Justia Minnesota Supreme Court Opinion Summaries

After the Dakota County Assessor estimated the market value of Westview Mall, owned by KCP Hastings, LLC, KCP challenged the estimated assessments. After a trial, the tax court adopted market valuations of the property that exceeded the County’s estimated assessments. The Supreme Court affirmed in part, vacated in part, and remanded, holding that the tax court (1) did not clearly err by using the mall’s gross building area rather than its gross leasable area in its calculations of market value; (2) clearly erred when it rejected KCP’s discounted-cash-flow analysis, which KCP’s appraiser used to arrive at his income-approach valuation; and (3) abused its discretion by determining the value of the subject property relying solely on the sales-comparison approach. View "KCP Hastings, LLC v. County of Dakota" on Justia Law

The property at issue in this appeal was the ethanol-production facility owned by Guardian Energy, LLC. After the county assessor estimated the market value of the property, Guardian Energy challenged the assessments by filing petitions with the tax court. The tax court determined that the assessed value of the property was significantly higher than the values proposed by either party. Guardian Energy sought review. The Supreme Court (1) affirmed the tax court’s determination that twenty-seven tanks used in the ethanol-production process were taxable real property; but (2) vacated the tax court’s valuation of the ethanol plant, holding that the tax court failed adequately to explain its calculation of external obsolescence, and therefore, the court’s valuation of the facility was not reasonably supported by the record as a whole. View "Guardian Energy, LLC v. County of Waseca" on Justia Law

Relators were sixteen electric cooperatives located in Minnesota. The cooperatives filed amended sales-tax returns for tax periods spanning the years 2004-06 to recover sales taxes they had paid for the portion of the revenues that they later converted into equity. The Commissioner of Revenue initially granted the refunds claimed on the cooperatives’ amended returns. However, the Commissioner later determined that the refund was made in error and assessed the cooperatives to recover the amounts refunded to them. The cooperatives appealed. The tax court concluded that the cooperatives were not legally entitled to sales-tax refunds for any earnings that they later converted into equity and that the challenged assessments were timely. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) electric cooperatives may not reclassify portions of monthly payments by their customers as equity contributions and receive sales-tax refunds based on the reclassification; and (2) when the Commissioner assesses a taxpayer based on a deficiency created by an erroneous refund, the two-year statute of limitations for erroneous refunds generally applies. View "Connexus Energy v. Comm’r of Revenue" on Justia Law

After a jury trial in 1995, Appellant was found guilty of first-degree premeditated murder and attempted first-degree premeditated murder. The district court imposed a sentence of life imprisonment with the possibility of release for the first-degree murder offense and a consecutive sentence of 180 months’ imprisonment for the attempted first-degree murder offense. In 2014, Appellant, who is African American, moved to correct his sentence, arguing that his sentence was unlawful under Minn. Sent. Guidelines II.F and that his sentence violated his right to equal protection because his sentence was more severe than the sentences of other similarly situated offenders who were not African American. The postconviction court denied relief. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by denying Appellant’s motion to correct his sentence. View "Nunn v. State" on Justia Law

Appellant was convicted of first-degree murder of a peace officer. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a postconviction petition, which the district court denied. The Supreme Court affirmed. Thereafter, Appellant filed a motion for relief from judgment alleging a number of claims, including ineffective assistance of trial and appellate counsel. Treating Appellant’s motion as a second postconviction petition, the district court denied relief, concluding that all of Appellant’s claims were untimely under Minn. Stat. 590.01(4). The Supreme Court affirmed, holding (1) even if the district court had treated Appellant’s request for relief as a motion under Minn. R. Civ. P. 60.02, his request would have been untimely; and (2) Appellant’s claims were also untimely under the postconviction statute. View "Evans v. State" on Justia Law

Based on an indirect audit that the Commissioner of the Minnesota Department of Revenue conducted of the sales and use tax returns for Conga Corporation for the tax periods from January 1, 2007 through March 31, 2010, the Commissioner determined that Conga had unreported revenues for the relevant tax periods and issued an order assessing additional sales, use, and entertainment taxes, plus penalties and interest. The tax court affirmed the Commissioner’s order with respect to the assessment of 2007 taxes but reversed with the penalty assessment for tax years 2008-2010, concluding that the Commissioner’s decision to use an indirect audit was not supported by the record. The Supreme Court reversed, holding that the Commissioner’s decision to use an indirect audit to assess taxes was supported by the record. Remanded. View "Conga Corp. v. Comm’r of Revenue" on Justia Law

On July 13, 2007, Appellant was charged with fifth-degree controlled substance crime. Appellant pleaded guilty. On February 27, 2009, the court stayed adjudication of Appellant’s case under Minn. Stat. 152.18(1), placing him on probation. On May 24, 2011, Appellant admitted to violating the terms of his probation. The district court revoked the stay of adjudication and entered a judgment of conviction. On May 23, 2013, Appellant filed a petition for postconviction relief requesting that he be permitted to withdraw his guilty plea. The postconviction court summarily denied the petition on the ground that it was untimely under Minn. Stat. 590.01(4)(a)(1) because it was filed more than two years after the order staying adjudication. The court of appeals affirmed, holding that a stay of adjudication is a “sentence” under Minn. Stat. 590.01(4)(a)(1) that triggers the two-year statute of limitations for filing a postconviction petition. The Supreme Court reversed, holding that a stay of adjudication under Minn. Stat. 152.18(1) is not a judgment of conviction or sentence under Minn. Stat. 590.01(4)(a)(1), and therefore, the district court erred by concluding that Appellant’s petition was time-barred. View "Dupey v. State" on Justia Law

Respondent, the chief investigator for the Medicaid Fraud Control Unit (MFCU) of the Minnesota Attorney General’s Office, was investigating Affiliated Counseling Center, LLC (Affiliated) when she applied for and received a search warrant for Affiliated’s premises. The police executed the warrant and seized numerous documents from Affiliated’s office, including patient files. Thereafter, Appellant, the sole owner of Affiliated, sued Respondent, alleging that Respondent committed conversion and trespass to chattels by losing and/or destroying some of Affiliated’s patient files. Respondent moved to dismiss, asserting that she was entitled to prosecutorial immunity. The district court denied the motion. The court of appeals reversed, concluding that Respondent was entitled to prosecutorial immunity because her challenged conduct was taken pursuant to her statutory authority to investigate Medicaid fraud. The Supreme Court reversed, holding (1) prosecutorial immunity does not extend to an investigator when the investigator’s conduct is not intimately involved with the initiation and maintenance of criminal charges; and (2) therefore, the court of appeals erred when it concluded that Respondent was entitled to prosecutorial immunity. View "Stresemann v. Jesson" on Justia Law

Appellant was one of nineteen individuals injured when a school bus was struck by an at-fault vehicle. Appellant sought excess underinsured motorist (UIM) coverage benefits from his family’s automobile policy with American Family Mutual Insurance Company because his damages exceeded the recovery available to him under the coverage of the school bus. American Family denied Appellant’s claim for excess UIM benefits, claiming that, pursuant to the Minnesota No-Fault Automobile Insurance Act, Appellant’s excess UIM coverage ($100,000) did not “exceed” the UIM coverage provided by the school bus’s insurance ($1,000,000). Appellant then brought this action, seeking the difference between the recovery he received and his UIM policy limits from American Family. The district court granted summary judgment in favor of American Family, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the phrase “coverage available,” as used in Minn. Stat. 65B.49(3)(a)(5), in reference to the “excess insurance protection” for an injured insured, is ambiguous; and (2) the phrase “coverage available” means the benefits actually paid to the insured under the coverage provided by the occupied vehicle’s policy. View "Sleiter v. Am. Family Mut. Ins. Co." on Justia Law

Appellant was found guilty of second-degree murder for the benefit of a gang, attempted second-degree murder, second-degree assault for the benefit of a gang, and second-degree assault. The court of appeals reversed Appellant’s convictions of attempted second-degree murder for the benefit of a gang and second-degree assault for the benefit of a gang. On remand, the district court imposed a 165-month prison sentence for Appellant’s conviction of the lesser-included offense of attempted second-degree murder. On appeal, Appellant argued that because the district court originally imposed a 165-month sentence for his conviction of attempted second-degree murder for the benefit of a gang, the court abused its discretion by imposing the same sentence for his conviction of attempted second-degree murder. The court of appeals affirmed, concluding that the sentence imposed on remand did not violate the public policy and fairness concerns articulated in State v. Prudhomme. The Supreme Court affirmed, holding that Appellant’s sentence was not in error because the record did not support Appellant’s assertion that the district court imposed a greater sentence on remand following his successful appeal of his conviction of attempted second-degree murder for the benefit of a gang. View "State v. Kangbateh" on Justia Law