Justia Minnesota Supreme Court Opinion Summaries

Police officers investigated suspected fentanyl sales at an apartment in East Grand Forks, Minnesota, in 2022. After surveillance and a search warrant, they found Mohamed Abdulgani Ahmed at the apartment, arrested him, and discovered 775 fentanyl pills, cash, and Ahmed’s wallet in the bedroom closet. Forensic analysis confirmed the pills contained fentanyl weighing approximately 77.5 grams. Ahmed admitted to selling some fentanyl pills but denied knowledge of the large bag of pills. Text messages from Ahmed’s phone indicated involvement in fentanyl sales with his roommate, A.F., and others. Ahmed was charged with conspiracy to commit first-degree sale of controlled substances, first-degree sale, and second-degree possession of controlled substances.The District Court for Polk County entered convictions for all three counts after a jury trial. Ahmed appealed, arguing errors in the prosecution’s closing argument and other issues. The Minnesota Court of Appeals affirmed the convictions for conspiracy and sale but reversed and remanded for the district court to vacate the conviction for second-degree possession, as it was a lesser-included offense under Minnesota law.The Supreme Court of Minnesota reviewed whether the prosecutor’s statement—that the State need not prove Ahmed knew the conspiracy involved more than fifty grams of fentanyl—was plain error. The court held that, under Minnesota Statutes section 152.096 and its prior decision in State v. Kuhnau, the State must prove the defendant intended the commission of every element of the underlying offense, including the statutory weight threshold. The prosecutor’s misstatement was plain error affecting Ahmed’s substantial rights and was prejudicial. The Supreme Court reversed in part, vacated in part, and remanded for a new trial on all three challenged counts. View "State of Minnesota vs. Ahmed" on Justia Law

A 16-year-old girl disclosed to her high school advisor that her stepfather had sexually abused her, prompting a police investigation. The accused was charged with first-degree criminal sexual conduct, based on allegations that he committed multiple acts of sexual penetration against his minor stepdaughter over a period of about two years, beginning when she was around nine years old. The complainant described several acts of abuse, including cunnilingus and fellatio, occurring on different occasions and in different locations. Other family members and professionals testified about her disclosures and related observations. The defendant denied the allegations, and his defense emphasized inconsistencies in the complainant’s account and testimony from other relatives.After a jury trial, the Hennepin County District Court found the defendant guilty of both first- and second-degree criminal sexual conduct, entering judgment on the first-degree charge and sentencing him to 144 months in prison. The defendant appealed to the Minnesota Court of Appeals, arguing that the district court’s failure to provide a jury instruction requiring specific unanimity—that is, requiring jurors to agree on which specific act constituted the charged offense—constituted plain error. The Court of Appeals affirmed the conviction, relying in part on its prior decision in State v. Rucker, which held that a specific-unanimity instruction was not required under similar circumstances.The Supreme Court of Minnesota reviewed the case and held that, under its recent decision in State v. Keyes, when a single count is charged but the evidence involves multiple distinct acts, each capable of independently satisfying the statutory elements, a specific-unanimity jury instruction is required. The Court concluded that the district court’s failure to provide such an instruction was plain error that affected the defendant’s substantial rights. The Supreme Court of Minnesota reversed the first-degree conviction and remanded for a new trial on that charge. View "State of Minnesota vs. Yang" on Justia Law

A police officer with 25 years of service sought workers’ compensation benefits after being diagnosed with post-traumatic stress disorder (PTSD). The officer had experienced numerous traumatic events during his career and began psychological treatment in 2021. He was diagnosed with PTSD by a licensed psychologist, who relied on the DSM-5 for the diagnosis. The City, disputing the claim, had its own psychologist conduct an independent psychological evaluation (IPE) using the same DSM edition, who concluded that the officer did not meet the criteria for PTSD but instead had alcohol abuse disorder. Subsequently, the officer’s psychologist conducted a follow-up evaluation using the updated DSM-5-TR, issuing a “lifetime” PTSD diagnosis.A compensation judge found the officer entitled to a statutory presumption that his PTSD was work-related but determined that the City had rebutted this presumption, relying on the City’s expert’s opinion despite it being based on the earlier DSM-5. The judge found the City’s expert more persuasive and denied the officer’s claim for benefits.The Workers’ Compensation Court of Appeals (WCCA) vacated the compensation judge’s order, holding that the City’s expert opinion could not be considered because it was not based on the most recently published DSM edition. The WCCA ruled that only an IPE using the most recent DSM edition could rebut the statutory presumption and made its own finding that the City failed to rebut the presumption.The Minnesota Supreme Court reviewed the case. It held that the most recently published edition of the DSM includes text revisions, but an IPE is not the only way to rebut the statutory presumption. The Court also held that a compensation judge is not barred from considering an IPE based on an outdated DSM edition. The Supreme Court reversed the WCCA’s decision and remanded for consideration of additional arguments not previously addressed. View "Rowe vs. City of Minneapolis" on Justia Law

A homeowner hired a general contractor to perform a remodeling project, which included electrical work provided by a subcontractor. During construction, a fire occurred at the home, allegedly due to improper electrical work by both the general contractor and the subcontractor. The homeowner’s insurer paid for the fire damage and, acting as subrogee, brought a negligence and breach of contract action against both contractors. After the fire, the homeowner discontinued the services of both contractors and later hired a new general contractor to complete the project.The Minnesota District Court granted summary judgment in favor of the contractors, dismissing the insurer’s claims as time-barred under the two-year statute of limitations for defective construction claims involving improvements to real property, as set out in Minn. Stat. § 541.051, subd. 1. The district court found that the statute of limitations began to run when the homeowner terminated the contract with the original general contractor, concluding that the action was not timely filed.On appeal, the Minnesota Court of Appeals reversed the district court's decision. The appellate court interpreted the statute to mean that the statute of limitations does not begin until the entire construction project is terminated, substantially completed, or abandoned, not merely upon termination of the contract with the general contractor.The Supreme Court of Minnesota reviewed the case to resolve the statutory interpretation issue. The court held that, for purposes of the statute of limitations under Minn. Stat. § 541.051, subd. 1, the termination of the contract with the general contractor constitutes “termination … of the construction or the improvement to real property.” As a result, the Supreme Court reversed the Court of Appeals and reinstated the district court’s dismissal of the insurer’s claims as time-barred. View "American Family Insurance Company vs. NB Electric, Inc." on Justia Law

In 2016, Tyrel Patterson and three accomplices participated in a burglary and robbery that resulted in the death of James Herron. Patterson was indicted on two counts of first-degree felony murder and ultimately pleaded guilty to one count under an aiding and abetting theory. He admitted to planning and executing the robbery, being armed, and robbing a resident, but maintained he was outside the house when Herron was fatally shot. He was sentenced to life in prison with the possibility of release after 30 years.Years later, Patterson petitioned the Scott County District Court to vacate his conviction under a new Minnesota law (the Act) that provides relief for certain felony murder convictions based on aiding and abetting, if the defendant did not cause the death or intentionally aid with the intent to cause death. The district court initially found a reasonable probability that Patterson could be entitled to relief, but ultimately denied his petition without holding an evidentiary hearing. The court relied on transcripts and findings from the trial of a co-defendant, concluding that Patterson caused Herron’s death.The Supreme Court of Minnesota reviewed the district court’s denial for abuse of discretion. It held that the district court erred by making credibility determinations without first holding an evidentiary hearing, as required by precedent and the Act’s procedural framework. The court reversed the district court’s decision and remanded the case for an evidentiary hearing to properly resolve disputed material facts and assess the credibility of the parties. The main holding is that a district court cannot make credibility determinations in proceedings under the Act without first conducting an evidentiary hearing. View "Patterson vs. State of Minnesota" on Justia Law

The case concerns a defendant who was charged with several offenses, including first-degree criminal sexual conduct, after an incident in which his former intimate partner, S.B., alleged that he committed two distinct acts of nonconsensual sexual penetration—one in a bedroom and one in a living room—during a violent episode. After the incident, S.B. reported the events to police, and the defendant was arrested at her home. Physical evidence supported S.B.’s account. The case proceeded to trial, where the primary dispute was whether the sexual assaults occurred as alleged.At trial in the Minnesota District Court, the defendant requested a specific-unanimity jury instruction, which would have required jurors to unanimously agree on which distinct act of sexual penetration satisfied the elements of the charged offense. The district court denied this request and instead gave a general-unanimity instruction. The jury found the defendant guilty on all counts, and he was sentenced to 360 months in prison. The defendant appealed to the Minnesota Court of Appeals, arguing that the failure to give a specific-unanimity instruction violated his right to a unanimous verdict. The Court of Appeals affirmed the convictions, concluding that the defendant had not properly preserved the issue and that the instruction was not required because the acts occurred as part of a single behavioral incident.The Supreme Court of Minnesota reviewed the case. The court held that when the State charges one count of criminal conduct but presents evidence of more than one distinct act, each of which on its own could prove the elements of the charged offense, a defendant is entitled to a specific-unanimity instruction. The district court abused its discretion in declining to give such an instruction. Further, the error was not harmless beyond a reasonable doubt because it was reasonably likely that jurors disagreed about which act constituted the offense. The Supreme Court of Minnesota reversed the convictions for first-degree criminal sexual conduct and remanded for a new trial. View "State of Minnesota vs. Keyes" on Justia Law

The case centers on a defendant who was charged with two counts of third-degree criminal sexual conduct after allegations that he forced a vulnerable adult to engage in oral sex. Shortly before trial, the defendant indicated he would assert an intoxication defense. On the day of trial, the parties reached a plea agreement: the defendant entered a Norgaard guilty plea to an amended charge of fifth-degree criminal sexual conduct, which allows a defendant to plead guilty despite having no memory of the incident, in exchange for dismissal of the remaining charge. During the plea hearing, the defendant confirmed he had reviewed the State’s evidence with his attorney, could not recall the events, and acknowledged a substantial likelihood that a jury would find him guilty. The district court accepted the plea and imposed a sentence, which was stayed on the condition of probation.The Minnesota Court of Appeals subsequently reviewed the defendant’s challenge to the validity of his plea. The appellate court found that the plea lacked an adequate factual basis, since the State had not described, on the record, the evidence it would present at trial to establish guilt. The Court of Appeals reversed the conviction and remanded with instructions to allow the defendant to withdraw his plea.The Supreme Court of Minnesota affirmed the appellate court’s decision. It held that, like an Alford plea, a Norgaard plea must be supported by a strong factual basis—specifically, a description of the State’s evidence sufficient to allow the district court to independently conclude there is a strong probability the defendant is guilty of the charge. Because the State had not described the evidence it would present at trial, the plea was not constitutionally valid. The disposition by the Supreme Court of Minnesota was to affirm the reversal and remand. View "State of Minnesota vs. Steichen" on Justia Law

The case arose when a property owner initiated an eviction action against a tenant. The parties resolved the matter through a court-approved settlement, under which the tenant agreed to vacate the apartment by a specified date. The tenant complied with the settlement terms. Several months later, the tenant moved for expungement of the eviction record, relying on a recently amended Minnesota statute providing that courts must expunge eviction files if the case is settled and the defendant fulfills the terms of the settlement.A housing court referee recommended expungement pursuant to that statute, and the district court signed the expungement order. The property owner, Sela Investments, appealed to the Minnesota Court of Appeals, arguing that the statutory expungement provision was unconstitutional. The Court of Appeals agreed, holding that the statute was a facial violation of the separation of powers because it infringed on the judiciary’s inherent authority to manage its own records. The appellate court reversed the expungement and remanded for the district court to apply a discretionary balancing test instead.On review, the Supreme Court of Minnesota first considered whether Sela Investments had standing to challenge the constitutionality of the statute. The court held that to have standing for a constitutional challenge, a party must show the statute has disadvantaged or is about to disadvantage its legal interest or right. The Supreme Court found that Sela Investments had not been harmed by the expungement statute, as it retained its own knowledge of the tenant and did not lose any legal right or interest.Because Sela Investments lacked standing, the Supreme Court held that neither it nor the Court of Appeals had jurisdiction to adjudicate the constitutional claim. The Supreme Court therefore vacated the decision of the Court of Appeals. View "Sela Investments, Ltd LLP vs. J.H." on Justia Law

A patrol officer with the Anoka Police Department completed a 12-hour shift during which he responded to multiple calls, including emergency situations such as a domestic dispute involving a report of a child with a knife. The following day, the officer died from a vascular rupture. His widow applied for state line-of-duty death benefits, submitting medical evidence that the stressful nature of police work contributed to his fatal condition. While her application for federal death benefits was approved, the Commissioner of Public Safety denied her application for Minnesota death benefits, concluding the officer’s death did not meet the statutory criteria for being “killed in the line of duty.”After the Commissioner’s denial, the widow appealed to the Office of Administrative Hearings, where the Administrative Law Judge (ALJ) granted summary disposition in favor of the Commissioner. The ALJ found that the officer’s final shift did not involve “nonroutine stressful or strenuous physical law enforcement activity” as required by statute. The Minnesota Court of Appeals reversed, holding that there was a genuine issue of material fact regarding whether the officer engaged in such nonroutine activity during his last shift. The court also concluded that the definition of “killed in the line of duty” from prior Minnesota Supreme Court cases did not apply to deaths specifically addressed by the legislature in the statute.The Supreme Court of Minnesota reviewed the case and clarified the statutory presumption for certain heart-related deaths. The Court held that an emergency response is presumptively “nonroutine” under the statute, regardless of how frequently it occurs or how it is characterized by the agency. It also determined that the phrase “nonroutine stressful or strenuous physical” modifies all activities listed in the statute. Additionally, the Court held that if the statutory presumption does not apply or is rebutted, the officer’s estate may still prove line-of-duty death under the legal standard set forth in Kramer v. State, Peace Officers Benefit Fund, and Johnson v. City of Plainview. The decision of the Court of Appeals was affirmed in part and reversed in part. View "In re Public Safety Officer Death Benefit for Groebner" on Justia Law

The case concerns PASCP Inc., a retail liquor store, which was audited by the Minnesota Commissioner of Revenue for sales and use taxes covering January 2015 through June 2020. During the audit, PASCP failed to provide sufficient and accurate sales records, supplying only incomplete documentation for a limited period. As a result, the Commissioner conducted an indirect audit using 2019 as a representative sample year, reconstructing sales based on vendor purchase records and PASCP’s retail price list. This method revealed that PASCP had significantly underreported taxable sales. Consequently, the Commissioner extended the statute of limitations for assessment from 3½ years to 6½ years, imposed additional taxes, and applied a 10 percent negligence penalty.After the Commissioner issued a Tax Order assessing the additional tax, penalties, and interest, PASCP administratively appealed, contesting both the audit methodology and the extension of the statute of limitations. The Commissioner affirmed the Tax Order upon review, and PASCP then appealed to the Minnesota Tax Court. The Tax Court granted summary judgment for the Commissioner, finding that there were no disputed material facts. The court determined that PASCP’s failure to maintain records justified the use of indirect audit methods, supported the extension of the statute of limitations under Minn. Stat. § 289A.38, subd. 6, and warranted the imposition of the negligence penalty under Minn. Stat. § 289A.60, subd. 5.The Supreme Court of Minnesota reviewed the case. It held that the Tax Court did not err in concluding that the Commissioner properly extended the statute of limitations to 6½ years due to PASCP’s underreporting of more than 25 percent of its tax liability. The Supreme Court further held that the negligence penalty was appropriate because PASCP admitted to not keeping required records, which constitutes a failure to meet the standard of a reasonably prudent taxpayer. The Supreme Court affirmed the Tax Court’s decision. View "PASCP Inc. v. Commissioner of Revenue" on Justia Law