Geraldine Tyler v. State of Minnesota
26 F.4th 789
8th Cir.2022Background
- Tyler stopped paying property taxes on a Minneapolis condominium in 2010, accruing about $15,000 in delinquent taxes.
- Hennepin County obtained judgment, the State took absolute title after the statutory redemption period, and Tyler did not redeem, confess judgment, or repurchase.
- The county sold the condominium in 2016 for $40,000 and distributed the net proceeds under Minnesota’s statutory scheme, which does not award surplus proceeds to former owners.
- Tyler sued, alleging the county’s retention of the $25,000 surplus violated the Takings Clause, constituted an excessive fine, violated substantive due process, and was unjust enrichment under state law.
- The district court dismissed all claims for failure to state a claim; the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Takings (federal & state) | County took surplus equity ($25k) without just compensation. | Minnesota law provides no property interest in surplus; owner had notice/opportunity to protect interest. | No taking: under state law no property interest in surplus; retention permissible where owner had adequate notice/opportunity. |
| Excessive fine (Eighth Amendment) | Retention of surplus is punitive and disproportionate. | Statutory scheme is remedial/administrative, not an excessive punitive fine. | Dismissed: no excessive-fine violation. |
| Substantive due process | Statute/foreclosure deprived Tyler of property without adequate protection of liberty/property interests. | Process provided (notice, redemption, confession of judgment, repurchase window); statutory scheme governs distribution. | Dismissed: no substantive due process violation. |
| Unjust enrichment (state law) | County was unjustly enriched by keeping surplus from sale. | Statute prescribes distribution of net proceeds and displaces any common-law claim. | Dismissed: statutory scheme precludes unjust-enrichment claim. |
Key Cases Cited
- Jones v. Flowers, 547 U.S. 220 (notice requirements in tax-foreclosure context)
- Phillips v. Wash. Legal Found., 524 U.S. 156 (property interests defined by state law)
- Nelson v. City of New York, 352 U.S. 103 (government may retain surplus after adequate notice/opportunity)
- Farnham v. Jones, 19 N.W. 83 (Minn. 1884) (historical common-law treatment of surplus proceeds)
- L.L. Nelson Enters. v. Cnty. of St. Louis, 673 F.3d 799 (8th Cir. 2012) (standard of review for dismissal)
- Hall v. State, 908 N.W.2d 345 (Minn. 2018) (state takings clause analyzed consistent with federal takings principles)