Justia Real Estate & Property Law Opinion Summaries

At issue in this case was Hennepin County’s assessment of the market value of two bulk-distribution warehouses for two assessment dates in 2009 and 2010. The tax court adopted market valuations that were far lower than the recent sale price of each subject property. The County appealed, arguing that the tax court provided inadequate reasons for rejecting the County’s sales comparison analysis and for rejecting a large portion of the County’s income capitalization analysis. The Supreme Court reversed the portion of the tax court’s decision rejecting the County’s sales comparison analysis and vacated the tax court’s order, holding that the tax court (1) did not err in rejecting portions of the County’s income capitalization analysis, but (2) failed adequately to explain its reasons for rejecting the County’s sales comparison analysis. Remanded. View "Archway Marketing Servs. v. County of Hennepin" on Justia Law

Appellant filed an action under 42 U.S.C. 1983 against Scott County and Credit River Township, claiming that the County took his property without just compensation by placing conditions on the approval of his plat application. The County moved for summary judgment, arguing that the district court did not have subject-matter jurisdiction because Appellant’s exclusive avenue for review of the County’s decision was to seek a writ of certiorari from the court of appeals. The district court determined that it had jurisdiction over the action. The court of appeals reversed, concluding that the County’s plat approval subject to conditions was a quasi-judicial action, which was reviewable only by certiorari appeal within sixty days. The Supreme Court reversed, holding that the district court had jurisdiction over Appellant’s section 1983 action. View "Zweber v. Credit River Township" on Justia Law

Plaintiff brought an action against Defendant for copyright infringement and obtained a money judgment in California. The judgment against Defendant was filed and docketed in a Minnesota district court. Plaintiff subsequently served a garnishment summons on Defendant and sought to attach Defendant’s domain name and the content of its related website. The district court concluded that neither the domain name nor its associated website constituted property subject to garnishment under Minn. Stat. 571.73(3). The court of appeals reversed. The Supreme Court affirmed, holding that an Internet domain name constitutes intangible personal property subject to attachment by garnishment under section 571.73(3)(3). View "Sprinkler Warehouse, Inc. v. Systematic Rain, Inc." on Justia Law

Appellant entered into a mortgage with Aegis Lending Corporation. The mortgage was later assigned to Pacifica L. Ninteen, and the servicing rights were eventually transferred to Vantium Capital, Inc. (“Acqura”). After foreclosure proceedings were commenced against Appellant, Appellant filed suit against Acqura, alleging numerous state law claims. Specifically, Appellant claimed that Acqura’s violated its Servicer Participation Agreement with Fannie Mae by failing to follow guidelines applicable under the federal Home Affordable Modification Program. The district court dismissed the lawsuit, holding that Minn. Stat. 58.18(1) did not provide a private cause of action for Appellant to pursue damages for Acqura’s alleged violation of its agreement with Fannie Mae and that Appellant therefore lacked standing. The court of appeals affirmed. The Supreme Court reversed, holding that section 58.18(1) provides for a private right of action and therefore gave Appellant standing to pursue her claim. View "Gretsch v. Vantium Capital, Inc." on Justia Law

In 1986, the City of Duluth and the Fond du Lac Band of Lake Superior Chippewa (the Band) entered into several agreements establishing a joint venture to operate gaming activities in Duluth. The agreements required that the Band seek approval before creating any additional Indian Country. In 1994, the Band and the City created a series of new agreements and amendments to the 1986 agreements. In 2010, the Band acquired a plot of land. The Band sought to have the plot placed in trust but did not seek the City’s approval to do so, as required by the 1986 agreements. The City commenced this action in state district court seeking a court order requiring the Band to withdraw its trust application. The district court dismissed the lawsuit, concluding that it lacked subject matter jurisdiction because the Band had only consented to suit in federal court in the 1994 agreements. The court of appeals reversed. The Supreme Court reversed the court of appeals’ decision and reinstated the district court’s judgment for the Band, holding that the Court lacked jurisdiction to decide the issue of whether the Band breached the 1986 agreements because it required interpretation of the 1994 agreements, which was a matter vested in the federal courts. View "City of Duluth v. Fond du Lac Band of Lake Superior Chippewa" on Justia Law

Through the exercise of its eminent-domain power, the County of Dakota acquired a commercial property owned by Appellant. Following an administrative hearing, three condemnation commissioners awarded Appellant $655,000 in damages. Appellant appealed, arguing that under Minnesota's minimum-compensation statute, he was entitled to an award of damages that would allow him "to purchase a comparable property in the community." The trial court concluded Appellant was entitled to $997,056 in damages after finding that certain property, which was located within the same city as the condemned property, qualified as a comparable property in the community under the statute. The court of appeals affirmed. At issue on appeal was what qualified as a "comparable property" located in the same "community" as the condemned property. The Supreme Court affirmed, holding (1) the phrase "comparable property" in the minimum-compensation statute refers to an existing property that has enough like characteristics or qualities to another property that the value of one can be used to determine the value of the other; and (2) the district court did not err when it determined that the disputed property qualified as a "comparable property in the community" of the condemned property. View "County of Dakota v. Cameron " on Justia Law

Appellant was a real estate firm that owned a vacant four-story building (the property) and sought to develop it into an office building. Before the Minneapolis City Council approved Appellant's site plan application, the Minneapolis Heritage Preservation Commission (Commission) nominated the property for designation as a local historic landmark. Appellant subsequently submitted an application for a certificate of appropriateness to the Commission. The City Council denied the application and subsequently designated the property as a local historic landmark. Plaintiff commenced this action against the City, alleging that the City violated Minn. Stat. 15.99(2)(a) by failing to approve or deny the application for a certificate of appropriateness within sixty days. The district court granted summary judgment for the City, concluding that section 15.99(2)(a) did not apply to an application for a certificate of appropriateness. The court of appeals affirmed. The Supreme Court reversed, holding that an application for a certificate of appropriateness is a "written request relating to zoning" under section 15.99(2)(a), and because the City failed to approve or deny Appellant's application within sixty days, summary judgment for the City was not proper. Remanded. View "500, LLC v. City of Minneapolis" on Justia Law

Mark Hilde hired Big Lake Lumber (Big Lake), Wruck Excavating (Wruck), and J. DesMarais Construction (DesMarais) to help him build a "spec home." 21st Century Bank (Bank) recorded a mortgage against the property to finance the purchase of the property and the home construction. After the Bank foreclosed on its mortgage, Big Lake commenced this mechanic's lien foreclosure action. The district court found that the mechanic's liens of Big Lake and DesMarais related back to the date Wruck commenced work on the improvement project, and thus, the mechanic's liens of Big Lake and DesMarais had priority over the mortgage of the Bank. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred by adopting and then applying a new "integrated analysis" to find the Bank's mortgage superior to the liens; and (2) the district court did not clearly err when it found that Wruck, Big Lake, and DesMarais contributed to the same project of improvement, and accordingly, under the relation-back doctrine, the mechanic's liens of Big Lake and DesMarais had priority over the Bank's mortgage. View "Big Lake Lumber, Inc. v. Sec. Prop. Invs., Inc." on Justia Law

After Washington County assessed the value of one of properties owned by Kohl's Department Stores for the years 2007-2009, Kohl's challenged the valuation. The tax court adjusted the County's assessment by increasing the valuations for 2007 and 2008 and decreasing the valuation for 2009. The Supreme Court affirmed, holding the tax court not err (1) by failing to adjust its capitalization rate to account for the property taxes paid by the owner on vacant space and for the neighborhood's excessive vacancy; and (2) when it calculated the property's fair market rent using comparable leases rather than a percentage of retail sales method. View "Kohl's Dep't Stores, Inc. v. County of Washington" on Justia Law

Appellants were landowners who elected to require a utility to condemn their property in fee after Respondents sought to acquire easements through their property by eminent domain in order to construct a high-voltage electric transmission line. After making this election, Appellants requested that Respondents provide them with minimum compensation and relocation assistance. Respondents moved the district court for an order clarifying whether such benefits are available to property owners making an election under Minn. Stat. 216E.12. The district court concluded that such benefits were available to Appellants, but the court of appeals reversed. The Supreme Court reversed, holding that Appellants satisfied the statutory criteria for receiving minimum compensation and relocation assistance and were therefore entitled to such benefits. Remanded. View "N. States Power Co. v. Aleckson" on Justia Law