886 N.W.2d 821
Minn.2016Background
- STRIB IV, LLC is a single‑member LLC wholly owned by Richard T. Burke and has owned two Medina parcels (total ~39.96 acres) since 2007; Burke does not live on those parcels.
- Burke personally (and through another single‑member LLC) owns adjoining agricultural parcels that have Green Acres classification.
- STRIB IV applied for Green Acres property tax classification under Minn. Stat. § 273.111; Hennepin County denied the application and the tax court affirmed.
- The parties agreed the sole legal question was whether the Green Acres statute “disregards” a single‑member LLC (treating the land as owned by the natural person member) so that STRIB IV’s land could qualify.
- The Supreme Court considered statutory text, surrounding provisions, the statute’s “broadly construed” directive, and precedent about statutory silence and entity disregard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether “individuals” in Minn. Stat. § 273.111 includes single‑member LLCs so that land titled in STRIB IV qualifies for Green Acres | The statute’s silence about single‑member LLCs and the directive to construe the statute broadly justify treating STRIB IV as disregarded and its land as owned by Burke | The statute’s plain language distinguishes individuals (natural persons) from entities and explicitly lists the types of entities eligible; single‑member LLCs are not included and are disregarded only where the Legislature has said so | Court held “individuals” means natural persons; statute does not authorize disregarding single‑member LLCs here, so STRIB IV’s land is not eligible for Green Acres |
Key Cases Cited
- Krueger v. Zeman Constr. Co., 781 N.W.2d 858 (Minn. 2010) (refusing to add persons or expand cause of action despite liberal construction directive)
- MBNA Am. Bank, N.A. v. Comm’r of Revenue, 694 N.W.2d 778 (Minn. 2005) (statutory silence can create ambiguity in limited circumstances)
- Burkstrand v. Burkstrand, 632 N.W.2d 206 (Minn. 2001) (example where statutory silence created ambiguity)
- Reiss Greenhouses, Inc. v. Cty. of Hennepin, 290 N.W.2d 785 (Minn. 1980) (earlier interpretation invoking statute’s broadly construed directive)
- Wegener v. Comm’r of Revenue, 505 N.W.2d 612 (Minn. 1993) (rare decision applying purpose over plain text when plain meaning utterly confounds legislative purpose)