed, finding the withdrawal rendered the case moot due to lack of a live controversy and noting that res judicata would prevent the City from pursuing the breach issue in the future. Charter's concerns of potential future demands were deemed speculative. The court granted the City's motion for dismissal with prejudice and suggested Charter file under Federal Rule of Civil Procedure 54(d)(2) for fee recovery, though it viewed the likelihood of such an award as low. The case is thus concluded with all claims dismissed and no ongoing obligations between the parties.

Legal Issues Addressed

Federal Rule of Civil Procedure 54(d)(2) for Attorney Fees

Application: Charter is instructed to file a motion under the Federal Rule of Civil Procedure 54(d)(2) for recovery of fees incurred due to the City's breach allegation.

Reasoning: Charter is advised to file a motion under Federal Rule of Civil Procedure 54(d)(2) and relevant local rules for fee recovery.

Mootness Doctrine in Declaratory Judgment Actions

Application: The court found that the withdrawal of breach findings and dismissal of the counterclaim rendered the case moot because there was no longer a live controversy.

Reasoning: The Court, however, found that the withdrawal of the breach findings and the dismissal of the counterclaim rendered the case moot, as there was no longer a live controversy.

Res Judicata Preclusion of Future Claims

Application: Once the counterclaim is dismissed, res judicata will prevent the City from raising the breach issue or seeking uncollected fees in the future.

Reasoning: Once the counterclaim is dismissed, res judicata will prevent the City from raising the breach issue or seeking uncollected fees in the future, thus making Charter's request for a declaration unnecessary.

Voluntary Cessation and Mootness

Application: Charter argued the case remained active due to voluntary cessation of conduct, but the court deemed this concern speculative and insufficient to maintain the controversy.

Reasoning: Charter asserts that the case remains active because voluntary cessation of conduct does not moot a case, fearing the City could resume prior allegations of breach.