Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Real Estate & Property Law
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The Supreme Court held that a letter contesting a notice of zoning violation was not a "request" as defined by Minn. Stat. 15.99, subd. (1)(c) and therefore did not entitle respondent property owners to the benefit of the automatic approval provision in Minn. Stat. 15.99, subd. (2)(a).The automatic approval provision requires agencies to, within sixty days, approve or deny a written zoning request. Failure to deny such a request within sixty days is deemed an approval of the request. Respondents received notice of a zoning violation from the City of Shorewood after installing a dock and contested the zoning violation in a written letter to the city planning commission. The City did not respond. Thereafter, Respondents were charged by criminal complaint with two misdemeanor violations of the city code. The district court granted Respondents' pretrial motion to dismiss, concluding that Respondents' letter was a "request" under Minn. Stat. 15.99, subd. 1(c), and therefore, Respondents' request for zoning action was automatically approved by operation of law. The Supreme Court reversed, holding that the letter was not a "request" under the statute. View "State v. Sanschagrin" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the district court's grant of summary judgment to Respondent on Appellant's adverse possession claim, holding that a claim of adverse possession to a portion of a separately assessed parcel requires the adverse claimant to pay taxes for at least five consecutive years unless a statutory exemption under Minn. Stat. 541.02 paragraph 3 applies.Appellant asserted adverse possession over a portion of two separately assessed parcels owned by Respondent. The district court ruled against Appellant's claim for both parcels. The court of appeals affirmed the court's grant of summary judgment to Defendant on Appellant's adverse possession claim for the west parcel but reversed the grant of summary judgment to Respondent as to the east parcel on the grounds that the percentage claimed did not trigger the tax payment requirement in section 541.02. Appellant appealed the court of appeals' decision that his adverse possession claim to fifty-two percent of the west parcel failed, arguing that the statute requires tax payment only for a claim to an entire separately assessed parcel. The Supreme Court affirmed, holding that the plain language of section 541.02 requires tax payment on a portion of a parcel. View "St. Paul Park Refining Co. LLC v. Domeier" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the jury's award of damages to Tamara Laechelt in this eminent domain action, holding that evidence of construction-related interference that arises after the date of taking is admissible to establish the value of the remainder property.A panel of commissions determined the amount of compensation Laechelt should be awarded for the County's acquisition of temporary and permanent easements from Laechelt. The County appealed the award and moved to exclude evidence of construction-related interference because the interference occurred after the date of the taking. The district court denied the motion and subsequently denied the County's motion for a new trial. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not err by denying the County a new trial. View "County of Hennepin v. Laechelt" on Justia Law

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The Supreme Court reversed the decision of the court of appeals defining AIM Development, LLC's nonconforming-use rights on a property containing a facility for nonhazardous, non-toxic industrial waste based on the terms of a state permit in effect at the time that it purchased the property, holding that a property owner's nonconforming-use rights are defined by the uses lawfully existing at the time of the adverse zoning change.In 2013, AIM Development purchased the property containing the waste facility, which had operated as a nonconforming use since 1989. At issue was the scope of AIM Development's nonconforming-use rights and whether the waste facility may accept waste from more than one source. Based on the terms of a state permit in effect when AIM Development purchase the property the court of appeals determined that the facility was limited to accepting waste from a recently demolished paper mill. The Supreme Court reversed, holding (1) the court of appeals erred in defining the scope of the nonconformity by the state permit; and (2) accepting waste from more than one source does not, standing alone, constitute an impermissible expansion of AIM Development's nonconforming-use rights. View "AIM Development (USA), LLC, Appellant, v. City of Sartell" on Justia Law

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In this case brought by two associations against the Minnesota Department of Natural Resources (DNR) arising out of alleged mismanagement of the groundwater-appropriation permitting process, the Supreme Court held that the two associations stated a claim under Minn. Stat. 116B.03 and that one of the associations failed to state a claim under the public trust doctrine.Two associations brought this suit against the DNR, alleging violations of the Minnesota Environmental Rights Act under section 116B.03 based on alleged pollution and impairment of White Bear Lake. The associations alleged that the DNR mismanaged the groundwater-appropriations permitting process, resulting in the lake's water levels reaching historic lows. One of the associations added a claim that the DNR had violated the common-law public trust doctrine. The district court found that the DNR had violated by section 116B.03 and the public trust doctrine. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding that the court of appeals (1) erred in concluding that the associations did not state a claim under section 116B.03; and (2) did not err in concluding that the one association failed to state a claim under the public trust doctrine. View "White Bear Lake Restoration Ass'n, ex rel. State v. Minnesota Department of Natural Resources" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the tax court increasing the assessed unit value of a pipeline system for tax years 2015 and 2016, holding that the tax court did not err in its calculations for the cost indicator of value but erred in assigning equal weight to the cost and income indicators of value.On appeal, the taxpayer (1) challenged the tax court's market value determination, asserting that the court erred in its treatment of construction work in progress and external obsolescence in the computation of the cost indicator of value; and (2) challenged the weight that the court assigned to the cost indicator of value, as opposed to the income indicator, in determining the unit value of the pipeline system. The Supreme Court held that the tax court (1) did not err in its calculations for the cost indicator of value; but (2) erred by concluding that it had no discretion to adjust the default weightings prescribed by Minnesota Rule 8100.0300, subpart 5 for the cost and income indicators of value. View "Enbridge Energy, Limited Partnership v. Commissioner of Revenue" on Justia Law

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In this condemnation action, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court rejecting Landowners' theory of damages supporting their claim for severance damages, holding that the lower courts did not err.The State, acting through the Minnesota Department of Transportation, condemned a portion of Landowners' property for a construction project intended to improve the quality of Highway 61. Court-appointed commissioners awarded Landowners $391,000 in damages, $305,000 of which were severance damages attributable to the presumed loss of access to the property from the abutting highway during construction. Each party appealed the damages award. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Landowners were not entitled to damages for loss of access under a theory that assumes that the taking of a temporary easement for a highway improvement includes the taking of the right of access to abutting property; and (2) Landowners were not entitled to severance damages based on construction-related interferences as an alternative means of compensation. View "State, Commissioner of Transportation v. Elbert" on Justia Law

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The Supreme Court affirmed the judgment of the tax court concluding that the market value of a distribution-warehouse property in Rogers, Minnesota was $15,638,000 as of January 2, 2014 and $15,597,000 as of January 2, 2015, holding that the tax court did not err in any of the ways asserted by Medline Industries.Specifically, the Supreme Court held that the tax court (1) did not err by crediting some of the county appraiser's opinions despite rejecting his opinion about the highest and best use of the property as a multi-tenant facility; (2) did not clearly err in the sales-comparison approach by relying on four comparable sales other than the May 2017 of a former Walgreens distribution center; (3) did not err in its income approach analysis; and (4) did not err in relying on the cost approach. View "Medline Industries, Inc. v. County of Hennepin" on Justia Law

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In this challenge to a zoning ordinance prohibiting industrial mineral operations within Winona County the Supreme Court affirmed the decision of the court of appeals affirming the order of the district granting summary judgment to the County on all of Minnesota Sands, LLC's claims, holding that the ordinance was constitutional.Minnesota Sands, a mining company, sought to mine and process silica sand in the County. Minnesota Sands sued the County requesting declaratory, injunctive, and monetary relief. The district court granted summary judgment to the County. The court of appeals affirmed, concluding that the ordinance did not violate the dormant Commerce Clause or work an unconstitutional taking of Minnesota Sands' property interests. The Supreme Court affirmed, holding (1) Minnesota Sands had standing to bring this case; (2) the County's ordinance did not violate the dormant Commerce Clause on its face, in purpose or in effect; and (3) Minnesota Sands' takings claims failed because the property interests it claimed were taken by the County had not yet accrued. View "Minnesota Sands, LLC v. County of Winona, Minnesota" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Appellant's petition seeking the return of seized property, holding that the district court did not clearly err in finding that the seized property was being held as potential evidence in a pending investigation and in deciding that the property was being held in good faith.Appellant, an attorney, was part of an investigation. Pursuant to a search warrant, law enforcement officers seized electronic devices containing files about Appellant's current and former clients. Appellant filed a motion seeking the return of the seized property. The district court considered the motion to be a petition under Minn. Stat. 626.04 and denied the motion on the ground that the property was being held in good faith as potential evidence in an uncharged matter. While this appeal was pending, Appellant was charged with theft by swindle. The Supreme Court affirmed without prejudice to any future challenge to the lawfulness of the search and seizure, holding that the district court did not abuse its discretion in denying the petition even though the court should have required the State to return the attorney copies of all client files seized. View "K.M. v. Burnsville Police Department" on Justia Law