Civil
Arbitration
Review
This case concerned the scope of judicial review of arbitration awards. Respondent healthcare system and appellant union arbitrated a dispute regarding respondent’s use of temporary staffing agency workers. Appellant, which represented two bargaining units of respondent’s employees, asserted that respondent had violated its collective bargaining agreements by using the staffing agency workers for more than 6 months. After interpreting applicable provisions in the agreements, the arbitrator issued an award in favor of appellant. Respondent filed a motion in District Court to vacate the arbitration award, arguing that the arbitrator had exceeded his powers. The District Court denied the motion and confirmed the award. Respondent appealed, and the Court of Appeals reversed, concluding that the arbitration award must be vacated because it did not draw its essence from the collective bargaining agreement.
The Supreme Court held that an arbitrator does not exceed their powers, within the meaning of Minn. Stat. § 572B.23(a)(4) of the Minnesota Uniform Arbitration Act, where the arbitrator’s decision draws its essence from the underlying collective bargaining agreement. Here, the Court of Appeals erroneously substituted its own judgment for that of the arbitrator. Reversed and remanded.
A21-1079 Hennepin Healthcare Sys., Inc. v. AFSCME Minn. Council 5 (Court of Appeals)
Taxation
Property Valuation
This case arose from the Tax Court’s market valuation of the real estate of the Minneapolis Hyatt Regency Hotel for the tax years 2016, 2017, and 2018. Relator, which owns the hotel, challenged the market values assessed by respondent county for these tax years. Relator first contested the Tax Court’s discovery and evidentiary decisions related to the nonpublic assessor’s records in the county’s possession. It asserted that the Tax Court erred by ordering that only the information that the county provided to the county’s expert—and upon which he relied—needed to be provided to relator in discovery. Relator also contended that the Tax Court clearly erred when the court accepted the appraisal report of relator’s expert, but then made unsupported and unexplained adjustments to the expert’s valuations. Through its adjustments, the Tax Court increased the market value of the hotel real estate from the expert’s appraised values of $39,700,000, $39,300,000, and $35,200,000 to $71,703,000, $67,940,000, and $68,881,000, for tax years 2016, 2017, and 2018, respectively.
The Supreme Court held that (1) because Minn. Stat. § § 278.05, subd. 3, and 13.03, subd. 6, can be read together, the Tax Court did not abuse its discretion when it applied the balancing test of § 13.03, subd. 6, and found that only the information that respondent county provided to its expert and on which he relied had to be made available to the taxpayer; and (2) the Tax Court’s adjustments to the market valuations of the subject property were not clearly erroneous. Affirmed.
A22-0671 1300 Nicollet, LLC v. County of Hennepin (Tax Court)
Unjust Enrichment
Damages
This dispute arose out of a romantic relationship between appellant and respondent. Over the course of their relationship, appellant made $282,736.02 in net cash payments directly to and on behalf of respondent to renovate respondent’s home. After the pair ended their relationship, respondent sold her home for $1.2 million, and appellant sued respondent for the amount of money that he contributed to renovate the home. The District Court concluded that respondent had been unjustly enriched by appellant’s financial contributions and awarded appellant $282,736.02 for appellant’s contributions to improve respondent’s home. On appeal, a divided Court of Appeals concluded that appellant could not recover on his unjust enrichment claim because the claim involved “investments in real estate,” which required appellant to prove the increase in value to respondent’s home attributable to his financial contributions. Because appellant did not do so before the District Court, the Court of Appeals majority reversed appellant’s $282,736.02 unjust enrichment award.
The Supreme Court held that (1) cash payments by a plaintiff directly to or on behalf of a defendant serve as an appropriate measure of relief in an unjust enrichment action involving purported investments to real property; and (2) the District Court did not clearly err in its award to plaintiff. Reversed.
A21-1427 Herlache v. Rucks (Court of Appeals)
Criminal
Felony Murder
Foreseeability
Following a bench trial, defendant was convicted of first-degree felony murder under an aiding and abetting theory of criminal liability. Defendant filed a direct appeal that was stayed so he could pursue postconviction relief. In his postconviction petition, defendant alleged a claim of ineffective assistance of trial counsel. After holding an evidentiary hearing, the District Court denied defendant’s postconviction petition. Defendant appealed.
The Supreme Court held that (1) a recanting codefendant’s prior inconsistent statement is properly admitted as substantive evidence if the statement meets the requirements of Minn. R. Evid. 801(d)(1)(A); (2) when viewed in a light most favorable to the verdict, the evidence presented at trial is sufficient to prove that a victim’s death was a reasonably foreseeable result of the burglary when the perpetrators were armed and the defendant participated in planning the burglary; (3) the District Court does not abuse its discretion in denying postconviction relief on the grounds of ineffective assistance of counsel for failing to communicate and explain an Alford plea when the petitioner does not present any substantive evidence other than their own assertions that such a plea offer was made; (4) when multiple offenses are alleged in the charging instrument, Minn. Stat. § 609.035, subd. 1, does not prohibit the District Court from finding the defendant not guilty of some charges but guilty of the remaining charges; (5) a challenge to an indictment is forfeited if not raised before trial; absent a showing of good cause, the appellate court will not review the issue; and (6) when viewed in a light most favorable to the verdict, the evidence presented at trial was sufficient to prove that the defendant committed first-degree felony murder under an aiding and abetting theory of criminal liability. Affirmed.
A19-0362, A22-0290 State v. King (St. Louis County)
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