Frederick Farms, Inc. v. County of Olmsted, 2011 Minn. LEXIS 467

In 2008 Olmsted County reclassified Frederick Farms, Inc.’s 300 acres from agricultural-homestead to agricultural-nonhomestead.
James Frederick personally owns 80 acres contiguous to Frederick Farms’ land and continues to claim agricultural-homestead on those acres.
Frederick Farms argued that as a joint family farm venture with James Frederick, the entire 380 acres should receive agricultural-homestead classification.
The Minnesota Tax Court denied summary judgment to Frederick Farms, leading to a stipulation and entry of judgment in favor of Olmsted County for purposes of appeal.
This Court reviews de novo the tax court’s application of Minnesota law to undisputed facts and the ownership requirements for homestead classifications.
The court ultimately holds that a joint family farm venture must own or lease land to qualify for agricultural-homestead status, and the joint venture in this case did not own or lease the 300 acres.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a joint family farm venture claim agricultural-homestead for land it does not own	Frederick Farms asserts the venture can own the land collectively and thus claim a single homestead.	The ownership requirement rests with the land owned by the venture, not merely used by it.	No; the venture must own or lease the land to qualify.
Does ownership by a participant satisfy the venture’s ownership requirement	Any participant’s ownership (Frederick Farms’ 300 acres) should satisfy the venture’s ownership.	Ownership must be in the joint venture itself, not merely by a participant.	No; ownership must be in the venture, not merely by a participant.
Is subdivision 8(a) read to allow an exception that would attribute ownership to the venture via a participant	Subdivision 8(a) should allow attribution of ownership to the venture through a participant.	Text and context require the venture to own the land; attribution would render 14(g) meaningless.	No; cannot reinterpret to defeat the explicit ownership requirement.
Does subdivision 14(g) leasing provision rescue Frederick Farms given lack of venture ownership	Subdivision 14(g) could allow homestead status for leased property to the venture.	There must be a lease to the venture from a party; no lease arrangement shown for the 80 acres.	Fails; lease exception not applicable without a lease from a venture member on the 80 acres.

City of Cohasset v. Minn. Power, 798 N.W.2d 50 (Minn. 2011) (statutory reading of the statute as a whole; plain meaning governs)
Premier Bank v. Becker Dev., LLC, 785 N.W.2d 753 (Minn. 2010) (courts prohibit adding words omitted by Legislature)
Hohmann v. Comm’r of Revenue, 781 N.W.2d 156 (Minn. 2010) (de novo review when facts undisputed; correct application of law)