Justia Minnesota Supreme Court Opinion Summaries
Articles Posted in Real Estate & Property Law
Odunlade v. City of Minneapolis
Relators represented a putative class including all residential property owners in three Minneapolis neighborhoods. Relators challenged the assessed values that the City placed on Relators' properties and alleged that because their properties were overvalued, Relators were required to overpay property taxes in 2009 through 2011. The tax court dismissed Relators' complaint, holding (1) because Relators alleged that the City's assessment practices were illegal, Minn. Stat. 278 provided the Realtors' exclusive remedy, (2) Relators' 2008 and 2009 claims were untimely under chapter 278, and (3) Relators' 2010 claims failed because chapter 278 did not allow multiple taxpayers to file a single action concerning multiple properties. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) Relators' claims based on the 2008 and 2009 tax years were untimely pursuant to chapter 278; but (2) because the plain language of chapter 278 allows multiple taxpayers to file one tax action concerning multiple properties, the tax court erred in dismissing Relators' claims based on the 2010 tax year to the extent those claims alleged a violation of Minn. Stat. 273.11. View "Odunlade v. City of Minneapolis" on Justia Law
Mattson Ridge, LLC v. Clear Rock Tile, LLP
Policyholder obtained a title insurance policy from Insurer for a parcel of property it owned. Because an ambiguity in the legal description of the property prevented Policyholder from reselling the property, Policyholder filed an action seeking a declaration of Insurer's obligations under the policy and alleging breach of contract against Insurer. The district court held in favor of Policyholder, concluding that Insurer was liable because the title to the property was unmarketable. The court, however, limited Policyholder's recovery to the face value of the policy. The court of appeals affirmed the finding of liability but held that Policyholder was entitled to recovery in excess of the policy limit. The Supreme Court (1) affirmed the district court's grant of partial summary judgment to Policyholder on the question of Insurer's liability for its failure to defend and indemnify Policyholder; but (2) reversed the court of appeals' award of damages to Policyholder in excess of the policy limit and remanded for reinstatement of the district court's award of damages.
View "Mattson Ridge, LLC v. Clear Rock Tile, LLP" on Justia Law
Weavewood, Inc. v. S & P Home Invs., LLC
At issue in this dispute over a mortgage was whether statutes of limitations apply to actions for declaratory judgment. The court of appeals reversed in part the district court's grant of summary judgment to Defendant based on the applicable statute of limitations, holding that to the extent Plaintiff's complaint sought declaratory relief, it was not barred by the statute of limitations. The Supreme Court reversed, holding that because the Uniform Declaratory Judgments Act is a procedural device through which parties may vindicate substantive legal rights, an action for declaratory judgment is barred by an applicable statute of limitations to the same extent that the same cause of action would be barred in a nondeclaratory proceeding. Remanded. View "Weavewood, Inc. v. S & P Home Invs., LLC" on Justia Law
Federated Retail Holdings, Inc. v. County of Ramsey
The county assessor determined that the fair market value of a tax parcel, which was improved by a department store operated by respondent Federated Retail Holdings, Inc., was $17,000,000 for the year 2006. The assessor included the value of a leasehold interest held by Federated in the parcel adjacent to the tax parcel in its value determination. Federated timely filed petitions challenging the assessor's market value determinations. The tax court held that Federated's ownership interest in the tax parcel included the leasehold interest in the adjacent property, but concluded that the value of the leasehold interest was not subject to the jurisdiction of the tax court and therefore did not include it. The county appealed. The Supreme Court reversed, holding that the tax court had subject-matter jurisdiction to consider the value of Federated's leasehold interest in adjacent property because it constituted real property of the tax parcel under Minn. Stat. 272.03, 1 and affected the fair market value of the tax parcel. View "Federated Retail Holdings, Inc. v. County of Ramsey " on Justia Law
Singer v. Comm’r of Revenue
Following a trial, the Minnesota tax court affirmed an order of the Commissioner of Revenue calculating the value of the estate of Ruth Singer and assessing the estate the sum of $69,679 in taxes and interest. The Supreme Court affirmed, holding (1) the tax court had jurisdiction; (2) Minn. Stat. 291.215, which provides that any elections made in valuing the federal gross estate shall be applicable in valuing the Minnesota gross estate, is constitutional, even if it is not uniform or its application results in a regressive tax; (2) the tax court did not err in affirming the Commissioner's assessment; (3) the federal estate tax law does not preempt Minnesota's estate tax law; and (4) the tax court properly determined that the value of Singer's home should be included in her gross estate. View "Singer v. Comm'r of Revenue" on Justia Law
In re Pamela Andreas Stisser Grantor Trust
Vernon Stisser, the personal representative of the estate of Pamela Stisser, petitioned the district court for an order directing certain payments and disbursements from Pamela's inter vivos trust (Trust). Among other claims, Vernon sought an order requiring trustee David Andreas (Trustee) to (1) pay all debts at the time of Pamela's death that were secured by Pamela's personal property and by Pamela's and Vernon's real estate; (2) compensate Vernon for his services as the personal representative of Pamela's probate estate; and (3) reimburse Pamela's estate for all probate estate administration expenses. The court granted Trustee's motion for partial summary judgment on Vernon's claim for payment of the secured debts. After a trial on Vernon's remaining claims, the court concluded the Trust did not require Trustee to compensate Vernon for his services as personal representative and required Trustee to pay only a limited amount of Vernon's claim administration expenses. The court of appeals affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding that the court of appeals incorrectly held that Trustee was required to pay debts secured by Pamela's personal property.
View "In re Pamela Andreas Stisser Grantor Trust" on Justia Law
Beuning Family LP v. County of Stearns
In 2008, Stearns County changed the tax classification of property co-owned by Respondent from residential nonhomestead to commercial. Respondent filed a petition under Minn. Stat. 278.01, claiming the property was misclassified, unequally assessed, and undervalued. The tax court dismissed the petition as untimely. Respondent did not appeal from the tax court's dismissal of its petition and instead filed a verified claim under Minn. Stat. 278.14 for a refund of taxes paid in 2009, claiming the property was misclassified for taxes payable in 2009. The County denied the refund claim. The tax court denied the County's motion to dismiss the section 278.14 appeal (Matter A11-1479). In the meantime, Respondent filed a timely petition under Minn. Stat. 278.01 with respect to property taxes assessed in 2009. The tax court ruled the property was properly classified as residential nonhomestead, its original classification (Matter A11-1480). The County petitioned for writ of certiorari in both matters. The Supreme Court dismissed the writs of certiorari, concluding that it lacked jurisdiction in each case. View "Beuning Family LP v. County of Stearns" on Justia Law
78th St. OwnerCo, LLC v. County of Hennepin
Relator 78th Street OwnerCo, LLC, the owner and landlord of a hotel, filed petitions contesting Hennepin County's assessments of its property for property taxes payable in 2008 and 2009, along with the taxes due in 2008 and 2009. The tax court dismissed both petitions for failure to comply with the statutory sixty-day rule, which states that failure to submit required documentation within sixty days results in automatic dismissal of the petition, because each petition did not include a copy of 78th Street's lease and a calculation of percentage rent paid, and the 2008 petition did not include a rent roll/tenant list. The Supreme Court affirmed, holding (1) 78th Street's argument that the information it did not submit was not relevant to the calculation of property tax for its hotel property was unavailing because a taxpayer is not permitted to evaluate relevancy under the sixty-day rule, and neither the relevancy standard nor the unavailability exception excuses a taxpayer from providing required information that is available to the taxpayer; and (2) neither version of the sixty-day rule was unconstitutionally vague as applied to 78th Street. View "78th St. OwnerCo, LLC v. County of Hennepin" on Justia Law
Eclipse Architectural Group, Inc. v. Lam
This case involved two mechanic's liens foreclosed against a hotel property. An agent of the lien claimants personally served mechanic's liens statements on the property owner. Appellant, a community bank, challenged the validity of this service. Appellant argued that a lien claimant may not personally serve a mechanic's lien statement, and therefore, service was improper. As a result, Appellant contended that the mechanic's liens were invalid and could not be foreclosed. The district court determined that service was proper and entered judgment in favor of the lien claimants. The court of appeals affirmed. The Supreme Court affirmed, holding that a lien claimant may personally serve a mechanic's lien statement, and therefore, service of the mechanic's lien statements in this case was proper. View "Eclipse Architectural Group, Inc. v. Lam" on Justia Law
DeCook v. Rochester Int’l Airport Joint Zoning Bd.
The Rochester International Joint Zoning Board enacted a zoning ordinance that increased the size of a runway safety zone and changed the restrictions within the safety zone to allow fewer types of uses of land within the zone. The safety zone extended over property owned by Leon and Judith DeCook. The DeCooks brought an inverse condemnation action, alleging that the Board's decision constituted a taking for which the DeCooks were entitled to compensation. The district court first concluded there was no taking, and upon remand, again concluded that the Board's actions did not constitute a taking. The DeCooks appealed another time, and the Supreme Court ultimately held the ordinance constituted a taking of the DeCooks' property. The DeCooks subsequently moved for an award of attorney fees incurred during the appeals. The Supreme Court granted the motion, as the Cooks prevailed and were entitled under Minn. Stat. 117.045 to an award of reasonable costs and expenses, including attorney fees, incurred on appeal. View "DeCook v. Rochester Int'l Airport Joint Zoning Bd." on Justia Law