Justia Minnesota Supreme Court Opinion Summaries

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

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

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

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

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

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court granting summary judgment ruling that the public's interest in an undeveloped road dedicated to public use by plat over 100 years ago had been extinguished by operation of the Marketable Title Act (MTA), Minn. Stat. 541.023, holding that the district court erred.On appeal, the Minnesota Department of Natural Resources and Itasca County argued that the lower courts erred in ruling that the MTA does not apply to roads dedicated to public use by plat. The Supreme Court agreed and reversed, holding that the MTA does not operate to extinguish public interests properly dedicated by plat. View "In re Application of Moratzka" on Justia Law

The Supreme Court reversed the decision of the court of appeals in this appeal involving a dispute between a homeowner and an insurance company over prejudgment interest, holding that Minnesota standard fire insurance policy, Minn. Stat. 65A/01, entitled Homeowner to prejudgment interest in an amount that may result in a total recovery that exceeded the policy limit.Homeowner sought coverage from Insurer after fires damaged his home. Insurer denied coverage, leading Homeowner to bring this lawsuit. A jury found for Homeowner. The district court award awarded Homeowner prejudgment interest in a limited amount, finding that Homeowner's total recovery for his personal property loss could not permissibly exceed the policy coverage limit. The court of appeals affirmed. The Supreme Court reversed and remanded the case to the district court to recalculate prejudgment interest, holding that, consistent with past precedent interpreting the standard fire policy, prejudgment interest can lawfully begin accruing before ascertainment of the loss when the insurer denies all liability. View "Else v. Auto-Owners Insurance Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeals applying the statutory definition of "public waters" in Minn. Stat. 103G.005, subd. 15, to determine whether the upper reach of Limbo Creek was a public water, holding that the court of appeals did not err.At issue was the upper reach of Limbo Creek in Renville County and whether it was a public water for purposes of environmental review under Minn. Stat. 116D.01-.11. Specifically in question was whether the classification of waters as "public water" was based on the statutory definition of "public waters" in Minn. Stat. 103G.005, subd. 15, or the "public waters inventory" maintained by the Department of Natural Resources. The Supreme Court affirmed the court of appeals' reliance on the statutory definition of "public waters" to determine in this case whether the upper reach of Limbo Creek was a public water, holding that court of appeals did not err. View "In re Petition of MCEA" on Justia Law

The Supreme Court reversed the judgment of the court of appeals construing a letter that Defendants submitted to the district court under Minn. R. Gen. Proc. 115.11 as a permissible tolling motion under Minn. R. Civ. App. P. 104.01, subd. 2 and accepting jurisdiction, holding that a request for permission to file a motion to reconsider pursuant to Rule 115.11 does not toll the time for appeal.In this dispute between commercial property owners over the allegedly fraudulent behavior of one of the owners during the refinancing of the property Defendants moved for summary judgment, arguing that Plaintiffs' claims were untimely and lacked merit. The district court granted the motion and dismissed the complaint with prejudice. Thereafter, Defendants filed the letter at issue seeking to correct an erroneous reference in the order. The district court issued an amended summary judgment order without directly responding to the letter. Defendants appealed, arguing that the appeal was untimely. The court of appeals accepted jurisdiction. The Supreme Court reversed, holding that the appeal was untimely, and therefore, the court of appeals erred by accepting jurisdiction. View "Stern 1011 First Street South, LLC v. Gere" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's complaint alleging that Defendant violated the Minnesota Bond Allocation Act, Minn. Stat. 474A.01-.21, holding that Plaintiff alleged a violation of the Act sufficient to support her common-law and statutory claims.Plaintiff, who leased and lived in one of Defendant's rent-restricted housing units, brought this putative class action alleging that Defendant violated the Act, which imposes rent limits on residential rental projects financed with tax-exempt municipal bonds. The district court dismissed the complaint for failure to state a claim upon which relief can be granted, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff stated a viable action, and therefore, the district court erred in dismissing her complaint. View "Thompson v. St. Anthony Leased Housing Associates II, LP" on Justia Law