Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Real Estate & Property Law
by
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

by
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

by
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

by
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

by
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

by
The Supreme Court held that an action taken by the Minnesota Pollution Control Agency (MPCA) in issuing a National Pollutant Discharge Elimination System/State Disposal System permit was arbitrary and capricious and that the permit did not comply with a Minnesota rule addressing wastewater discharges to groundwater, Minn. R. 7060.0600, subp. 2.At issue was the MPCA's issuance of the permit for a Poly Met Mining, Inc. project. The court of appeals reversed in part, concluding that the MPCA failed properly to consider whether the federal Clean Water Act (CWA) applied to future discharges from Poly Met's facility to groundwater. The Supreme Court remanded the cause, holding (1) remand was required because there were suggestions that the MPCA did not properly consider whether the permit complies with the CWA and that the MPCA did not genuinely engage in reasoned decision-making; (2) remand was required for consideration of whether a variance was available to allow the planned discharge to the unsaturated zone within the containment system; and (3) the prohibition on injecting polluted water directly to the groundwater saturated zone for long-term storage did not apply in this case. View "In the Matter of the Denial of Contested Case Hearing Requests & Issuance of National Pollutant Discharge Elimination System" on Justia Law

by
The Supreme Court affirmed the judgment of the Minnesota Tax Court, though its adjustments, increasing the market value of the real estate of the Minneapolis Hyatt Regency Hotel for the tax years 2016 through 2018, holding that when a county opposes discovery and the taxpayer moves to compel discovery, the balancing test found in Minn. Stat. 13.03, subdivision 6 is applicable.Relator, which owned the Hotel, challenged the market values assessed by the County of Hennepin for the tax years at issue, arguing that the tax court clearly erred when it accepted the appraisal report of Relator's expert but then made unsupported and unexplained adjustments to the expert's valuations. The Supreme Court affirmed, holding that the tax court (1) did not err or abuse its discretion in its discovery and evidentiary rulings; and (2) did not clearly err in adjusting Relator's valuation of the hotel real estate. View "1300 Nicollet, LLC v. County of Hennepin" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals reversing Appellant's unjust enrichment award, holding that the district court did not clearly err in its award to Appellant.Over the course of the parties' romantic relationship Appellant made $282,736.02 in net cash payments to Respondent to renovate Respondent's home. Respondent sold her home for $1.2 million after the couple ended their relationship, and Appellant sued to recover his contribution. The district court awarded Appellant $282,736.02 for his contributions, concluding that Respondent had been unjustly enriched by Appellant's financial contributions. The court of appeals reversed because Appellant did not prove before the district court the increase in value to Respondent's home attributable to his financial contributions. The Supreme Court reversed, holding (1) the net amount of money that Appellant contributed directly to and on behalf of Respondent was an appropriate measure of relief for unjust enrichment; and (2) the district court did not clearly err in its award to Appellant. View "Herlache v. Rucks" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals concluding that the interpretation of a restrictive covenant was a question of fact for a jury, holding that because the evidence did not conclusively establish one covenanting party's intent in drafting the document at issue, the interpretation of the covenant was a question of fact for a jury.Specifically, the Supreme Court held (1) the interpretation of an ambiguous restrictive land use covenant is a question for a jury unless extrinsic evidence proffered by the parties is conclusive as to the covenanting parties' intent; (2) a jury should strictly construe an ambiguity in a restrictive covenant against the land use restriction only if the jury is unable to resolve by a preponderance of the evidence the ambiguity from the extrinsic evidence; and (3) the court of appeals did not err in concluding that the extrinsic evidence in this case did not conclusively resolve the ambiguity in the restrictive covenant. View "Windcliff Ass'n v. Breyfogle" on Justia Law

by
The Supreme Court affirmed the judgments of the tax court declining to include a "concession fee" as rental income attributable to the properties in this case under the income-capitalization approach to property valuation, holding that the tax court did not err.At issue was Hennepin County's valuation of the respective properties owned by Enterprise Leasing Company of Minnesota and Avis Budget Car Rental, LLC at the Minneapolis-St. Paul International Airport. The tax court disagreed with Hennepin County's approach, decided not to include the concession fee as rental income, and estimated a market value in each case that was lower than the value that the County sought at trial. The Supreme Court affirmed in both cases, holding that the tax court did not clearly err in excluding the concession fee from rental income. View "Enterprise Leasing Co. of Minn. v. County of Hennepin" on Justia Law