Justia Minnesota Supreme Court Opinion Summaries
Articles Posted in Government & Administrative Law
A.A.A. v. Dep’t of Human Servs.
Appellant in this case was a nine-year-old boy with severe autism, epilepsy, and chronic seizures. The Commissioner of the Minnesota Department of Human Services (DHS) found that Appellant was not dependent in "mobility" and therefore reduced his authorized personal care assistant (PCA) services covered through the Minnesota Medical Assistance program. The district court reversed the Commissioner's decision, concluding that Minn. Stat. 256B.0659 did not require Appellant to be physically incapable of mobility to be eligible for covered services. The court of appeals reversed because Appellant was physically able to begin and complete moving from place to place without assistance. At issue was whether a person who is physically able to move without assistance but lacks the ability to direct his movement to a specific location has a dependency in mobility under the statute. The Supreme Court affirmed, holding that the Commissioner's interpretation of the statute was supported by the plain and ordinary meaning of "mobility." View "A.A.A. v. Dep't of Human Servs." on Justia Law
Schober v. Comm’r of Revenue
In 2005, the Department of Revenue audited Relator and assessed Relator for the amount of sales tax he collected from his customers but failed to remit to the State. The Commissioner of Revenue (Commissioner) adjusted the initial assessment and assessed tax. The tax court upheld the Commissioner's assessment. The Supreme Court affirmed. In 2011, Plaintiff submitted to the Commissioner documents and an informal request for a refund based on his repayment of sales tax to his customers. The Commissioner responded to Relator by letter, in which he denied Plaintiff's request for a refund. Plaintiff appealed to the tax court. The tax court concluded it lacked subject matter over the appeal, holding that the Commissioner's letter was not an appealable order of the Commissioner because it was merely administrative correspondence. However, the court also denied Relator's claim for a refund. The Supreme Court (1) reversed the tax court's decision as to its jurisdiction, holding that the Commissioner's consideration of Relator's refund claim was a final decision on the claim that could be appealed; and (2) affirmed the tax court's decision on the merits of Relator's refund claim, holding that Relator's arguments either lacked merit or were barred by res judicata.
View "Schober v. Comm'r of Revenue" on Justia Law
Harbaugh v. Comm’r of Revenue
Plaintiff and his ex-wife both claimed their two children as dependents on their state individual income tax returns. The Minnesota Department of Revenue determined that only Plaintiff's ex-wife was entitled to claim the children as dependents and that Plaintiff had underpaid his state taxes. Plaintiff appealed. The extended deadline for filing Plaintiff's notice of appeal was December 27. On December 22, Plaintiff mailed his notice of appeal to the tax court and the Department of Revenue. The Department received the notice on December 27, but the notice sent to the court was marked by the court as filed on December 28. The The tax court dismissed Plaintiff's appeal for lack of subject matter jurisdiction on the ground that Plaintiff had not timely filed his notice of appeal. The Supreme Court affirmed, holding (1) the mailbox rule does not extend to statutorily created rights of appeal; and (2) Plaintiff failed to present direct evidence in support of his assertion that his notice of appeal arrived on December 27. View "Harbaugh v. Comm'r of Revenue" on Justia Law
Coker v. Jesson
In 2000, Appellant was indeterminately committed as a sexual dangerous person as a result of a series of sex offenses involving teenage girls. Appellant later petitioned for provisional discharge from civil commitment. After weighing the evidence presented by Appellant and the Commissioner of Human Services at a first-phase hearing, the Supreme Court Judicial Appeal Panel dismissed Appellant's petition under Minn. R. Civ. P. 41.02(b). The court of appeals affirmed. The Supreme Court reversed, holding that the Appeal Panel committed reversible error in applying Rule 41.02(b) by failing to view the evidence produced at the first-phase hearing in a light most favorable to Appellant and by weighing the evidence produced during the first phase of the hearing. Remanded. View "Coker v. Jesson" on Justia Law
Living Word Bible Camp v. County of Itasca
The Living Word Bible Camp, a tax-exempt organization, owned property in Itasca County. Living Word sought to obtain the necessary governmental approvals to use the property as a summer bible camp and retreat center. Itasca County classified the property as tax-exempt from 2001 to 2007 then reclassified the property as taxable as of 2008. Living Word challenged the reclassification for the 2008 and 2009 assessments. The tax court affirmed the County's reclassification because Living Word had failed to make sufficient progress in obtaining the necessary governmental approvals for its proposed use of the property. The Supreme Court reversed, holding that the tax court (1) erred in concluding that Living Word was not entitled to an exemption because it was not using the property in furtherance of a charitable purpose; and (2) erred in determining that Living Word's current activities on the property could not be considered in determining whether that use was sufficient to qualify as a tax-exempt use. Remanded. View "Living Word Bible Camp v. County of Itasca" on Justia Law
Eden Prairie Mall, LLC v. County of Hennepin
Eden Prairie Mall, LLC (EPM) owned a mall. Included in the mall parcel for property tax purposes were the mall's in-line tenants, five anchor tenants, and a movie theater complex. EPM sought review of the tax court's market value determinations for the mall and one of its anchor tenants for the assessment dates of 2005 and 2006. The tax court adopted the market values for the mall parcel proposed by Hennepin County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. On appeal, the Supreme Court concluded the tax court's value determinations were not supported by the record and remanded with instructions for the tax court to explain its reasoning and describe the factual support in the record for its determinations. On remand, the tax court adopted market values that exceeded its earlier determinations. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions because the tax court failed to explain its reasoning and describe the factual support in the record for its determinations. Remanded. View "Eden Prairie Mall, LLC v. County of Hennepin" on Justia Law
444 Lafayette, LLC v. County of Ramsey
The subject property was located at 44 Lafayette Road in Saint Paul. Relators challenged the County's assessments for the assessment dates 2007, 2008, and 2009. After trial, the tax court adopted the market values proposed by the County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. The Supreme Court reversed and remanded with instructions for the tax court to explain its reasoning for rejecting the appraisal testimony and to describe the factual support in the record for its determinations. On remand, the tax court again adopted market values that exceeded the parties' appraisal opinions. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions in its calculation of parking income and expenses. Remanded for a further evidentiary hearing regarding the appropriate calculation of net parking income. View "444 Lafayette, LLC v. County of Ramsey" on Justia Law
Mauer v. Comm’r of Revenue
Relator was at all times relevant to this case employed by the National Basketball Association as a referee. Relator did not file Minnesota income tax returns for the 2003 and 2004 tax years but subsequently filed a 2003 state tax return as a part-year Minnesota resident. The Commissioner of Revenue determined that Relator was a full-time, legal resident of Minnesota during the relevant tax years. Relator appealed, asserting that, in 2003, he established his domicile in Florida. The Commissioner again determined that Relator was a full-time Minnesota resident during the 2003 and 2004 tax years, and the tax court affirmed. The Supreme Court affirmed, holding that sufficient evidence supported the tax court's decision, and the court correctly concluded that Relator failed to carry his burden of overcoming the legal presumption that he remained domiciled in Minnesota during the 2003 and 2004 tax years. View "Mauer v. Comm'r of Revenue" on Justia Law
Washek v. New Dimensions Home Health & State Fund Mut. Ins. Co.
In 2002, Employee suffered injuries in a work-related accident and was rendered a paraplegic. Employer and its insurer accepted liability for Employee's injuries and paid various workers' compensation benefits. In 2010, Employee filed a medical request seeing payment for the installation of a ceiling-mounted motorized lift system. A compensation judge (1) determined that the cost of making the structural changes was compensable under Minn. Stat. 176.135 because those changes were necessary to provide Employee with reasonable and necessary medical treatment, and (2) ordered Employer and its insurer to pay for the modifications in their entirety. The workers' compensation court of appeals reversed, concluding that the changes to Employee's home necessary to permit installation of the lift system constituted "alteration or remodeling" of Employee's home and that Employer's liability was therefore limited by Minn. Stat. 176.137. The Supreme Court affirmed, holding that the cost of the structural modifications to Employee's residence that were necessary to permit the ceiling-mounted track system to be installed were "alteration or remodeling" costs subject to section 176.137 and were not costs of medical treatment. View "Washek v. New Dimensions Home Health & State Fund Mut. Ins. Co. " on Justia Law
Larson v. Comm’r of Revenue
From 1999-2006, Relator filed his Minnesota individual income tax return as a nonresident. After the Commissioner of Revenue conducted two audits of Relator's individual income tax returns spanning the 2002-2006 tax years, the Commissioner determined that Relator was a resident of Minnesota during the tax years. Relator appealed, arguing that he became a resident of Nevada in 1998, and therefore, the Commissioner erred in requiring him to pay taxes as a Minnesota resident during the relevant tax years. The tax court affirmed, concluding that Relator was a Minnesota domiciliary during the tax years and, therefore, was a resident of Minnesota for income tax purposes. The Supreme Court affirmed, holding that the tax court did not err in its application of the law, and the record supported the tax court's determination. View "Larson v. Comm'r of Revenue" on Justia Law