1. Whether valuation-based building permit fees are exempt from unconstitutional conditions analysis under Koontz v. St. Johns River Water Management District, 570 U.S. 595 (2013).

2. Whether the Cities' building permit fees are "user fees" exempt from the Takings Clause.

3. Whether the lower court properly determined on summary judgment that the Cities' building permit fees are user fees when no court has ruled the Cities' building permit fees valid under Minnesota law requiring proportionality between the fees and the Cities' actual cost of remanded to the trial court for adjudication.

Whether valuation-based building permit fees are exempt from unconstitutional conditions analysis under Koontz and constitute 'user fees' not subject to the Takings Clause