This case concerns the classification and valuation of the Oak Ridge Conference Center for real estate tax purposes, where American Express challenged the tax court's assessment of the property at $27,300,000 using only the cost approach after classifying it as special purpose. The Minnesota Supreme Court held that the tax court's classification of the facility as special purpose property was clearly erroneous and that its exclusive reliance on the cost approach was an abuse of discretion, given the availability of data for an income approach and the fact that the property was not special purpose. The court further reasoned that the tax court had incorrectly estimated value based on value-in-use rather than market value. However, the court affirmed the tax court's use of reproduction cost, inclusion of certain cost categories, and valuation of the site as though vacant.
This case concerns a challenge by waste collection companies to a sanitary district's tax and subsidy system used to fund a solid waste processing facility and reduce tipping fees. The Minnesota Supreme Court held that the arrangement does not violate the Dormant Commerce Clause because it imposes no differential burden on out-of-state commerce and lacks discriminatory purpose. The court reasoned that any incidental burden on interstate commerce is outweighed by the local benefits of the environmental programs funded by the tax. The decision reverses the lower courts' rulings on discriminatory effect and remands the case.
In State v. Robinson, the Minnesota Supreme Court considered whether the state had jurisdiction under Public Law 280 to prosecute an enrolled member of the Leech Lake Band of Chippewa Indians for underage alcohol consumption, failure to yield to an emergency vehicle, and fleeing a police officer, all occurring on the reservation. The district court dismissed the consumption and failure-to-yield charges as civil/regulatory rather than criminal/prohibitory and dismissed the fleeing charge for lack of probable cause. The court reversed in part and affirmed in part, applying a two-step version of the Cabazon test to classify the laws by determining whether the relevant conduct was generally prohibited or permitted subject to regulation and by examining the state's public policy concerns.
The case involved whether the State of Minnesota had jurisdiction to enforce various traffic and driving-related laws against members of the White Earth Band of Chippewa Indians for violations occurring within the boundaries of their reservation. The Minnesota Supreme Court affirmed the lower courts' dismissal of the charges, holding that the state lacked jurisdiction under Public Law 280. The court reasoned that the laws in question were civil/regulatory rather than criminal/prohibitory in nature, as they did not prohibit conduct but instead regulated it, and there were no exceptional circumstances justifying state enforcement without express federal authorization.
This case involved a dispute over modifying a spousal maintenance award in a divorce proceeding. After the original 1983 dissolution judgment provided Sandra Hecker with temporary maintenance of $800 per month for 121 months, she moved in 1993 to increase the amount and make it permanent, citing her failure to complete vocational training and become self-supporting due to child-rearing responsibilities. The district court granted the modification, awarding $2,000 per month permanently, and the Minnesota Supreme Court affirmed, reducing it to $1,375 per month. The court reasoned that Sandra's unexpected failure to rehabilitate during the temporary period constituted a substantial change in circumstances that rendered the original award unreasonable and unfair under the modification statute, consistent with precedents like Nardini v. Nardini. The decision emphasized the parties' stipulation for temporary maintenance while recognizing the recipient's duty to make reasonable efforts toward self-sufficiency.
The case involved Minnegasco, a natural gas utility, challenging a 1993 rate order from the Minnesota Public Utilities Commission that imputed goodwill revenue from an affiliate and allocated certain costs, resulting in a lower approved rate increase than requested. After a related decision (MAC) held that the Commission lacked statutory authority for imputing such revenue, the court of appeals ruled that the Commission could not retroactively modify the final rate order even on remand. The Minnesota Supreme Court reversed, holding that the Commission has implied authority under the utility statutes to order revenue recoupment to compensate Minnegasco for losses from the unlawful imputation. The core reasoning was that the overall structure of chapter 216B supports providing a meaningful remedy for the Commission's overreach, and a superseding rate order does not eliminate that authority on remand.