Justia Minnesota Supreme Court Opinion Summaries

At issue in this case was Hennepin County’s assessment of the market value of two bulk-distribution warehouses for two assessment dates in 2009 and 2010. The tax court adopted market valuations that were far lower than the recent sale price of each subject property. The County appealed, arguing that the tax court provided inadequate reasons for rejecting the County’s sales comparison analysis and for rejecting a large portion of the County’s income capitalization analysis. The Supreme Court reversed the portion of the tax court’s decision rejecting the County’s sales comparison analysis and vacated the tax court’s order, holding that the tax court (1) did not err in rejecting portions of the County’s income capitalization analysis, but (2) failed adequately to explain its reasons for rejecting the County’s sales comparison analysis. Remanded. View "Archway Marketing Servs. v. County of Hennepin" on Justia Law

Appellant filed an action under 42 U.S.C. 1983 against Scott County and Credit River Township, claiming that the County took his property without just compensation by placing conditions on the approval of his plat application. The County moved for summary judgment, arguing that the district court did not have subject-matter jurisdiction because Appellant’s exclusive avenue for review of the County’s decision was to seek a writ of certiorari from the court of appeals. The district court determined that it had jurisdiction over the action. The court of appeals reversed, concluding that the County’s plat approval subject to conditions was a quasi-judicial action, which was reviewable only by certiorari appeal within sixty days. The Supreme Court reversed, holding that the district court had jurisdiction over Appellant’s section 1983 action. View "Zweber v. Credit River Township" on Justia Law

Plaintiff brought an action against Defendant for copyright infringement and obtained a money judgment in California. The judgment against Defendant was filed and docketed in a Minnesota district court. Plaintiff subsequently served a garnishment summons on Defendant and sought to attach Defendant’s domain name and the content of its related website. The district court concluded that neither the domain name nor its associated website constituted property subject to garnishment under Minn. Stat. 571.73(3). The court of appeals reversed. The Supreme Court affirmed, holding that an Internet domain name constitutes intangible personal property subject to attachment by garnishment under section 571.73(3)(3). View "Sprinkler Warehouse, Inc. v. Systematic Rain, Inc." on Justia Law

The State acquired three parcels of land for use during construction of Interstate 394. Because the State no longer needed the parcels, it planned to convey the land to the Golden Valley Housing and Redevelopment Authority (HRA). Webb Golden Valley owned nearby land and argued that the conveyance violated Minn. Stat. 161.44(1). The district court (1) granted Defendants’ motion to dismiss as to two of the parcels for lack of standing, and (2) dismissed the complaint in its entirety when Webb failed to post a surety bond. The court of appeals reversed, holding (1) Webb’s interest in purchasing the two parcels was sufficient to confer standing to challenge the State’s proposed transfer; and (2) the HRA’s allegations of public harm were not supported by evidence in the record, and therefore the district court erred in granting the HRA’s motion for an order directing Webb to post a surety bond. The Supreme Court affirmed in part and reversed in part, holding (1) Webb had standing to bring this suit; but (2) the district court did not abuse its discretion by ordering Webb to post a surety bond, and because Webb did not post the surety bond, the district court did not err in dismissing Webb’s lawsuit with prejudice. View "Webb Golden Valley, LLC v. State" on Justia Law

After Appellants, several public utilities, sought to condemn a permanent easement across the property of Landowners for a high-voltage transmission line, Landowners elected to compel Appellants to purchase their entire parcel of land pursuant to the Buy-the-Farm statute, Minn. Stat. 216E.12(4). Appellants challenged Landowners’ election, arguing that it was not reasonable because the land subject to the election was much larger than the land needed for the easement and that the district court must consider several factors in addition to the statute’s requirements, including the size of the election. The district court approved the election, concluding that it was not required to analyze factors outside the provisions of the Buy-the-Farm statute. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the language of the statute forecloses Appellants’ assertion that the district court must engage in a totality-of-the-circumstances analysis of the reasonableness of Landowners’ election; (2) case law does not require an extra-statutory analysis; and (3) because Landowners’ election meets the statutory requires, the district court did not err in approving the compelled purchase of the parcel. View "Great River Energy v. Swedzinski" on Justia Law

When Amos Graves was anticipating losing his home to foreclosure, Michael Wayman persuaded him to enter into a transaction that would purportedly save his home. Graves executed a quitclaim deed in favor of a corporate entity under Wayman’s control, but, the next day, sent a cancellation notice to Wayman, as was his statutory right. Wayman refused to cancel the transaction. When Wayman ceased making mortgage payments, First Minnesota Bank, the eventual mortgagee of the property, foreclosed on and purchased the home. Graves sued Wayman, Wayman’s companies, and First Minnesota, alleging that First Minnesota’s mortgage was invalid because Graves did not lawfully sell his home to Wayman. The district court awarded the property to First Minnesota, concluding that the bank was a bona fide purchaser. The court of appeals reversed and awarded the property to Graves, concluding that First Minnesota did not qualify as a bona fide purchaser. The Supreme Court affirmed in part and reversed in part, holding (1) First Minnesota was not entitled to rights in the property as a bona fide purchaser; but (2) the court of appeals erred in concluding that Graves should be awarded title to the property free of any interest of First Minnesota. Remanded. View "Graves v. Wayman" on Justia Law

During a hail storm, all twenty of the townhome buildings managed by Cedar Bluff Townhome Condominium Association (Cedar Bluff) were damaged, with at least one siding panel on each building sustaining damage. Cedar Bluff submitted a claim to American Family Mutual Insurance Company (American Family) under its businessowners’ policy, which provided for the replacement of “damaged property with other property…[o]f comparable material and quality.” A dispute arose as to whether the policy required the replacement of all siding, including undamaged siding, in order to provide a color match. Because the parties were unable to agree on the amount of the loss, Cedar Bluff demanded an appraisal. The appraisal panel concluded that siding of comparable material and quality required a reasonable color match between the damaged and undamaged siding. American Family refused to pay the appraisal award. The court of appeals agreed with the appraisal panel, concluding that “a reasonable person could understand that ‘comparable material’ means material that is the same color as the damaged property.” The Supreme Court affirmed, holding that, under the terms of its policy with American Family, Cedar Bluff was entitled to have all of the siding panels on each of its twenty buildings replaced. View "Cedar Bluff Townhome Condo. Ass’n, Inc. v. Am. Family Mut. Ins. Co." on Justia Law

Appellant entered into a mortgage with Aegis Lending Corporation. The mortgage was later assigned to Pacifica L. Ninteen, and the servicing rights were eventually transferred to Vantium Capital, Inc. (“Acqura”). After foreclosure proceedings were commenced against Appellant, Appellant filed suit against Acqura, alleging numerous state law claims. Specifically, Appellant claimed that Acqura’s violated its Servicer Participation Agreement with Fannie Mae by failing to follow guidelines applicable under the federal Home Affordable Modification Program. The district court dismissed the lawsuit, holding that Minn. Stat. 58.18(1) did not provide a private cause of action for Appellant to pursue damages for Acqura’s alleged violation of its agreement with Fannie Mae and that Appellant therefore lacked standing. The court of appeals affirmed. The Supreme Court reversed, holding that section 58.18(1) provides for a private right of action and therefore gave Appellant standing to pursue her claim. View "Gretsch v. Vantium Capital, Inc." on Justia Law

Mark Hilde hired Big Lake Lumber (Big Lake), Wruck Excavating (Wruck), and J. DesMarais Construction (DesMarais) to help him build a "spec home." 21st Century Bank (Bank) recorded a mortgage against the property to finance the purchase of the property and the home construction. After the Bank foreclosed on its mortgage, Big Lake commenced this mechanic's lien foreclosure action. The district court found that the mechanic's liens of Big Lake and DesMarais related back to the date Wruck commenced work on the improvement project, and thus, the mechanic's liens of Big Lake and DesMarais had priority over the mortgage of the Bank. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred by adopting and then applying a new "integrated analysis" to find the Bank's mortgage superior to the liens; and (2) the district court did not clearly err when it found that Wruck, Big Lake, and DesMarais contributed to the same project of improvement, and accordingly, under the relation-back doctrine, the mechanic's liens of Big Lake and DesMarais had priority over the Bank's mortgage.View "Big Lake Lumber, Inc. v. Sec. Prop. Invs., Inc." on Justia Law

In 1986, the City of Duluth and the Fond du Lac Band of Lake Superior Chippewa (the Band) entered into several agreements establishing a joint venture to operate gaming activities in Duluth. The agreements required that the Band seek approval before creating any additional Indian Country. In 1994, the Band and the City created a series of new agreements and amendments to the 1986 agreements. In 2010, the Band acquired a plot of land. The Band sought to have the plot placed in trust but did not seek the City’s approval to do so, as required by the 1986 agreements. The City commenced this action in state district court seeking a court order requiring the Band to withdraw its trust application. The district court dismissed the lawsuit, concluding that it lacked subject matter jurisdiction because the Band had only consented to suit in federal court in the 1994 agreements. The court of appeals reversed. The Supreme Court reversed the court of appeals’ decision and reinstated the district court’s judgment for the Band, holding that the Court lacked jurisdiction to decide the issue of whether the Band breached the 1986 agreements because it required interpretation of the 1994 agreements, which was a matter vested in the federal courts. View "City of Duluth v. Fond du Lac Band of Lake Superior Chippewa" on Justia Law