Odunlade v. City of Minneapolis, 823 N.W.2d 638

Relators in three Minneapolis neighborhoods challenge City assessments for 2008–2010, claiming overvaluation due to excluding arms-length purchases and relying on earlier higher sales.
Relators allege federal and state equal protection violations, Minnesota uniformity violation, and Minn. Stat. § 273.11 market-value requirement.
Tax court dismissed all claims, holding Minn. Stat. ch. 278 the exclusive remedy and untimeliness or improper joinder for 2010 claims.
Major issue: whether Chapter 278 applies to a broad, multi-property challenge and whether multiple petitioners may join in one petition for 2010 claims.
Supreme Court majority: Chapter 278 applies; 2008–2009 claims untimely; declaratory/mandamus claims barred; but 2010 claims may proceed in one petition by multiple relators.
Dissent: agrees with timeliness and constitutional outcomes but rejects the majority’s reading of § 278.01 to allow multiple petitioners to file a single petition for multiple parcels.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 278.01 provide the exclusive remedy for relators’ claims?	Odunlade argues § 278.01 applies to assessment challenges.	City maintains § 278.01 covers only the specified bases and is exclusive.	Yes, § 278.01 provides the exclusive remedy for these claims.
Are the 2008 and 2009 claims time-barred under § 278.01?	Relators contend timely under annual 278 petitions.	Taxes payable deadlines render 2008–2009 claims untimely.	Correct; 2008–2009 claims are time-barred.
May multiple relators join in a single § 278 petition for 2010 (multiple properties)?	Canon of singular includes plural allows one petition for multiple parcels by multiple owners.	Statute’s singular form implies one petitioner, with § 278.02 allowing multiple parcels only for a single petitioner.	Yes, a single petition by multiple petitioners may raise common issues for 2010 claims.
Do relators' constitutional claims fail as a matter of law?	Equal protection and uniformity violations based on excluding bank sales.	Relators lack viable disparate-treatment or disparate-impact allegations and fail to state a claim.	Constitutional claims fail on the merits.

Fichtner v. Schiller, 271 Minn. 263 (Minn. 1965) (exclusive remedy for unfair or unequal valuation claims)
Evanson v. Comm’r of Taxation, 280 Minn. 559 (Minn. 1968) (statutory exclusive remedy for tax valuation challenges)
Bethke v. County of Brown, 301 Minn. 380 (Minn. 1974) (each year’s taxes must be challenged under chapter 278)
Programmed Land, Inc. v. O’Connor, 633 N.W.2d 517 (Minn. 2001) (broad interpretation of 278.01; policy aims)
In re Objections & Defs. to Real Prop. Taxes, 410 N.W.2d 321 (Minn. 1987) (joint consideration of property tax objections and procedures)
Arlington Heights v. Metro. Housing Development Corp., 429 U.S. 252 (U.S. 1977) (equal protection disparate-impact framework)
San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (U.S. 1973) (wealth not a suspect class for equal protection claims)
Land O’Lakes Dairy Co. v. Vill. of Sebeka, 225 Minn. 540 (Minn. 1948) (declaratory relief and related preclusion principles in tax disputes)