Justia Minnesota Supreme Court Opinion Summaries

Appellant was a real estate firm that owned a vacant four-story building (the property) and sought to develop it into an office building. Before the Minneapolis City Council approved Appellant's site plan application, the Minneapolis Heritage Preservation Commission (Commission) nominated the property for designation as a local historic landmark. Appellant subsequently submitted an application for a certificate of appropriateness to the Commission. The City Council denied the application and subsequently designated the property as a local historic landmark. Plaintiff commenced this action against the City, alleging that the City violated Minn. Stat. 15.99(2)(a) by failing to approve or deny the application for a certificate of appropriateness within sixty days. The district court granted summary judgment for the City, concluding that section 15.99(2)(a) did not apply to an application for a certificate of appropriateness. The court of appeals affirmed. The Supreme Court reversed, holding that an application for a certificate of appropriateness is a "written request relating to zoning" under section 15.99(2)(a), and because the City failed to approve or deny Appellant's application within sixty days, summary judgment for the City was not proper. Remanded. View "500, LLC v. City of Minneapolis" on Justia Law

Appellants were landowners who elected to require a utility to condemn their property in fee after Respondents sought to acquire easements through their property by eminent domain in order to construct a high-voltage electric transmission line. After making this election, Appellants requested that Respondents provide them with minimum compensation and relocation assistance. Respondents moved the district court for an order clarifying whether such benefits are available to property owners making an election under Minn. Stat. 216E.12. The district court concluded that such benefits were available to Appellants, but the court of appeals reversed. The Supreme Court reversed, holding that Appellants satisfied the statutory criteria for receiving minimum compensation and relocation assistance and were therefore entitled to such benefits. Remanded. View "N. States Power Co. v. Aleckson" on Justia Law

Respondent credit union sought to foreclose on the homestead that Appellant and her husband (Husband) owned. The district court granted summary judgment to Appellant after concluding that the mortgage Appellant signed with Respondent was void under Minn. Stat. 507.02 because it was not also signed by Husband. The court of appeals reversed, concluding that the mortgage was valid because Husband had quitclaimed all of his interest in the homestead property to Appellant before the mortgage was executed. The Supreme Court reversed, holding that the mortgage signed by Appellant in favor of Respondent was void because (1) the mortgage at issue here did not meet any of the statutory exceptions to the signature requirement in section 507.02; and (2) Husband's quitclaim deed did not constitute an explicit waiver of his rights under the homestead statute. View "Marine Credit Union v. Detlefson-Delano" on Justia Law

After the City of Moorhead annexed Americana Estates (Americana), a residential subdivision with sixty-five metered electric service accounts, the City filed a condemnation petition to begin municipal electric service to residents of Americana. After a hearing, a three-member commission of the district court awarded the Red River Valley Cooperative Power Association (RRVC), which previously served Americana, $307,214. Both parties appealed the commission's award of damages. After a jury trial, the district court awarded a total compensation award to RRVC of $385,311. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the City's valuation was inconsistent with the plain language of Minn. Stat. 216B.47 by failing to give meaningful consideration to four statutory factors and thus was properly excluded from consideration by the district court; and (2) the district court did not abuse its discretion in excluding portions of an untimely revised report submitted by the City dealing with facility replacement costs. View "City of Moorhead v. Red River Valley Coop. Power Ass'n" on Justia Law

The Living Word Bible Camp, a tax-exempt organization, owned property in Itasca County. Living Word sought to obtain the necessary governmental approvals to use the property as a summer bible camp and retreat center. Itasca County classified the property as tax-exempt from 2001 to 2007 then reclassified the property as taxable as of 2008. Living Word challenged the reclassification for the 2008 and 2009 assessments. The tax court affirmed the County's reclassification because Living Word had failed to make sufficient progress in obtaining the necessary governmental approvals for its proposed use of the property. The Supreme Court reversed, holding that the tax court (1) erred in concluding that Living Word was not entitled to an exemption because it was not using the property in furtherance of a charitable purpose; and (2) erred in determining that Living Word's current activities on the property could not be considered in determining whether that use was sufficient to qualify as a tax-exempt use. Remanded. View "Living Word Bible Camp v. County of Itasca" on Justia Law

Eden Prairie Mall, LLC (EPM) owned a mall. Included in the mall parcel for property tax purposes were the mall's in-line tenants, five anchor tenants, and a movie theater complex. EPM sought review of the tax court's market value determinations for the mall and one of its anchor tenants for the assessment dates of 2005 and 2006. The tax court adopted the market values for the mall parcel proposed by Hennepin County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. On appeal, the Supreme Court concluded the tax court's value determinations were not supported by the record and remanded with instructions for the tax court to explain its reasoning and describe the factual support in the record for its determinations. On remand, the tax court adopted market values that exceeded its earlier determinations. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions because the tax court failed to explain its reasoning and describe the factual support in the record for its determinations. Remanded. View "Eden Prairie Mall, LLC v. County of Hennepin" on Justia Law

The subject property was located at 44 Lafayette Road in Saint Paul. Relators challenged the County's assessments for the assessment dates 2007, 2008, and 2009. After trial, the tax court adopted the market values proposed by the County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. The Supreme Court reversed and remanded with instructions for the tax court to explain its reasoning for rejecting the appraisal testimony and to describe the factual support in the record for its determinations. On remand, the tax court again adopted market values that exceeded the parties' appraisal opinions. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions in its calculation of parking income and expenses. Remanded for a further evidentiary hearing regarding the appropriate calculation of net parking income. View "444 Lafayette, LLC v. County of Ramsey" on Justia Law

1st Fidelity Loan Servicing initiated a foreclosure by advertisement to collect the debt secured by a mortgage on the home of Respondent. 1st Fidelity subsequently purchased the property at the foreclosure sale. Respondent filed a complaint seeking a declaration that the sale was null and void and the recovery of monetary damages, alleging that 1st Fidelity failed to comply with certain statutory requirements. The district court granted summary judgment in favor of 1st Fidelity on the ground that it had substantially complied with the relevant statutes. The court of appeals reversed, concluding that Minnesota's foreclosure by advertisement statute requires strict compliance and that a foreclosing party's failure to strictly comply renders the foreclosure void. The Supreme Court affirmed, holding (1) a party must strictly comply with Minn. Stat. 580.02(3), which requires that all assignments of a mortgage be recorded before a party is entitled to make a foreclosure by advertisement; and (2) because 1st Fidelity did not strictly comply with section 580.02(3), the foreclosure was void. Remanded. View "Ruiz v. 1st Fidelity Loan Servicing, LLC " on Justia Law

Central Lakes College (CLC) formally petitioned the City of Brainerd to reconstruct a road. The City validated the petition and resolved to pay for a portion of the project with special assessments. Appellants, who owned property adjacent to the road, challenged the legality of the petition, arguing that because CLC was an instrumentality of the State, and the State cannot be bound by special assessments of its property, CLC was not an "owner" of property permitted to petition for an improvement under Minn. Stat. 429.031(1)(f). The district court granted summary judgment for the City. The Supreme Court affirmed, holding (1) CLC was an "owner" of property under the plain language of the statute; and (2) therefore, CLC's petition was valid. View "City of Brainerd v. Brainerd Invs. P'ship" on Justia Law

Todd County assessed taxes on property owned by John and Carrie Beck based on its conclusion that the property had an estimated market value of $397,400 as of January 2, 2009. John petitioned the tax court for relief. After a trial, the tax court found the fair market value of the property on that date was $395,000. John appealed, arguing that the tax court erred by (1) adopting the appraisal of Todd County's expert despite several challenges John raised to the assumptions and values underlying the appraisal, (2) rejecting the testimonies of John and Carrie challenging the County's assessment of the property, and (3) not determining separate land and improvement values for the property. The Supreme Court reversed because the tax court completely failed to address why it rejected the extensive evidence offered by John in support of his petition for tax relief. Remanded for the tax court to explain adequately the reasoning underlying its valuation determination. View "Beck v. County of Todd" on Justia Law