Articles Posted in Minnesota Supreme Court

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The Supreme Court affirmed the tax court’s denial of relief to Ronald and Dee Johnson, who filed this action challenging the property taxes that Hennepin County assessed against their property. The tax court granted the County’s motion to dismiss the petition for tax years 2007 through 2012 because those claims were not filed in compliance with Minn. Stat. 278.01-.02 and dismissed the Johnson’s constitutional claims for lack of jurisdiction. The tax court then granted judgment in favor of the County on the Johnsons’ remaining claims challenging the assessment for the 2013 tax year. Thereafter, the tax court denied the Johnsons’ five post-trial motions. The Supreme Court affirmed, holding that the evidence in the record adequately supported each of the tax court’s decisions at issue. View "Johnson v. County of Hennepin" on Justia Law

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At issue in this case was the permissibility of preaward interest on an insurance appraisal award under the preaward interest statute, Minn. Stat. 549.09, subd. 1(b). Cincinnati Insurance Company issued James Poehler a homeowner’s insurance policy that provided replacement cost coverage for Poehler’s home and personal property. After a fire damaged Poehler’s property, Poehler demanded an appraisal under the appraisal clause of the policy. The appraisers issued an award, determining that Poehler’s total loss was more than what Cincinnati had paid by the time of the appraisal hearing. The district court confirmed the appraisal award and granted Poehler preaward interest. The court of appeals reversed, concluding that the preaward interest statute does not apply to appraisal awards pursuant to an insurance policy in the absence of “an underlying breach of contract or actionable wrongdoing.” The Supreme Court reversed, holding (1) section 549.09 does not require a finding of wrongdoing for the recovery of a reward interest on appraisal awards; (2) the loss payment provision in Cincinnati’s insurance policy did not preclude Poehler from recovering preaward interest on the appraisal award; and (3) the loss payment provision in Minn. Stat. 65A.01, the Minnesota standard fire insurance policy, did not apply in this case. View "Poehler v. Cincinnati Insurance Co." on Justia Law

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The Supreme Court declined Appellants’ invitation to depart from the United States Supreme Court’s decision in Camara v. Municipal Court, 387 U.S. 523 (1967) and hold that Minnesota’s constitution requires that an administrative search warrant be supported by probable cause of the sort required in a criminal investigation. Camara held that an administrative warrant satisfies the probable cause requirement if reasonable legislative or administrative standards for conducting an unconsented-to rental housing inspection are satisfied with respect to a particular dwelling. In this case, the City of Golden Valley petitioned the district court for an administrative search warrant to search rental property for compliance with the city code. The district court denied the petition for the administrative search warrant, concluding that the issuance of such a search warrant was foreclosed without suspicion of a code violation. The court of appeals reversed. The Supreme Court affirmed, holding that the Minnesota Constitution does not require individualized suspicion of a code violation to support an administrative search warrant for a rental housing inspection. View "City of Golden Valley v. Wiebesick" on Justia Law

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At dispute in this case was the taxable value of Macy’s Retail Holdings, Inc.’s downtown Minneapolis property. Macy’s challenged the Minneapolis Assessor’s valuation of the property for the 2008, 2009, and 2010 tax years. After a trial, the tax court valued the property at figures lower than the assessor’s original valuation of the property for each of the years in question but not to the extent urged by the testimony and appraisal report of Macy’s expert witness. The Supreme Judicial Court affirmed, holding that the tax court (1) did not clearly err in its determination of the property’s highest and best use and in its consideration of comparable-sales data; (2) did not abuse its discretion when it declined to strike portions of the appraisal report and testimony of the County’s expert witness as a sanction for a discovery violation; and (3) did not clearly err in disregarding the sale of a nearby commercial property when it evaluated the comparable-sales data provided by the parties. View "Macy’s Retail Holdings, Inc. v. County of Hennepin" on Justia Law

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The Mandels owned a home that, in 2011, was damaged by rainwater. Based on an post-casualty appraisal, the Mandels deducted $82,247 from their income reflected on their 2011 federal tax return. This deduction also affected the Mandels’ Minnesota taxable income. Following an audit, the Commissioner of Revenue disallowed much of the Mandels’ casualty-loss deduction by reducing the allowable tax deduction to the amount of the cost of the repairs the Mandels actually made to their home. The Mandels appealed. The tax court granted summary judgment in favor of the Commissioner. The Supreme Court affirmed, holding that the tax court did not err in determining that the Mandels’ post-casualty appraisal was not “competent” and did not err in granting the Commissioner’s motion for summary judgment. View "Mandel v. Commissioner of Revenue" on Justia Law

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Menard, Inc. challenged Clay County’s assessment of the market value of Menard’s home improvement retail store as of January 2, 2011 through January 2, 2014. A trial ensued before the tax court, after which the court adopted market valuations below the County’s assessment values but above Menard’s expert appraiser’s valuation. Both Menard and the County appealed. The Supreme Court affirmed the tax court’s value determinations, holding that the tax court did not err in weighting the sales comparison approach and the cost approach for the valuation years at issue and did not fail adequately to explain its reasoning for that decision. View "Menard, Inc. v. County of Clay" on Justia Law

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Appellant agreed with Respondent to rent an apartment located in Hennepin County. Respondent received the first month’s rent and security deposit but refused to deliver physical possession of the premises to Appellant. Appellant brought an unlawful exclusion petition under Minn. Stat. 504B.375 - the unlawful exclusion statute - to enforce her agreement with Respondent. The housing referee recommended granting Respondent’s motion to dismiss on the grounds that Appellant did not qualify as a “residential tenant” under the statute because she was not physically “occupying” the residential premises. The district court adopted the referee’s decision. The court of appeals affirmed. The Supreme Court reversed, holding (1) a tenant who holds the present legal right to occupy residential rental property pursuant to a lease or contract satisfies the definition of “residential tenant” under Minn. Stat. 504B.001, and (2) therefore, upon the effective date of a lease agreement, a tenant has the right to bring an unlawful removal or exclusion petition under Minn. Stat. 504B.375(1). View "Cocchiarella v. Driggs" on Justia Law

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This case arose out of the foreclosure of Respondent’s townhome. Respondent’s townhome association served Respondent’s adult son with notice of the foreclosure under Minn. R. Civ. P. 4.03(a), the substitute-service rule. Respondent brought this action seeking a declaratory judgment that the foreclosure sale was legally void. The district court determined that service was ineffective under Rule 4.03(a) because Respondent’s son was not “residing” in Respondent’s townhome when the association attempted to serve Respondent. The court of appeals affirmed. The Supreme Court affirmed, holding that because Respondent’s son had not lived at Respondent’s home for an extended period when the substitute service occurred, the service was ineffective under Rule 4.03(a). View "Jaeger v. Palladium Holdings, LLC" on Justia Law

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Two churches (the Churches) located in the City of Saint Paul were subject to a right-of-way assessment (ROW assessment) that the City assessed to nearly every owner of real property within the city limits to pay for public right-of-way maintenance services. The Churches appealed their 2011 ROW assessment, arguing that the charge was a tax and was not imposed uniformly upon the same class of property and that the assessed amount improperly exceeded the special benefit to the Churches’ properties. The district court upheld the assessments after applying a reasonableness test, concluding that the ROW was not a tax imposed under the City’s taxing power but was a fee imposed under the City’s police power and, therefore, was not subject to constitutional restrictions on taxation. The court of appeals affirmed. The Supreme Court reversed, holding (1) the ROW assessment was imposed as an exercise of the City’s taxing power rather than its police power; and (2) summary judgment was inappropriate because a genuine issue of material fact existed regarding the extent of special benefits to the Churches’ properties attributable to the right-of-way services. View "First Baptist Church of St. Paul v. City of St. Paul" on Justia Law

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Blandin Paper Company (Blandin) owned 4,680 parcels of timberland located in Aitkin, Itasca, St. Louis, and Koochiching Counties (the Counties). Blandin challenged tax assessments of market value for the timberland properties. Before trial, the Counties filed a motion to exclude evidence Blandin offered regarding the unit-rule method for determining the market value of the property at issue. The tax court denied the motion, determining that the unit-rule method is admissible in property tax proceedings. At trial, the court adopted Blandin’s appraisal values based on the unit-rule method and reduced the assessor's aggregate market value of the properties. The Supreme Court reversed, holding (1) the unit-rule method to determine the fair market value of real property may be admissible in a property tax proceeding; (2) the record in this case does not establish that the appraisal evidence offered by Blandin satisfied the requirements set forth in this opinion for admitting such evidence; and (3) the case must be remanded for both parties to have the opportunity to present evidence in favor of their respective positions. View "County of Aitkin v. Blandin Paper Co." on Justia Law