Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the Minnesota Tax Court affirming the order of the Commissioner of Revenue that assessed Terrance Sargent’s income tax liability for tax years 2010-2014, holding that Sargent’s arguments on appeal were without merit.On appeal, Sargent argued that Minnesota’s income tax violates the Minnesota Constitution and the United States Constitution on several grounds. The Supreme Court affirmed the Minnesota Tax Court's decision after considering all of Sargent’s arguments, holding that they each were without merit. View "Sargent v. Commissioner of Revenue" on Justia Law

The Commissioner of Revenue properly invoked her alternative-apportionment authority under Minn. Stat. 290.20(1) and applied an alternative apportionment method that fairly reflected the income of Associated Bank, N.A. and its affiliates (the Bank) allocable to Minnesota.The Bank, which included two LLC partnerships under Wisconsin law, objected to the Commissioner’s assessment of additional state corporate franchise tax liability for tax years 2007 and 2008. The Bank had calculated the tax owed based on the relevant statutes for apportioning income to Minnesota. The Commissioner found that applying the general apportionment formula to the LLCs did not “fairly reflect” the Bank’s “taxable net income allocable” to Minnesota. Accordingly, the Commissioner invoked her authority under section 290.20(1) and applied an alternative apportionment method to correct a distortion of reported income. After exhausting its administrative remedies, the Bank appealed to the tax court. Relying on the Supreme Court’s decision in HMN Financial, Inc. v. Commissioner of Revenue, 782 N.W.2d 558 (Minn. 2010), the tax court agreed and reversed the Commissioner’s order. The Supreme Court reversed, holding (1) HMN Financial is not dispositive; and (2) the Legislature plainly gave the Commissioner the authority to use an alternative apportionment method under the circumstances presented here. View "Associated Bank, N.A. v. Commissioner of Revenue" on Justia Law

Security Bank & Trust Company (Security Bank) lacked standing both in its capacity as personal representative of Gordon P. Savoie’s estate and in its capacity as trustee of the Gordon P. Savoie Revocable Trust to bring this legal malpractice action related to estate planning services for its deceased client.In its complaint, Security Bank alleged that Larkin, Hoffman, Daly & Lindgren, Ltd. (Larkin) failed to advise Savoie that his estate would be subject to a substantial generation-skipping transfer tax upon a distribution to a beneficiary who was more than thirty-seven years younger than him. The district court granted Larkin’s motion for judgment on the pleadings, determining that Savoie lacked standing either as personal representative or as trustee. The court of appeals reversed, concluding that Security Bank had standing as personal representative because a cause of action for legal malpractice accrued to Savoie during his lifetime, and therefore, survived to Security Bank. The Supreme Court reversed, holding (1) a cause of action for malpractice did not accrue during Savoie’s lifetime and therefore did not survive to Security Bank; and (2) Security Bank could not state a claim for legal malpractice against Larkin in its capacity as trustee. View "Security Bank & Trust Co. v. Larkin, Hoffman, Daly & Lindgren, Ltd." on Justia Law

In a complaint seeking an injunction for breach of contract, the district court was not required to find irreparable harm based solely on the language of a private agreement and did not abuse its discretion by declining to grant an injunction in light of the absence of evidence of irreparable harm.St. Jude Medical sued Heath Carter and Boston Scientific Corporation after Carter left his job at St. Jude to work for Boston Scientific, alleging that Carter had violated his employment agreement with St. Jude. The agreement stated that if Carter breached its terms, St. Judge would suffer irreparable injury, and St. Jude would be entitled to an injunction against Carter and his new employer because St. Jude’s remedy at law for damages would be inadequate. The district court concluded that St. Jude was not entitled to an injunction because, although Carter breached the agreement, St. Jude failed to demonstrate that it would suffer irreparable harm from that breach. The court of appeals reversed, ruling that the district court erred by failing to consider the terms of the agreement when deciding whether to enjoin Carter. The Supreme Court reversed, holding that the district court was not required to exercise its equitable authority simply by reason of the contract language. View "St. Jude Medical, Inc. v. Carter" on Justia Law

The Supreme Court has applied the rule of contra proferentem - “a doctrine that ambiguities in a contract are to be construed unfavorably against the drafter” - only after an attempt is made to determine the parties’ intent behind an ambiguous term, and only if a preponderance of the evidence does not prove the parties’ intent should the jury construe ambiguous terms against the drafter.In this breach of contract case, the district court instructed the jury to determine whether two contracts were ambiguous and, if so, to both determine the intent of the parties and construe ambiguous terms against the drafter. The court of appeals reversed and remanded for a new trial, determining that the canon of contra proferentem was to be applied only after the evidence failed to reveal the mutual intent of the parties. The Supreme Court held that the jury instruction in this case materially misstated the law twice by directing the jury to (1) determine whether the contracts at issue were ambiguous, rather than instructing the jury that the contracts were ambiguous; and (2) both determine the intent of the parties and construe ambiguous terms against the drafter without specifying which task must be completed first. View "Staffing Specifix, Inc. v. TempWorks Management Services, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals declaring the City of Rochester’s competitive bidding process and the resulting contract awarded to First Transit invalid.The City owned a fleet of buses operated by First Transit, Inc. since 2012. Until 2012, those buses were operated by Rochester City Lines Company (RCL). In the instant case, RCL challenged the City’s competitive bidding process, which resulted in the bus operation contract being awarded to First Transit. The City’s appointed moderator rejected RCL’s protest. The court of appeals, however, ruled that the City’s request for proposals (RFP) appeared impermissibly biased against RCL. The Supreme Court reversed and remanded the case, holding that RCL forfeited any appearance-of-bias argument. View "Rochester City Lines Co. v. First Transit, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals declaring the City of Rochester’s competitive bidding process and the resulting contract awarded to First Transit invalid.The City owned a fleet of buses operated by First Transit, Inc. since 2012. Until 2012, those buses were operated by Rochester City Lines Company (RCL). In the instant case, RCL challenged the City’s competitive bidding process, which resulted in the bus operation contract being awarded to First Transit. The City’s appointed moderator rejected RCL’s protest. The court of appeals, however, ruled that the City’s request for proposals (RFP) appeared impermissibly biased against RCL. The Supreme Court reversed and remanded the case, holding that RCL forfeited any appearance-of-bias argument. View "Rochester City Lines Co. v. First Transit, Inc." on Justia Law

State law did not preempt a proposal to amend the charter of the City of Bloomington to require voter approval before the City can implement organized collection of solid waste.Appellants petitioned the City for a ballot initiative seeking the enactment of an ordinance that would require voter approval before the City could implement organized waste collection. The City declined to place Appellants’ proposed amendment on a ballot on the ground that Minn. Stat. 115A.94 preempted the field of regulation by the process by which a city organizes waste collection. The district court granted summary judgment for the City. The court of appeals affirmed. The Supreme Court reversed, holding (1) the legislature did not intend to occupy the field of regulation of the process of organizing collection of solid waste; and (2) therefore, Appellants’ proposed charter amendment was not preempted by state law. View "Jennissen v. City of Bloomington" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the district court’s denial of Father’s motion to increase his parenting time to every other week, holding that Father’s proposed modification was a de facto motion to modify physical custody, and therefore, the endangerment standard applied.Father had parenting time every other weekend with his minor child, and, during summer months, the parties alternated weeks with the child. When Father brought a motion to expand the alternating week schedule to the entire year the district court treated the motion as a motion to modify physical custody. The court applied the endangerment standard in Minn. Stat. 518.18(d)(iv) and, finding that Father did not present a prima facie case of endangerment, denied the motion. The court of appeals reversed, holding that Father’s motion was no a motion to modify custody. The Supreme Court reversed, holding that Father’s motion was a substantial change that would modify the parties’ custody arrangement. View "Christensen v. Healey" on Justia Law

The Supreme Court affirmed the decision of the court of appeals interpreting Minn. Rev. Stat. 524.3-101 to allow real property to devolve immediately upon a testator’s death to a residual devisee.Plaintiff, in her capacity as personal representative to her father’s estate, sued Defendants to quiet title to residential property owned by her father at his death. Plaintiff’s brother, John, conveyed his interest in the property by quitclaim deed to Minnesota Premier Properties a few days after Wells Fargo bought the foreclosed property at a sheriff’s sale after the decedent’s death. The district court granted summary judgment to Plaintiff, concluding that John did not have an interest to convey to Premier through the quitclaim deed. The court of appeals reversed, holding that, under section 524.3-10, a valid, transferable ownership interest in real property devolves immediately upon a testator’s death to a person to whom the property is devised by the testator’s will. The Supreme Court affirmed, holding that the court of appeals did not err in interpreting the statute. View "Laymon v. Minnesota Premier Properties, LLC" on Justia Law