Justia Minnesota Supreme Court Opinion Summaries

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Minn. Stat. 554.02, a section of Minnesota’s anti-SLAPP law, is unconstitutional as applied to claims at law alleging torts. Petitioners sued Asian Women United of Minnesota (AWUM), a nonprofit organization, seeking to recover under a number of legal theories of injuries allegedly inflicted by AWUM through four previous lawsuits. AWUM moved for dismissal under Minnesota’s anti-SLAPP law. Minn. Stat. 554.01-.06. The district court dismissed all of Petitioners’ claims with the exception of their claim for malicious prosecution. The district court concluded that Minn. Stat. 554.02 - the section of the law that governs motions “to dispose of a judicial claim” - violated Petitioners’ right to a jury trial by requiring the trial judge to find facts. As a result, the district court denied AWUM’s motion to dismiss. The Supreme Court affirmed, holding that section 554.02 is unconstitutional when it requires a district court to make a pretrial finding that speech or conduct is not tortious under Minn. Stat. 554.03, as was the case here. View "Leiendecker v. Asian Women United of Minnesota" on Justia Law
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Defendant was found guilty of possession of a firearm by an ineligible person. The court of appeals reversed, concluding that the evidence was insufficient to support the conviction. The State petitioned for review, arguing that the court of appeals erred in its application of law and asking the Supreme Court to abandon the separate standard of review for convictions based on circumstantial evidence. The Supreme Court affirmed, holding (1) the court of appeals correctly applied the law and properly found that the State presented insufficient evidence to support Defendant’s conviction; and (2) the State has not established a compelling reason for the court to overrule an approximately century-old rule governing the review of convictions based on circumstantial evidence. View "State v. Harris" on Justia Law
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Appellant was convicted of first-degree murder committed for the benefit of a gang. The Supreme Court affirmed. The day before the postconviction statute of limitations expired, Appellant filed his second petition for postconviction relief and, over the next six months, filed various addenda and attachments to his second petition. Appellant also filed a third petition raising additional claims and filed a motion requesting re-testing of certain trial evidence. Without holding an evidentiary hearing, the postconviction court denied both petitions and Appellant’s other requests, determining that his claims were untimely filed or procedurally barred, or failed on the merits. The Supreme Court affirmed, holding that each of the claims Appellant raised in his second and third petitions for postconviction relief, as well as the claims raised in the addenda to the second petition, failed. View "Brown v. State" on Justia Law
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Appellant, a juvenile offender, challenged the district court’s imposition of three consecutive sentences of life imprisonment with the possibility of release after thirty years on each sentence for his three murder convictions. Appellant argued, among other things, that the rule announced in Miller v. Alabama and clarified in Montgomery v. Louisiana should apply to his case because his consecutive sentences were, in the aggregate, the functional equivalent of life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) this court declines to extend the Miller/Montgomery to include Appellant or other similarly situated offenders because the United States Supreme Court has not squarely addressed the issue of whether consecutive sentences should be viewed separately when conducting a proportionality analysis; and (2) Appellant’s three consecutive sentences do no unfairly exaggerate the criminality of his conduct. View "State v. Ali" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for first-degree felony murder rendered after a jury trial. The district court sentenced Defendant to life imprisonment with the possibility of release after thirty years. Specifically, the Court held (1) the State presented sufficient evidence to prove beyond a reasonable doubt that the killing of the victim occurred while Defendant was attempting to commit an aggravated robbery; and (2) the district court did not commit plain error by failing to include language requiring a causal relationship between the killing and the attempted robbery in the jury instruction on first-degree felony murder. View "State v. Webster" on Justia Law
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Based on the plain language of Minn. Stat. 176.101, subd. 1(i), the Supreme Court held that an offer to return to work with the same employer is not “consistent with” an employee’s rehabilitation plan stating that the employee’s vocational goal is to return to work with a different employer in the same industry. The Court affirmed the decision of the Workers’ Compensation Court of Appeals that reversed the compensation judge’s decision to discontinue temporary total disability (TTD) compensation to the employee at issue in this case, holding that the employer was not entitled to discontinue TTD benefits because its job offer was not consistent with the employee’s plan of rehabilitation. View "Gilbertson v. Williams Dingmann, LLC" on Justia Law

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This tax dispute arose out of a failed real estate investment that resulted in significant tax consequences for Germaine Harmon, the widow of one of the original investors. Harmon challenged the Commissioner of Revenue’s assessment of her 2010 Minnesota income-tax liability, which the Commissioner based on a Schedule K-1 filed by the partnership in charge of the foreclosed real estate investment. The Supreme Court affirmed the tax court’s grant of summary judgment in favor of the Commissioner, holding that the tax court did not err by determining that Harmon failed to overcome the presumption of validity of the Commissioner’s assessment of taxes. View "Harmon v. Commissioner of Revenue" on Justia Law

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In 2015, Appellant was charged with two counts of first-degree driving while impaired (DWI). Appellant contested the use of his 1998 conviction for criminal vehicular operation resulting in substantial bodily harm to enhance his 2015 DWI charge to a first-degree offense. The district court found sufficient probable cause for enhancement. Thereafter, Appellant pleaded guilty to one count of first-degree driving while impaired. Appellant appealed, arguing that he was entitled to withdraw his plea because his 1998 conviction was not included in the list of predicate felonies in Minn. Stat. 169A.24 that enhance a DWI charge to a first-degree DWI. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a criminal vehicular operation conviction from a year not specifically listed in the current version of the first-degree DWI statute can be used to enhance a DWI charge to a first-degree offense; and (2) accordingly, Appellant’s plea was established with an accurate factual basis. View "State v. Boecker" on Justia Law
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After a bench trial, Appellant was convicted of three counts of first-degree premeditated murder. The Supreme Court affirmed on direct appeal. Appellant then filed a pro se petition for postconviction relief, arguing that he was entitled to a new trial based on newly discovered evidence in the form of affidavits signed by five alibi witnesses. Appellant also claimed ineffective assistance of trial counsel and appellate counsel. The postconviction court summarily denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by summarily denying Appellant’s request for a new trial based on newly discovered evidence and based on Appellant’s claim that both his trial counsel and appellate counsel provided ineffective assistance. View "State v. Mosley" on Justia Law
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In 1999, Yik Lo created H.K.D. Lo, Inc. Yik and his wife, Yau Lo, operated several restaurants through H.K.D., the last of which they sold in 2005. In approximately 2004, Yik and Yau’s son, Kee Lo, opened a restaurant called Jun Bo that Kee operated through H.K.D. In 2011, Yik and Yau formally dissolved H.K.D. In 2012, the Commissioner of Revenue assessed Yik personally liable for sales taxes owed by H.K.D. in the amount of $91,019. Yik appealed. The tax court concluded that Yik was not personally liable for H.K.D.’s unpaid tax debt because Yik was not a person who had “control of, supervision of, or responsibility for” filing H.K.D.’s tax returns or paying H.K.D.’s taxes. The Supreme Court reversed, holding that because Yik funded H.K.D., signed checks on its behalf, had a fifty percent stake in the company, and delegated day-to-day control of the business to someone else, Yik had control over H.K.D.’s tax obligations, despite the fact that Kee demanded and exercised authority over Jun Bo’s daily operations. View "Lo v. Commissioner of Revenue" on Justia Law
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