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A. Primary Jurisdiction Under the primary-jurisdiction doctrine, a court can stay judicial proceedings if a case rais es “issues of fact not within the conventional experience of judges or cases requiring the exercise of administrative discretion to permit agency consideration of the matter.” (quotation omitted).

Appellate courts “presume that the Legislature does not intend to abrogate the common law unless it does so by express wording or necessary implication.” (quotation omitted); (declining to view legislative silence as overruling similar common-law requirement in child- support context).

rt articulated a three- factor test to determine whether changes or additions made to real property meet this definition: “[1] whether the addition or betterment is permanent, [2] whether it enhances the capital value of the property, and [3] whether it is designed to make the real property more useful or valuable, rather than intended to restore the property’s previous usefulness or value.”

in which the supreme court concluded that summary judgment was improper because the plaintiffs had sufficiently claim ed negligent maintenance, operation, and inspection.

arred by Minn. Stat. § 541.051.3 The district court held that Robinson’s work was “construction” under section 541.051, reasoning that it was not “merely demolition” because it was “integral to the installation of an updated boiler system.” The district court further held that Robinson’s work was an “improvement” to Moore’s

7, 1980, ch. 518, §§ 2–4, 1980 Minn. Laws 595, 595–96

Ratemaking is a legislative function delegated to government agencies and, “under separation -of-powers principles, courts should not second-guess the reasonableness or lawf ulness of agency -approved rates.” (citing Schermer v. State Farm Fire & Cas.

“We independently review whether a question is important and doubtful.” Siewert v. N. States Power Co. , aff’d, see also Emme v. C.O.M.B., Inc. , -81 (Minn. 1988) 6 (applying de novo review to determine whether a question is important and doubtful).

We use a common-sense approach to this determination of whether something is an “improvement to real property.”

“Stray voltage is a phenomenon in which an electrical current—voltage that returns to the ground after powering an appliance—passes through an obj ect not intended as a conductor.” Siewert v. N. States Power Co.

" Siewert v. N. States Power Co. , , 281 (Minn. 2011) (quoting Wirig v. Kinney Shoe Corp. , , 377-78 (Minn. 1990) ).

Stray voltage is “a phenomenon in which an electrical current—voltage that returns to the ground after powering an appliance—passes through an obj ect not intended as a conductor.” Siewert v. N. States Power Co.

Courts apply a “common-sense interpretation” of the phrase “imp rovement to real property.” (quotation omitted).

Siewert v. N. States Power Co. , , 286 (Minn. 2011) (internal quotation marks omitted) (quoting Pac.

See Siewert v. N. States Power Co. , , 277 (Minn. 2011) ; Hoffman v. N. States Power Co. , , 42 (Minn. 2009) ; Watson ex rel.

lar argues there is “no factual support for a de nial based on alleged concerns about stray voltage and corresponding ‘incompatibility’ with agricultural land use in the area.” Stray voltage is “a phenomenon in which an electrical current—voltage that returns to the ground after powering an appliance—pa sses through an object not i ntended as a conductor.” Siewert v. N. States Power Co.

Siewert v. N. States Power Co.

at 321 ( holding that because statutes did not unambiguously grant authority for DNR to certify city’s variance decision and there is no implied authority for such certification , DNR did not have express or implied authority to do so); n.2 (Minn. 2011) ( applying Hubbard analysis in deciding whether Minnesota Publi c Utilities Commission had express or implied authority to exercise jurisdiction over common law tort claims against public utilities).

rovides, “Nothing in this section shall apply to actions for damages resulting from negligence in the maintenance, operation or inspection of the real property improvement against the owner or other person in possession.” “There are two requirements to the exception—one based on what kind of action is involved and the other based on whom the action is against.”

(“Utilities and similar installations have generally been considered real property improvements in Minnesota.”); Nolan & (concluding that “storm sewer system is an improvement to real property as contemplated by Minn. Stat. § 541.051”)

B. Stray Voltage The supreme court has described stray voltage as “a phenomenon in which an electrical current — -voltage that returns to the ground after powering an appliance— passes through an object not intended as a conductor.”

We presume that “the Legislature does not intend to abrogate the common law unless it does so by express wording or necessary implication.” (citations omitted) (internal quotation marks omitted).

Swan Lake II, d at 538 ; -86 (Minn.2011) (declining to apply primary jurisdiction doctrine).