Dealers Manufacturing, Co. v. County of Anoka

615 N.W.2d 76, 2000 Minn. LEXIS 478, 2000 WL 1129203
CourtSupreme Court of Minnesota
DecidedAugust 10, 2000
DocketC9-99-1869
StatusPublished
Cited by6 cases

This text of 615 N.W.2d 76 (Dealers Manufacturing, Co. v. County of Anoka) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dealers Manufacturing, Co. v. County of Anoka, 615 N.W.2d 76, 2000 Minn. LEXIS 478, 2000 WL 1129203 (Mich. 2000).

Opinions

OPINION

STRINGER, Justice.

We consider whether a taxpayer challenging a property tax assessment is entitled to a reduction in the assessed value of contaminated property based on stigma. Taxpayer, Dealers Manufacturing, Co. (Dealers), petitioned the tax court for a reduction in the assessment of its contaminated property in Anoka County (the county) on the basis that, because the county failed to take into account the stigma ef-feet on the market value of the property, the assessed value exceeded the market value of the property. The parties filed cross-motions for partial summary judgment as to the interpretation of Minn.Stat. § 273.11, subd. 17 (1998), specifically, whether it limits reduction in market value for stigma relating to contamination. The tax court granted Dealers’ motion concluding that Minn.Stat. § 273.11, subd. 17 does not apply to reductions in market value due to stigma. See Dealers Mfg. Co. v. County of Anoka, No. C4-98-2963, 1999 WL 717228, at * 5-6 (Minn. Tax Ct. Sept. 8,1999). We affirm.

The subject of this property tax dispute is a manufacturing plant site in Anoka County owned by Dealers. In 1988 Dealers discovered groundwater and soil contamination related to the use of solvents and the Minnesota Pollution Control Agency (MPCA) placed the property on the State Superfund list. Dealers implemented a MPCA-approved response action plan in 1995. As of 1998, Dealers had spent $350,000 to clean up the property against a total clean-up cost projection of $560,000. Contaminants were still present on the property at the time of the tax court’s partial summary judgment ruling.

In the course of its remediation efforts, in 1997 Dealers obtained an appraisal by Alan Leirness, MAI, which concluded that the property value was subject to a stigma devaluation factor due to the risk of liability for clean-up costs, fear of liability to the public arising from the contamination, and possible lack of mortgageability.1 In Leirness’ opinion the impact of the stigma could exceed $500,000.

The county assessed the market value of the property at $1,336,600 in 1997 and Dealers filed a petition in the tax court in 1998 pursuant to Minn.Stat. § 278.01 [78]*78■ (1998)2 challenging the assessment on the basis that it exceeded the property’s actual market value in violation of Minn.Stat. § 273.11, subd. 1 (1998),3 and that the-property was not assessed equally when compared with other property in violation of Dealers’ constitutional rights to equal protection and uniform taxation.4 The county responded that Minn.Stat. § 273.11, subd. 175 limits reductions in market value resulting from contamination, including the stigma factor, to the reasonable cost of a response action plan.

In granting Dealers’ motion for partial summary judgment, the tax court noted that Minn.Stat.. § 273.11, subd. 17 makes no reference to “stigma” — it addresses only reduction in market value resulting from the “presence of contaminants” — and that because stigma can remain after all contaminants have been removed from the property, it is incongruous to construe it to be included in “contamination value.” The court further noted that assessors are required to consider all relevant factors when valuing property and to assess property at market value, see Minn. Stat. § 273.12 (1998); Minn.Stat. § 273.11, subd. 1, and to exclude or limit the stigma factor in the valuation of the property would be inconsistent with this statutory mandate. Finally, the tax court reasoned that as the legislature was well aware of the impact of stigma on property tax revenues,6 if it had intended to include stigma among the factors determining contamination value, it would have referenced “stigma” in Minn.Stat. § 273.11, subd. 17. The tax court ordered a trial to determine the value of the property as of January 2, 1997, consistent with its ruling that the market value impact of stigma was not to be included in the contamination value for purposes of section 273.11, subd. 17.7

[79]*79Our review of an order of the tax court is limited to whether the court lacked jurisdiction or it was contrary to the evidence or based on an error of law. See Minn.Stat. § 271.10 (1998). The tax court appropriately grants summary judgment where there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law. See Minn. R. Civ. P. 56.03; see also Brookfield Trade Ctr., Inc., -609 N.W.2d at 873-74; Rule 81.01(a) (noting Minnesota Rules of Civil Procedure apply to tax court proceedings where not inconsistent with tax court procedures). The tax court’s partial summary judgment ruling is based on the resolution of a question of law which we review de novo. See F-D Oil Co., Inc. v. Commissioner of Revenue, 560 N.W.2d 701, 704 (Minn.1997).

We begin our analysis with the observation that we have recognized the practice of considering the market value impact of both the present value of cleanup costs and the stigma devaluative factor as appropriate considerations in determining the market value of contaminated properties. See Westling v. County of Mille Lacs, 543 N.W.2d 91, 93 (Minn.1996) (Westling II). In Westling II, we affirmed a market valuation of zero based on the estimated cost of clean-up and the stigma discount. Id. ■

The county argues however, that Minn. Stat. § 273.11, subd. 17 places a cap on deductions from market value relating to contamination, including the stigma factor, at the cost of a reasonable remediation plan. The county contends that even though the statute does not refer to “stigma,” the “presence of contaminants” is defined as “the release or threatened release * * * of contaminants on the property,” 8 Minn.Stat. § 270.92, subd. 5 (1998)-thus because property affected by stigma is subject to the “release or threatened release” of contaminants, Minn.Stat. § 273.11, subd. 17 applies to stigma. The county attempts to provide a coherent application of Minn.Stat. § 273.11, subd. 17 consistent with its argument, contending that the statute should be applied in the following situations: where a taxpayer has not yet begun to implement a response action plan for property affected by stigma, the contamination value should equal the cost of such a plan; after the taxpayer has begun to implement the plan, the contamination value should equal the amount of the remaining clean-up costs plus any market value reduction resulting from stigma up to the total cost of the response action plan; as the plan nears completion, the portion of the deduction attributable to clean-up costs should decrease and the portion attributable to stigma should increase, with the deduction never exceeding the total cost of the response action plan.

The county’s argument fails for several reasons. First, a stigma factor can attach to property whether contaminants are present, are threatened, or are totally absent.

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Dealers Manufacturing, Co. v. County of Anoka
615 N.W.2d 76 (Supreme Court of Minnesota, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
615 N.W.2d 76, 2000 Minn. LEXIS 478, 2000 WL 1129203, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dealers-manufacturing-co-v-county-of-anoka-minn-2000.