Justia Minnesota Supreme Court Opinion Summaries

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After Appellant pleaded guilty to third-degree criminal sexual conduct, removal proceedings were initiated against him. In an attempt to avoid deportation, Appellant filed an emergency motion to withdraw his guilty plea, arguing, inter alia, that he received ineffective assistance of counsel because counsel failed accurately to inform him that his plea would lead to his removal from the United States. Specifically, Appellant argued that Padilla v. Kentucky required his attorney to advise him that the plea would result in his deportation, rather than just the deportation was a possibility. The postconviction court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding that Padilla did not require Appellant’s counsel to do anything more than provide a general warning about the immigration consequences of entering the plea, and therefore, Appellant’s counsel satisfied his obligation under the Sixth Amendment. View "Sanchez v. State" on Justia Law

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Defendant was arrested and charged with drug-related crimes. The district court ordered Defendant’s pretrial release. The district court later found probable cause that Defendant had violated the conditions of her release and issued a warrant for her arrest. Officers then went to the residence of Defendant’s boyfriend. One officer opened an unlocked door, went inside, and arrested Defendant. While arresting her, the officer saw marijuana and a bong in plain view. Law enforcement then obtained a search warrant for the apartment of Defendant’s boyfriend. The state subsequently charged Defendant with two counts of fifth-degree possession of a controlled substance and possession of drug paraphernalia. The district court suppressed all fruits of Defendant’s arrest and dismissed the charges, concluding that the arrest was illegal because the warrant for Defendant's arrest did not authorize police to enter her boyfriend’s apartment. The court of appeals reversed. The Supreme Court affirmed, holding that neither the Fourth Amendment of the U.S. Constitution nor Article I, Section 10 of the Minnesota Constitution requires police to obtain a search warrant before entering a home to arrest a guest who is the subject of a lawfully issued arrest warrant. View "State v. deLottinville" on Justia Law

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Plaintiff sued Defendants, health care providers, alleging professional negligence. Defendants filed a motion to compel authorization of an informal discussion with the surgeon who performed the Plaintiff’s surgery. The surgeon was not named as a defendant. Upon Plaintiff’s motion, the district court issued a protective order requiring Plaintiff to authorize the surgeon to participate in the informal discussion but restricting Defendants’ questioning of the surgeon to his own treatment of Plaintiff. Defendants filed an interlocutory appeal. Meanwhile, the parties and the surgeon participated in an informal discussion. While the interlocutory appeal was pending, the case was tried to a jury. The district court allowed the surgeon to opine on matters other than his own treatment of Plaintiff. The jury found in favor of Defendants. Thereafter, the court of appeals proceeded to decide the interlocutory appeal and reversed the district court’s protective order, concluding that Defendants were allowed to ask the surgeon about Defendants’ care of Plaintiff and the cause of her injury. The Supreme Court vacated the court of appeals’ opinion, holding that the court of appeals lacked appellate jurisdiction over the interlocutory order. View "Howard v. Svoboda" on Justia Law

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Respondent received a head injury during the course of her employment. Respondent filed a request with the workers’ compensation division seeking coverage for various treatments she was receiving for her injuries, including treatment for emotional and psychological conditions that allegedly developed from her injury. The compensation judge denied Respondent’s request for coverage of emotional and psychological conditions, finding that Respondent had not suffered a concussion and post-concussive syndrome. The compensation judge relied heavily on the opinion of a certain psychologist. The WCCA reversed and vacated the denial of coverage of the emotional and psychological conditions, concluding that there was not an adequate factual foundation for the psychologist’s opinion. The Supreme Court reversed, holding (1) the WCCA erred when it raised and ruled on the forfeited issue of whether a psychologist was competent to provide an expert opinion; (2) the WCCA erred when it reversed the compensation judge’s decision based primarily on the psychologist’s report; and (3) the WCCA erred when it reversed the compensation judge’s finding that Respondent did not suffer a concussion and post-concussive syndrome. View "Gianotti v. Independent School District 152" on Justia Law

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After the Supreme Court overturned Petitioner’s first conviction on direct appeal, Petitioner was tried a second time and convicted of first-degree murder while committing or attempting to commit a kidnapping. Petitioner was sentenced to life in prison without the possibility of release. The Supreme Court affirmed. This appeal concerned Petitioner’s third petition for postconviction relief in which Petitioner raised a variety of claims. The postconviction court summarily denied the claims as either meritless or untimely filed. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in summarily denying the petition, as one of Petitioner’s claims was meritless and the remaining claims were untimely filed. View "Hannon v. State" on Justia Law
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Defendant was convicted of first-degree premeditated murder and sentenced to life in prison without the possibility of release. The court concluded that the district court did not commit plain error in admitting evidence of defendant's post-arrest, pre-Miranda silence during the State's case-in-chief; any error by the district court in permitting the State to discuss defendant's post-arrest, pre-Miranda silence in closing argument was harmless; and the district court did not abuse its discretion in denying defendant's request to give a jury instruction on defense of dwelling. Accordingly, the court affirmed the judgment. View "State of Minnesota v. Lilienthal" on Justia Law
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Madison Equities, Inc. brought an action against Robert Crockarell for repayment of an overdue promissory note. Crockarell filed a separate action against Madison Equities and others alleging that Madison Equities filed suit against Crockarell on the note to interfere with Crockarell’s business interests. The district court granted summary judgment to Madison Equities on the promissory note claim but ordered a stay of entry of judgment pending meditation in Crockarell’s business-related action. Madison Equities petitioned the court of appeals for a writ of mandamus to compel the district court to vacate the stay. The court of appeals denied the petition. The Supreme Court reversed and issued a writ of mandamus ordering the district court to vacate the stay, holding that Madison Equities was entitled to the writ where the district court did not have authority to order the stay, Madison Equities suffer a public harm that was specifically injurious to it, and Madison Equities did not have any other adequate remedy in the ordinary course of law. View "Madison Equities, Inc. v. Crockarell" on Justia Law
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Defendant was convicted of a petty misdemeanor for violating Lester Prairie Municipal Code section 5.5.1.2, which prohibits certain blight conditions on residents’ property, including the open storage of unregistered or inoperative motor vehicles. The court of appeals reversed, concluding that the ordinance was ambiguous and resolving the ambiguity in favor of Defendant. The Supreme Court reversed, holding (1) the unambiguous language of the ordinance prohibits a person from keeping a junked or abandoned vehicle or other scrap metal on her property for longer than thirty days without a special use permit; and (2) there was sufficient evidence to prove that Defendant violated the ordinance by keeping an abandoned vehicle on her property for longer than thirty days without a special use permit. View "State v. Vasko" on Justia Law
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American Family Insurance Company (American Family) issued automobile insurance policies to policyholders that were later injured in automobile accidents. The policy contained an anti-assignment clause, but, in order to obtain medical treatment, the policyholders assigned their interests in basic economic loss benefits to their medical provider, Stand Up Multipositional Advantage MRI, P.A. (Stand Up). Stand Up filed suit against the policyholders, their attorneys, and American Family for failing to make payment directly to Stand Up in accordance with the assignments. The district court granted summary judgment for the defendants, concluding that the anti-assignment clause was unenforceable, and therefore, the assignments to Stand Up were valid. The court of appeals reversed. The Supreme Court affirmed, holding that the anti-assignment clause was valid and precluded the assignments the policyholders made to Stand Up. View "Stand Up Multipositional Advantage MRI, P.A. v. American Family Insurance Co." on Justia Law

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John David Emerson was arrested and charged with second-degree assault with a dangerous weapon. Upon Emerson’s motion, the district court issued an order restraining the Dakota County Sheriff from collecting Emerson’s DNA for law enforcement identification purposes. The Sheriff filed a petition for a writ of prohibition asking the court of appeals to prohibit the district court from enforcing its order against the Sheriff, arguing that the district court lacked subject matter jurisdiction to hear and decide Emerson’s motion. The court of appeals denied the motion. The Supreme Court reversed, holding (1) the district court had subject matter jurisdiction but exceeded its lawful authority when it used the wrong procedure to address Emerson’s constitutional challenge the DNA-collection statute; and (2) the Sheriff met all three elements for a writ of prohibition. View "In re Leslie, Dakota County Sheriff" on Justia Law
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