Ronald R. and Dee L. Johnson, Relators,
County of Hennepin, Respondent.
Court Office of Appellate Courts
R. Johnson and Dee L. Johnson, Excelsior, Minnesota, pro se.
Michael O. Freeman, Hennepin County Attorney, Jane N.B.
Holzer, Assistant County Attorney, Minneapolis, Minnesota,
the tax court did not make any errors of law and the record
supports the court's findings and conclusions, the
decisions of the tax court are affirmed.
and decided by the court without oral argument.
GILDEA, CHIEF JUSTICE.
Ronald and Dee Johnson (the "Johnsons") initiated
this action, which challenges the property taxes that
Hennepin County (the "County") assessed against
their property. The tax court denied relief to the Johnsons
and they appeal. Because we conclude that the tax court did
not err, we affirm.
April 30, 2014, the Johnsons filed a petition challenging the
County's assessments of their real property for tax years
2007 through 2013. In addition to the assessment challenges,
the Johnsons asserted a variety of constitutional claims. The
tax court granted the County's motion to dismiss the
petition for tax years 2007 through 2012 because those claims
were not filed in compliance with Minn. Stat. §§
278.01-.02 (2016), which require that a petition not contain
more than one assessment date and that it be filed on or
before April 30 of the year in which the tax becomes payable.
The tax court dismissed the constitutional claims because the
court concluded that it had no jurisdiction over the claims
and could not gain jurisdiction through an
"Erie Shuffle." In an order, we concluded
that the tax court's decisions on both issues were
"correct." Johnson v Cty. of Hennepin,
No. A15-1339, Order at 5 (Minn. filed Oct. 23, 2015).
order filed April 4, 2016, the tax court resolved the merits
of the Johnsons' remaining claims, challenging the
assessment for the 2013 tax year, in favor of the County.
Johnson v. Cty. of Hennepin, No. 27-CV-14-07031,
2016 WL 1399315 (Minn. T.C. Apr. 4, 2016). Specifically, the
tax court held that the Johnsons had failed to overcome the
prima facie validity of the County's assessed value of
their property, see Minn. Stat. § 271.06, subd.
6 (2016), and that they did not meet their evidentiary burden
to prove unequal assessment. Johnson, 2016 WL
1399315, at *4. The tax court also concluded that although
the subject property qualified for Green Acres
classification,  it did not qualify as homestead property.
Id. at *5. The tax court also rejected the
Johnsons' assertion that Dee Johnson had not received
sufficient service of the court's scheduling order.
Id. at *3.
the Johnsons brought a series of post-trial motions,
including a motion for a new trial, three separate motions
for rehearing, and a motion to transfer the case to the