Justia Real Estate & Property Law Opinion Summaries

Renee Vasko challenged her property tax assessment on two grounds: the revocation of her homestead classification and the assessed value of her property. In 2018, McLeod County sent a homestead application to Vasko’s property address, which was returned as undeliverable. The County learned from the City of Lester Prairie that there had been no measurable water use at the property since 2016. Consequently, the County revoked the homestead classification effective January 2, 2019, and assessed the property at $110,100.Vasko filed a petition in the Minnesota Tax Court, disputing the revocation of the homestead classification and the property’s assessed value. She presented evidence, including mail addressed to the property, utility records, and testimony, to establish occupancy and use of the property. Vasko also compared her property’s valuation to five other properties in the City to argue that her home was overvalued. The Tax Court found that Vasko did not occupy and use the property as a homestead in 2019 and upheld the County’s valuation, concluding that Vasko did not provide sufficient evidence to rebut the presumptive validity of the County’s assessment.The Minnesota Supreme Court reviewed the case and affirmed the Tax Court’s decision. The Court held that the Tax Court correctly placed the burden of proof on Vasko to show that the revocation of the homestead classification was unlawful and that the assessed value was incorrect. The Supreme Court found no clear error in the Tax Court’s findings that Vasko did not occupy and use the property as a homestead and that she failed to provide substantial evidence to challenge the County’s valuation. The decision of the Tax Court was affirmed. View "Vasko vs. County of McLeod" on Justia Law

The case involves the valuation of two commercial properties in a Woodbury shopping center for tax purposes. The taxpayer, Tamarack Village Shopping Center, LP, challenged Washington County’s initial assessments of the properties, arguing that the tax court should have used an effective rent calculation to account for tenant improvement allowances and deducted lease-up costs due to an above-market vacancy rate.The tax court heard testimony from the taxpayer’s real property asset manager, the taxpayer’s expert appraiser, and the County’s expert appraiser. The tax court largely accepted the County’s appraiser’s opinions and rejected the taxpayer’s appraiser’s opinions. The tax court’s final value conclusions increased the properties’ assessed market values over the county assessor’s initial valuations. The taxpayer appealed, contending that the tax court erred in its analysis by not using an effective rent calculation and by not deducting lease-up costs.The Minnesota Supreme Court reviewed the case. The court held that the tax court did not err in declining to use an effective rent calculation because the taxpayer’s tenant improvement allowances were typical of the market. The court also found that the tax court did not clearly err in declining to deduct lease-up costs from the property’s indicated value to account for its above-market vacancy rate, as the taxpayer failed to show that such a deduction was required. The court affirmed the tax court’s decision, upholding the increased assessed market values of the properties. View "Tamarack Village Shopping Center, LP vs. County of Washington" on Justia Law

Fitness International, LLC ("Fitness") entered into a lease agreement with City Center Ventures, LLC ("City Center") for a property in Hopkins, Minnesota, where Fitness operated a health club. Due to executive orders during the COVID-19 pandemic, Fitness was mandated to close its business for approximately 3.5 months in 2020. Fitness sought to recover the rent paid during these closure periods, arguing that the doctrine of frustration of purpose excused its obligation to pay rent during the mandatory closure.The Hennepin County District Court granted summary judgment in favor of City Center, concluding that Fitness's obligation to pay rent was not excused. The Minnesota Court of Appeals affirmed, noting that Fitness cited no binding authority allowing the doctrine of frustration of purpose to establish a breach-of-contract claim. The court of appeals also determined that the mandatory COVID-19 closures did not prohibit all permitted uses of the property, thus not substantially frustrating the lease's purpose.The Minnesota Supreme Court reviewed the case to consider the doctrine of frustration of purpose. The court recognized that the Restatement (Second) of Contracts §§ 265 and 269 provide appropriate frameworks for analyzing claims of permanent and temporary frustration of purpose, respectively. However, the court did not decide whether the doctrine could be used affirmatively for a breach-of-contract claim. Instead, it concluded that even if Fitness could pursue such a claim, the obligation to pay rent was only suspended, not discharged, during the temporary frustration. Since Fitness did not establish that paying rent after the closure would be materially more burdensome, the court affirmed the lower courts' decisions, denying Fitness's claim for rent recovery.The Minnesota Supreme Court affirmed the decision of the court of appeals, holding that Fitness's obligation to pay rent was merely suspended during the temporary frustration and not discharged. View "Fitness International, LLC v. City Center Ventures, LLC" on Justia Law

David Hepfl and Jodine Meadowcroft had a complex romantic history, including two marriages and divorces. After their second divorce, they reconciled in 2016 and decided to build a cabin on Meadowcroft's property, which she had retained as nonmarital property. Hepfl paid for the construction and furnishing of the cabin, as well as additional structures like a dock and outhouse. Their relationship ended again in October 2020, and Meadowcroft obtained an Order for Protection (OFP) against Hepfl. Hepfl then filed a civil action alleging unjust enrichment to recover the cabin and its associated fixtures and furnishings or reasonable payment.The district court ruled in favor of Hepfl, concluding that Meadowcroft would be unjustly enriched if she retained the cabin and its associated items without compensating Hepfl. The court found that Hepfl had no intention of gifting the cabin to Meadowcroft and that his contributions were made with the expectation of shared use. Meadowcroft's motion for amended findings was denied, and she was ordered to pay Hepfl for the construction costs and return or compensate for the additional items.The Minnesota Court of Appeals affirmed the district court's decision, agreeing that Meadowcroft's retention of the cabin would result in unjust enrichment. The court noted that Hepfl's contributions were made with the expectation of shared use and that Meadowcroft's actions induced him to make these expenditures.The Minnesota Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that Hepfl did not need to show that Meadowcroft engaged in morally wrongful conduct to succeed in his unjust enrichment claim. Instead, it was sufficient that Meadowcroft's retention of the cabin and its associated items would be inequitable under the circumstances. The court emphasized that unjust enrichment claims between former partners in a cohabitating, marriage-like relationship should focus on the equities of the situation rather than the conduct of the parties. View "Hepfl v. Meadowcroft" on Justia Law

The case revolves around a dispute over attorney fees awarded under Minnesota Statutes section 117.031(a) in an eminent domain proceeding. The State of Minnesota, through the Department of Transportation (MnDOT), seized a portion of Joseph Hamlin's property under the "quick take" provision of Minnesota eminent domain law. Hamlin was awarded attorney fees after the compensation he received was more than 40% greater than MnDOT's final offer. The attorney fees awarded exceeded the amount Hamlin owed his attorney under a contingent fee agreement.MnDOT appealed the district court's decision, arguing that the term "reasonable" in section 117.031(a) should limit the attorney fee award to the amount owed in the contingent fee agreement. The district court had applied the lodestar method (a method for calculating attorney fees based on the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate) and awarded Hamlin $63,228 in attorney fees. The court of appeals affirmed the district court's decision, holding that "reasonable attorney fees" in section 117.031(a) are calculated under the lodestar method and are not limited by any existing agreement between the landowner and his attorney.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court reiterated its previous holding in County of Dakota v. Cameron that "reasonable attorney fees" in section 117.031(a) refers to attorney fees calculated by the lodestar method. Therefore, an award of reasonable attorney fees is not capped by a contingent fee agreement. The court concluded that a landowner's fee agreement with their attorney does not limit an award of attorney fees because "reasonable attorney fees" under section 117.031(a) means attorney fees calculated using the lodestar method. View "State v. Schaffer" on Justia Law

The case revolves around Lisa Stone, a tenant who signed a lease agreement that required her to provide maintenance services for which she alleges she was not compensated, in violation of Minnesota law. She initiated a class-action lawsuit against Invitation Homes, Inc., the parent company of her landlord, and THR Property Management, L.P., the manager of the leased property. Stone later amended her complaint to include various subsidiaries of Invitation Homes as defendants. Some of these subsidiaries argued that Stone lacked standing to sue them as she had not alleged that they had caused any injuries.The district court denied the subsidiaries' motion to dismiss. The subsidiaries appealed this decision to the court of appeals, which reversed the district court's decision and dismissed Stone's claims against the subsidiaries. The court of appeals reasoned that Stone lacked standing to bring her claims under the theory for standing found by the district court, and the juridical-link doctrine was improperly raised by Stone for the first time on appeal and did not apply in this case.Stone appealed to the Supreme Court of Minnesota, arguing that she has standing against the subsidiaries under the juridical-link doctrine. This doctrine posits that in a class action in which a named plaintiff has not alleged an injury caused by all defendants, a class may be certified when all defendants are linked by a conspiracy or concerted scheme that harmed the class. However, the Supreme Court affirmed the decision of the court of appeals, stating that Stone had forfeited the ability to have the merits of standing under the juridical-link doctrine determined on appeal as she failed to assert standing based on the juridical-link doctrine in the district court. View "Stone, vs. Invitation Homes, Inc." on Justia Law

The Minnesota Supreme Court reversed a decision by the Court of Appeals, ruling that the district court did not abuse its discretion in certifying an order as a final partial judgment under Minnesota Rule of Civil Procedure 54.02. The case arose from a dispute between the City of Elk River and Bolton & Menk, Inc. over a large construction contract for a wastewater treatment plant improvement project. The City sued Bolton for alleged breach of contract and professional negligence. Bolton responded by filing a third-party complaint against three other parties involved in the contract. The district court dismissed Bolton's third-party complaint and Bolton sought to have the dismissal order certified as a final judgment for immediate appeal. The district court granted this certification, but the Court of Appeals dismissed Bolton's appeal, determining that the district court had abused its discretion in certifying the order as a final judgment. The Minnesota Supreme Court disagreed, finding that the district court had offered valid reasons for its certification, including that the third-party claims presented distinct issues from the principal claims and that the case was in its early stages at the time of certification. The Supreme Court therefore reversed the decision of the Court of Appeals and remanded the case for further proceedings. View "City of Elk River vs. Bolton & Menk, Inc." on Justia Law

The Supreme Court held that, under Minnesota statutes in a condemnation proceeding, Blue Earth County did not owe just compensation to Landowners for the loss of a right to access to a newly constructed controlled-access highway built across their property.The district court ruled that Landowners had not been deprived of any right of access for which they should be justly compensated, noting that the County continued to provide farm access to Landowners' property. The court of appeals affirmed. The Supreme Court affirmed, holding that a person who owns property abutting a newly constructed controlled-access highway has no right of access to the controlled-access highway. View "Wood v. County of Blue Earth" on Justia Law

The Supreme Court reversed the conclusions of the district court and court of appeals that Minn. Stat. 515B.2-118(b), a statute of limitations contained within the Minnesota Common Interest Ownership Act, applied to bar Appellant's claims in this case, holding that the lower courts erred.Appellant owned and operated a common interest community in Richfield that was registered under the Act in 2004. Following a repair project, Appellant sought commercial contributions from Respondent, who refused under the belief that its property interest had been severed from the community. Both parties brought actions seeking declarations as to whether Respondent was required to contribute to the repair project. Respondent cited an amended declaration, recorded in 2007, in arguing that it was not a member of the community and thus not responsible for contributions. The district court and court of appeals concluded that section 515B.2-118(b) applied to bar Appellant's claims. The Supreme Court reversed, holding that the statute of limitations contained in section 515B.2-118 for challenging the validity of an amendment or supplemental declaration does not bar an action that broadly challenges not the underlying validity of an amended declaration but whether severance occurred under the statute. View "City Bella Commercial, LLC v. City Bella on Lyndale" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the tax court that the taxable 2018 market value of a DoubleTree in Bloomington was $25,500,000, an amount that exceeded the valuations offered by the DoubleTree's owner and the County of Hennepin, holding that remand was required on a single issue.The County initially assessed the value of the DoubleTree property at $31,586,400, but Relator, the DoubleTree's owner, appealed the valuation to the tax court. After a trial, the tax court determined that the taxable 2018 market value of the DoubleTree was $25,500,000. The Supreme Court vacated the judgment in part and otherwise affirmed, holding that remand was required for the tax court to revisit and explain its adoption of the percentage reduction to the sales price of one of the hotels it used in its sales comparison analysis to account for non-taxable assets included in the sales price of comparator hotels. View "Bloomington Hotel Investors, LLC v. County of Hennepin" on Justia Law