Minnesota Lawyer
Civil
Real Property
Marketable Title
This case concerned whether the Marketable Title Act (MTA), Minn. Stat. § 541.023, extinguished the public’s interest in an undeveloped road dedicated to public use by plat over 100 years ago. Respondent trustee initiated a Torrens proceeding to register title to land including the undeveloped road. The Court of Appeals affirmed the District Court’s summary judgment ruling that the public’s interest in the road had been extinguished by operation of the MTA.
The Supreme Court held that the Marketable Title Act does not apply to land dedicated to public use by plat. Reversed and remanded.
A21-0829, A21-0832 In re Application of Moratzka (Court of Appeals)
Workers’ Compensation
Assault Exception
This appeal arose out of the application of a provision of the Minnesota Workers’ Compensation Act known as the “assault exception.” Relator was attacked at his job site by a mentally ill acquaintance as relator was performing his work duties. The assailant falsely believed, as a result of his mental illness, that relator was involved in killing his uncle; the uncle died from a heart ailment with no evidence of any unusual circumstances. Relator, who suffered serious injuries in the attack, sought workers’ compensation benefits, which under Minn. Stat. § 176.021, subd. 1, are to be awarded “in every case of personal injury or death of an employee arising out of and in the course of employment.” The workers’ compensation court rejected his claim based on the statutory definition of “personal injury.” The compensation judge determined, and the Workers’ Compensation Court of Appeals (WCCA) agreed, that under this definition of personal injury, including the so called assault exception, relator was not entitled to recover workers’ compensation benefits.
The Supreme Court held that (1) under the Workers’ Compensation Act, the plain meaning of the assault exception in Minn. Stat. § 176.011, subd. 16, is that an act must be consciously and deliberately intended to injure the employee for personal reasons; and (2) under the assault exception, the mental illness of an assailant does not prevent a compensation judge from determining that an assailant intended to injure an employee for personal reasons, which bars the victim employee from receiving workers’ compensation benefits. Affirmed.
A22-0656 Profit v. HRT Holdings (Workers’ Compensation Court of Appeals)
Taxation
Property Tax
Two rental car companies at the Minneapolis-St. Paul International Airport separately appealed to the Tax Court from the county’s valuation of their respective properties. The county then appealed both cases after the Tax Court’s estimated market value in each case was lower than the value that county sought at trial. The appeals—which were consolidate for purposes of this opinion—raised the same issue: whether the Tax Court erred in declining to include a “concession fee” as rental income attributable to the property under the income-capitalization approach to property valuation.
The Supreme Court held that the Tax Court did not clearly err by excluding the “concession fee” from rental income in the income-capitalization approach the court used to assess market value. Affirmed.
A22-1022, A22-1024 Enterprise Leasing Co. v. County of Hennepin (Tax Court)
Orders
Attorney Discipline
Reinstatement
Jason J. Ahn was reinstated to the practice of law.
Attorney Discipline
Suspension
Elizabeth W. Bloomquist was suspended from the practice of law for a minimum of 30 days.
