THISSEN, Justice.

Edward F. Fox, Mark R. Bradford, Bassford Remele, P.A., Minneapolis, Minnesota, for appellant.

Marc J. Manderscheid, Andrew M. Carlson, Taft Stettinius & Hollister LLP, Minneapolis, Minnesota; and Karin Sonneman, Winona County Attorney, Paul Ellison, Assistant County Attorney, Winona, Minnesota; and Terry W. Viesselman, Martin County Attorney, Fairmont, Minnesota, for respondents.

Mahesha P. Subbaraman, Subbaraman PLLC, Minneapolis, Minnesota, for amicus curiae Alliance Property Consultants, Inc.

Diana L. Longrie, Longrie Law Office, Maplewood, Minnesota, for amicus curiae Chambers Self-Storage Oakdale, LLC.

Anthony C. Paulmbo, Anoka County Attorney, Jason J. Stover, Christine Carney, Assistant County Attorney, Anoka, Minnesota; and James C. Backstrom, Dakota County Attorney, Suzanne W. Schrader, Assistant County Attorney, Hastings, Minnesota; and Michael O. Freeman, Hennepin County Attorney, Sara L. Bruggeman, Assistant County Attorney, Minneapolis, Minnesota; and Peter J. Orput, Washington County Attorney, James Zuleger, Assistant County Attorney, Stillwater, Minnesota, for amicus curiae Minnesota County Attorneys Association.

OPINION

THISSEN, Justice. Appellant Walmart, Inc. owns real property improved with a Walmart Supercenter store in respondents Martin County and Winona County (the Counties). In this consolidated appeal, Walmart claims that, for tax purposes, the Counties overvalued the properties, or unfairly or unequally assessed the value of the properties as compared with other similarly situated properties. Walmart alleges that the Counties engaged in willful, intentional, unlawful, or systematic discrimination in their tax assessments and asserts that such discrimination violates the Equal Protection Clause and Walmart's right to uniformity in taxation. See U.S. Const. amend. XIV ; Minn. Const. art. X, § 1.

Walmart contends that it may proceed with its constitutional claims independent of the statutory remedy in Minn. Stat. ch. 278 (2020), which provides a means to challenge property tax assessments. It accordingly argues that the statutory deadline for bringing such challenges set forth in Minn. Stat. § 278.01, subd. 1(c) (2020), does not apply to its constitutional claims. We disagree. We hold that if a taxpayer's challenge to a property tax assessment is a claim of unfair or unequal assessment, chapter 278 provides the exclusive remedy for such a challenge, even if the challenge is framed as a constitutional violation of the taxpayer's right to equal protection or uniformity in taxation. Because Walmart's claims allege that the Counties have unfairly or unequally assessed its properties, they are subject to the limitations period of chapter 278 and are time-barred. Accordingly, we affirm the decision of the court of appeals.

FACTS

Walmart owns real property improved by Supercenter stores in Fairmont (Martin County) and Winona (Winona County) (the Properties). Walmart alleges that, for tax years 2013 through 2018, the Counties "willfully, intentionally, and unlawfully" discriminated against the company by placing an assessed value greater than market value on the Properties or by unfairly or unequally assessing the value of the Properties as compared with other similarly situated properties. Specifically, Walmart alleges in each complaint:

The ... County Assessor's 2013 through 2018 valuations and assessments of [Walmart's] Real Property intentionally and systematically discriminated against [Walmart's] Real Property as compared to similarly situated properties of the same class in the same taxing district, resulting in prohibited unequal assessments as evidenced by the Comparison Chart .... These disparities and discriminatory, unequal assessments are the result of valuing [Walmart's] Real Property at substantially more than its actual, fair market value or, in the alternative, valuing similar properties at substantially less than their actual, fair market value.

Walmart attached an "Unequal Assessment and Lack of Uniformity Chart" for each property that allegedly "demonstrate[d] the gross disparity between [the Counties’] 2013 through 2018 assessments of [Walmart's] Real Property and the actual market sales and assessments of similar real property" in the respective counties as well as statewide. Walmart alleges that this unequal treatment is intentional and violates its equal protection rights under section 1 of the Fourteenth Amendment to the United States Constitution and its right to uniformity in taxation under Article 10, section 1, of the Minnesota Constitution.

Walmart filed its complaints in district court in May 2019. The Counties moved to dismiss Walmart's complaints under Rule 12.02(e) of the Minnesota Rules of Civil Procedure. The district courts in Martin County and Winona County concluded that Walmart's complaints challenged its property tax assessments and thus were subject to section 278.01, including the time-bar under that statute that requires a property tax challenge to be filed on or before April 30 of the year in which the tax becomes payable, Minn. Stat. § 278.01, subd. 1(c). Because Walmart filed its claims after that date, the district court granted the Counties’ motions and dismissed the complaints.

Walmart appealed both orders. In a consolidated appeal, the court of appeals affirmed. Walmart Inc. v. Winona Cnty. , Nos. A19-1877, 19-1878, 2020 WL 3956251, at *1 (Minn. App. July 13, 2020). The court of appeals agreed with the district courts that Walmart's claims fell within the scope of section 278.01 and were barred by the limitations period for claims under that section. Id. The court of appeals did not reach Walmart's separate argument that chapter 278 does not apply because a taxpayer may bring its equal protection and uniform taxation claims independently of the statutory remedy provided by chapter 278—a possibility left open by our decision in Programmed Land, Inc. v. O'Connor , 633 N.W.2d 517, 529–30 (Minn. 2001). Walmart , 2020 WL 3956251, at *7. Instead, the court of appeals concluded that Walmart failed to plead its constitutional claims sufficiently. Id. We granted Walmart's petition for review.

ANALYSIS

This case comes to us from the court of appeals after the district courts granted the Counties’ motions to dismiss Walmart's complaint for failure to state a claim under Minn. R. of Civ. Proc. 12.02(e). We review a district court's dismissal for failure to state a claim de novo. Bodah v. Lakeville Motor Express, Inc. , 663 N.W.2d 550, 553 (Minn. 2003). A party fails to state a claim under Rule 12.02(e) when its complaint does not "set forth a legally sufficient claim for relief." Id. "We accept factual allegations in the complaint as true and construe all reasonable inferences in favor of the nonmoving party." Walsh v. U.S. Bank, N.A. , 851 N.W.2d 598, 606 (Minn. 2014).

The central question in this case is as follows: Do Walmart's claims that the Counties willfully, intentionally, and unlawfully discriminated against the company in violation of the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution and the Uniformity in Taxation Clause of Article X, section 1, of the Minnesota Constitution fall within the scope of chapter 278, such that Walmart is subject to the limitations period set forth in section 278.01 ? This is a question of law, which we review de novo. See Programmed Land , 633 N.W.2d at 522.

We begin with an overview of the statutory route to challenge a property tax assessment. Chapter 278 provides a mechanism for taxpayers to challenge assessments levied on their properties based on one of five enumerated grounds: (1) the property tax was partially, unfairly, or unequally assessed; (2) the assessed property was overvalued; (3) the property tax is illegal; (4) the taxpayer already paid the tax; or (5) the property is exempt from property tax. See Minn. Stat. § 278.01, subd. 1(a) (2020) ; Programmed Land , 633 N.W.2d at 522 (stating that chapter 278 "provides a cause of action to bring five types of challenges to property taxes"). Critical to this case, a challenge to a tax assessment made under chapter 278 must be filed on or before April 30 of the year in which the tax becomes payable. Minn. Stat. § 278.01, subd. 1(c). Further, a taxpayer's chapter 278 challenge must be limited to a single tax year. Minn. Stat. § 278.02 (2020) ("No petition shall include more than one assessment date."). Walmart filed its complaints, which asserted claims based on the tax assessments levied against the Properties for tax years 2013 through 2018, in May 2019. Because there is no question that Walmart missed the "on or before April 30" filing deadline for the tax years 2013 through 2018, Walmart's claims are untimely if Walmart is held to the limitations period set forth in chapter 278.

We therefore turn to the question of whether Walmart's claim that the Counties violated the company's rights to equal protection and uniform taxation by assessing the Properties differently than other similarly situated properties falls within the scope of one of the five enumerated statutory categories set forth in section 278.01, subdivision 1(a). If a challenge to a property tax assessment is based on one of the five statutory grounds, chapter 278 provides the "exclusive means" for bringing such a challenge. Programmed Land , 633 N.W.2d at 523. But we have also said that section 278.01 "does not provide a cause of action for all possible challenges to property taxes." Id.

In Programmed Land , and later in Odunlade v. City of Minneapolis , 823 N.W.2d 638, 647 (Minn. 2012), we opened the door (albeit in dicta) to the possibility that, if a taxpayer's claim of an unfair or unequal assessment is framed as a violation of constitutional rights, the taxpayer could challenge the assessment independently of the procedures set forth in chapter 278. Importantly, we did not recognize in Programmed Land or Odunlade an independent basis for asserting constitutional claims outside of chapter 278. Rather, we simply declined to answer whether taxpayers "may proceed independently under either [constitutional] theory" because we concluded that the alleged assessment errors at issue in those cases did not violate either constitutional provision. Programmed Land , 633 N.W.2d at 530 ; see Odunlade , 823 N.W.2d at 647 ("We need not, and do not, decide whether chapter 278 precludes [taxpayers’] constitutional claims because we conclude that these claims fail as a matter of law.") Today, we answer that question.

We start our analysis by considering how a taxpayer proves an unfair or unequal assessment claim under section 278.01, subdivision 1(a). A claim of unfair or unequal assessment requires a court to compare the actual market value and tax assessment of the property in question with the actual market value and tax assessment of similarly situated properties. United Nat'l Corp. v. Cnty. of Hennepin , 299 N.W.2d 73, 76 (Minn. 1980) ; see Programmed Land , 633 N.W.2d at 530. If the ratio of the assessed value to the actual market value of the property in question is less than the ratio of the assessed value to the actual market value of other comparable properties in the same taxing district, then a claim of unfair or unequal assessment may be stated. Anacker v. County of Cottonwood , 302 N.W.2d 342, 345 (Minn. 1981). This concept of unfair or unequal assessment mirrors the equal protection test for unfair and unequal taxation set forth by the Supreme Court of the United States: a property owner suffers a violation of the Equal Protection Clause when other owners’ similarly situated properties are assessed at a lower rate, where the difference in taxation is shown by comparing the share of total property taxes assessed in a jurisdiction allocated to the first property relative to the value of the property with the share of total property taxes assessed in a jurisdiction allocated to the similarly situated properties relative to the value of those properties. See Allegheny Pittsburgh Coal Co. v. Cnty. Comm'n of Webster Cnty., W. Va. , 488 U.S. 336, 345–46, 109 S.Ct. 633, 102 L.Ed.2d 688 (1989). In other words, the basic operational test to determine whether an assessment is "unfair or unequal" under section 278.01, subdivision 1(a), and the basic operational test to determine whether an assessment violates the constitutional guarantees of equal protection and uniform taxation are the same.

We have also stated that "a taxpayer will not meet the evidentiary burden of establishing a violation of rights protected under the federal or state constitution , unless he can demonstrate that the disparity about which he complains resulted from the intentional or arbitrary or systematic undervaluation of other properties." United Nat'l Corp. , 299 N.W.2d at 76 (emphasis added). And while we have not found in our decisions "any support for the claim that a dual standard, one constitutional and the other statutory, should be applied" in unfair or unequal assessment cases, we have also never definitively decided that a taxpayer must show intentional, arbitrary, or systematic undervaluation of other properties to prove a chapter 278 claim of unfair and unequal assessment, or whether a simple error by the assessor will suffice. Id. at 77–78 (declining to decide whether, under section 278.01, subdivision 1(a), a taxpayer might establish an unfair or unequal assessment claim by showing that, as a result of simple error rather than intentional, arbitrary, or systematic conduct, the assessment is high as compared with other properties); see Anacker , 302 N.W.2d at 346 (holding that the plaintiff's section 278.01 claims failed because the plaintiff made no showing of unequal assessment or overvaluation).

What is clear, however, is that to the extent that the requisite showing of the taxing authority's intent may differ between the statutory remedy and constitutional claims, the proof required to establish the narrower constitutional claim is properly characterized as a subset of the proof required to establish a broader claim encompassed by section 278.01, subdivision 1(a). Stated another way, the broadest possible test to determine whether the statutory prohibition on unfair or unequal assessments in section 278.01, subdivision 1(a) (including proof that undervaluation of other properties is intentional, arbitrary, systematic, or perhaps simple error), is inclusive of the test for whether an assessment violated a taxpayer's equal protection and uniform taxation rights (including proof that undervaluation of other properties is intentional, arbitrary, or systematic). Accordingly, claims asserting violations of those constitutional rights may be brought under section 278.01, subdivision 1(a).

We return, then, to the central question before us: Does Walmart's claim that the Counties violated the company's equal protection and uniform taxation rights by assessing its Properties differently from other similarly situated properties fall within the scope of the "unfair or unequal" category in section 278.01, subdivisions 1(a) ?

The Counties’ answer to this question is straightforward: Walmart's complaints allege that, for discriminatory reasons, the Counties intentionally assessed properties comparable to Walmart's properties at substantially less than their fair market value while valuing Walmart's properties closer to their fair market value. But once stripped of their constitutional garb, the Counties assert, Walmart's claims are simply that the Counties assessed Walmart's properties unfairly or unequally as compared with other properties. That is one of the grounds for a property tax challenge enumerated in section 278.01, subdivision 1(a), for which chapter 278 provides the exclusive remedy. Consequently, the Counties argue, Walmart's claims fall within the scope of section 278.01, subdivision 1(a), and so Walmart must comply with that section's limitations period.

We agree with the Counties. The plain language of section 278.01, subdivision 1(a), makes no exception for constitutional claims that fall within one of the five categories of claims listed in the statute. See Vill. Lofts at St. Anthony Falls Ass'n v. Hous. Partners III-Lofts, LLC , 937 N.W.2d 430, 435 (Minn. 2020) (stating that we must follow the plain and unambiguous language of a statute); State v. Carson , 902 N.W.2d 441, 446 (Minn. 2017) (rejecting the argument that the Legislature could not have intended what the words of the statute plainly said); Genin v. 1996 Mercury Marquis , 622 N.W.2d 114, 117 (Minn. 2001) (stating that a court cannot add meaning or words to a statute that were intentionally or inadvertently left out).

Further, the statute does not prohibit a taxpayer from bringing an equal protection or uniformity in taxation challenge under chapter 278. As noted above, the test for whether an assessment violates the statutory prohibition on "unfair or unequal assessments" in section 278.01, subdivision 1(a), is the same as or broader than, and therefore inclusive of, the test for whether an assessment violates a taxpayer's equal protection and uniform taxation rights under the federal and state constitutions. Therefore, we hold that if a taxpayer's challenge to its property taxes is a claim of unfair or unequal assessment, or one of the other grounds set forth in section 278.01, subdivision 1(a), chapter 278 provides the exclusive remedy for such a challenge. This is true even if the challenge were framed as a constitutional violation of the Equal Protection Clause or the Uniformity in Taxation Clause. Moreover, we have repeatedly concluded that the Legislature intended the statute to provide the exclusive means to challenge an assessment when the challenge is based on one of the five types listed in section 278.01, subdivision 1(a). See, e.g. , Odunlade , 823 N.W.2d at 644. We have grounded that conclusion on the "purpose and function" of the statute and on the Legislature's use of broad language to describe the types of permitted challenges and the remedies available to the taxpayer who succeeds with a statutory claim. Programmed Land , 633 N.W.2d at 526. We have stated that "when the legislature enacted [chapter 278], it did so for the purpose of providing a rather simple remedy for the taxpayer to have his real estate tax grievances determined." Land O'Lakes Dairy Co. v. Vill. of Sebeka , 225 Minn. 540, 31 N.W.2d 660, 665 (1948). Thus, we have concluded that chapter 278 was enacted to benefit both the taxpayer and the state. See State v. Elam , 250 Minn. 274, 84 N.W.2d 227, 230 (1957) ("[W]e think it is apparent from the express wording of the statute that the act was passed for the benefit of the state as well."). As we noted in Programmed Land ,

[t]he taxpayer benefited because chapter 278 provided a means to object to property taxes without first having to default and then answer in delinquent tax proceedings, and the state benefited because, by providing a cause of action without having to default, chapter 278 limited or prevented tax delinquency and enforced the prompt collection of taxes, ensuring a reliable stream of revenue ....

633 N.W.2d at 525–26.

With these objectives in mind, we have declined to undermine the Legislature's intent "by allowing a significant number of tax grievances to be free of the chapter 278 filing limitation and, consequently, actionable years after the taxes were due." Id. at 526. We have also noted that no right to appeal from an assessment existed at common law; it is a purely statutory right and, accordingly, requires strict compliance. See Ewert v. City of Winthrop , 278 N.W.2d 545, 550 (Minn. 1979) ; Vill. of Edina v. Joseph , 264 Minn. 84, 119 N.W.2d 809, 816 (1962) (explaining that appeals from tax assessments, "their course, and the time and manner in which they are to be allowed and perfected are of statutory origin").

To prevail on its argument that section 278.01, subdivision 1(a), does not provide the exclusive remedy for challenging a tax assessment based on constitutional claims of equal protection and uniformity in taxation, Walmart must demonstrate that the statute excludes such claims from its purview. But Walmart points to nothing in the plain language of the statute that makes an exception for claims asserting equal protection and uniformity in taxation challenges to assessments. Rather, Walmart asserts that the standard for a constitutional claim differs substantively from the standard for a statutory claim. Walmart also urges that the Tax Court lacks the jurisdiction to resolve constitutional claims and contends that, in any event, chapter 278 does not provide an adequate remedy for constitutional claims because the truncated limitations period hampers the taxpayer's ability to muster the necessary evidence. We now turn to those arguments.

Walmart first argues that an independent remedy for equal protection and uniformity in taxation violations is appropriate because the standard for proving that a property tax assessment violates either of these constitutional provisions is different from the standard for proving a statutory violation under section 278.01, subdivision 1(a). In particular, Walmart argues that a constitutional violation requires a showing of intentional, arbitrary, or systematic discrimination while a claim under chapter 278 does not. As discussed above, Minnesota law is unclear on that point. See United Nat'l Corp. , 299 N.W.2d at 77–78. But aside from a possible difference between the required mental state for constitutional and statutory claims, the operational test is the same. See id. at 76. Most importantly, even if the required mental states are different, the dispositive question is not whether section 278.01 requires intentional, arbitrary, or systematic discrimination. The relevant question is the inverse: Does section 278.01, subdivision 1(a), allow a taxpayer to bring such a claim that is the result of intentional, arbitrary, or systematic discrimination? The answer to that question is plainly "Yes."

Once again, nothing in chapter 278 prevents a taxpayer from challenging an assessment as unfair or unequal simply because the government acted intentionally, arbitrarily, or systematically in imposing the tax. Further, the remedies that Walmart seeks in its complaints—a reduction in the assessed value of its Properties and a return of its alleged overpayments made from 2013 through 2018—are the same remedies that Walmart would receive had it prevailed in a challenge brought under chapter 278 asserting that an assessment was unfair or unequal.

Next, Walmart argues that the Legislature could not have meant for constitutional claims to be addressed under chapter 278 because section 278.01, subdivision 1(a), permits a taxpayer to seek relief before a tax court. To support its argument, Walmart cites Erie Mining Co. v. Commissioner of Revenue , 343 N.W.2d 261, 264 (Minn. 1984), and Wilson v. Commissioner of Revenue , 619 N.W.2d 194, 199 (Minn. 2000), and points out that the tax court, as an arm of the executive branch, lacks original jurisdiction to decide constitutional challenges to property taxes brought initially in the tax court. It makes no sense, Walmart asserts, for the Legislature to create a procedure to resolve a taxpayer's constitutional claims while also permitting such claims to be brought in a forum with no power to address those claims.

But Walmart's argument ignores the plain language of chapter 278. Although the statute permits taxpayers to bring their claims in tax court, it also provides taxpayers with the option of proceeding in district court, which has jurisdiction to decide constitutional questions. See Minn. Stat. § 278.01, subd. 1(a). In addition, even if Walmart's claims were brought initially in the tax court, we have adopted a process by which the tax court could acquire jurisdiction over Walmart's constitutional challenges.

All tax matters over which the tax court has jurisdiction should be filed with the tax court. If any party raises a constitutional issue, the tax court should stay the proceedings and refer the constitutional question to the district court. The district court may either decide the constitutional issue or refer the matter back to the tax court which will then have subject matter jurisdiction to rule initially on the constitutional issue. If the tax court should declare any matter unconstitutional and no appeal is taken to this court, that ruling shall only be the law of the particular case involved.

Erie Mining Co. , 343 N.W.2d at 264. Consequently, the alleged statutory inconsistency that Walmart identifies is easily reconcilable and provides no basis for discerning a legislative intent to allow constitutional claims to be asserted independently of chapter 278. Finally, Walmart argues that chapter 278 does not provide an adequate remedy to address its equal protection and uniformity in taxation claims because it may take a taxpayer longer than 1 year to perceive that a county assessor is intentionally discriminating by assessing the taxpayer's property at a higher rate than comparable properties and to gather the evidence to support such a claim. Therefore, Walmart argues, we should construe section 278.01 to exclude equal protection and uniformity in taxation claims to avoid unconstitutionally hobbling a taxpayer's ability to vindicate those constitutional rights with a tightly truncated limitations period. See State v. Irby , 848 N.W.2d 515, 521–22 (Minn. 2014) (discussing the doctrine of constitutional avoidance). We disagree.

The language of section 278.01, subdivision 1(a), is clear. It makes no exceptions for constitutional claims that fall within one of the five categories of property tax challenges set forth in the statute. Minn. Stat. § 278.01, subd. 1(a) ; see Irby , 848 N.W.2d at 521–22 (stating that the constitutional avoidance doctrine applies only after the statute is found to be ambiguous). In conclusion, chapter 278 is the exclusive process for Walmart to challenge the Counties’ assessment of its Properties for violating Walmart's constitutional rights to equal protection and uniformity in taxation under the federal and state constitutions. Because these claims were not brought within the time limitations set forth in section 278.01, subdivision 1(c), Walmart's claims are time-barred.

CONCLUSION

For the foregoing reasons, the decision of the court of appeals is affirmed.

Affirmed.

ANDERSON, J., took no part in the consideration or decision of this case.