Justia Minnesota Supreme Court Opinion Summaries

Angeline and Frank Brozovich appealed a tax order issued by the Commissioner of Revenue, which assessed them $10,864.58 in unpaid individual income tax, penalties, and interest for tax years 2019 and 2020. The assessment was based on the finding that the Brozoviches improperly deducted over $105,000 in losses related to their residential real estate in Bainbridge Island, Washington. The primary issue was whether Angeline qualified as a “real estate professional” under Internal Revenue Code § 469(c)(7)(B) for those tax years.The Minnesota Tax Court held a trial and determined that Angeline did not qualify as a real estate professional because she failed to submit credible evidence that she met the minimum requirement of 750 hours or more on qualifying services in support of renting the Bainbridge Island Property during the years at issue. The tax court also found that other deductions claimed by the Brozoviches, including those related to renting the property to their son, credit card interest payments, and a lawncare payment, were improperly claimed.The Minnesota Supreme Court reviewed the case and affirmed the tax court’s decision. The court held that the tax court had jurisdiction to decide cases arising under Minnesota tax law that incorporate federal tax law. It also held that the tax court did not err in determining that Angeline was not a real estate professional and that some of the claimed deductions were unsupported by the evidence offered. The court found no clear error in the tax court’s factual findings and concluded that the tax court’s decision was supported by the evidence as a whole. View "Brozovich v. Commissioner of Revenue" on Justia Law

The case involves two petitions for a writ of quo warranto filed against certain members of the Minnesota House of Representatives. The petitions claim that at the start of the legislative session on January 14, 2025, the House did not have a quorum to transact business. Secretary of State Steve Simon, who has statutory responsibilities in the House at the start of the legislative session, brought one petition. Representatives Melissa Hortman, Jamie Long, and Athena Hollins brought the other petition. The issue arose because, following a district court ruling that a DFL member did not meet the residency requirement, the House had 67 members from each of the two major political parties, and only the Republican members were present.The Minnesota Supreme Court consolidated the cases and determined that Secretary of State Simon's petition was justiciable, thus not needing to address the justiciability of the other petition. The court held that the quorum clause in Article IV, Section 13, of the Minnesota Constitution requires a majority of the total number of seats of which each house may consist to constitute a quorum. Under current statute, the total number of seats in the Minnesota House of Representatives is 134, so a quorum is 68 members.The Minnesota Supreme Court concluded that the quorum clause's requirement of a majority of each house refers to the total number of seats prescribed by law, which is currently 134 for the House of Representatives. Therefore, a quorum requires 68 members. The court assumed that the parties would conform to this opinion without the necessity of issuing a formal writ. View "Simon v. Demuth" on Justia Law

In this case, the Governor of Minnesota issued a writ of special election on December 27, 2024, to fill a vacancy in the office of State Representative for District 40B in Ramsey County. The writ scheduled the special election for January 28, 2025. The Minnesota Voters Alliance, two voters from House District 40B, and the Republican Party of Minnesota challenged the writ, arguing it was issued prematurely.The Ramsey County District Court had previously ruled on December 20, 2024, in an election contest brought by Paul Wikstrom against Curtis Johnson, the elected representative for House District 40B. The court found that Johnson did not meet the residency requirement to serve as the district's representative. No appeal was filed against this decision. Johnson subsequently sent a letter to the Governor on December 27, 2024, stating he would not accept his seat and resigned effective immediately.The Minnesota Supreme Court reviewed the case and determined that the writ of special election was issued prematurely. The court held that Minnesota Statutes section 204D.19, subdivision 4, which governs the timing of special elections following a successful election contest, required the writ to be issued 22 days after the start of the legislative session unless the house passed a resolution regarding the court's determination. The court found that Johnson's letter did not create a vacancy that allowed for the writ's issuance on December 27, 2024, as he was not an incumbent and could not resign from an office he did not hold.The Minnesota Supreme Court granted the petition, quashed the writ of special election, and ordered the cancellation of the special election scheduled for January 28, 2025. View "Minnesota Voters Alliance v. Walz" on Justia Law

A minor, through his mother, filed a lawsuit against Best Academy after his teacher, Aaron Hjermstad, sexually assaulted him. Hjermstad had a history of sexual abuse allegations from his previous employment, which Best Academy did not uncover during their hiring process. The school did not obtain reference letters or contact references, which were part of their hiring protocol.The district court granted summary judgment in favor of Best Academy, reasoning that hiring decisions are always protected by the discretionary-function exception to municipal tort liability under Minnesota Statutes section 466.03, subdivision 6. The court of appeals affirmed this decision, applying the same reasoning.The Minnesota Supreme Court reviewed the case and concluded that a municipality’s hiring decision is not categorically a policy-level decision involving weighing competing economic, social, political, and financial considerations. The court emphasized that the discretionary-function exception should be interpreted narrowly and that municipalities bear the burden of proving that their conduct involved such considerations. The court found that Best Academy did not provide evidence that its decision not to investigate Hjermstad’s background was based on balancing policy considerations. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "Minor Doe 601 v. Best Academy" on Justia Law

Hollydale Land LLC (Hollydale) owned a golf course in Hennepin County, Minnesota, which was taxed under the Minnesota Open Space Property Tax Law. This law allows for reduced tax assessments on properties used for recreational purposes, with deferred taxes calculated based on the difference between the market value and the reduced value. When Hollydale sold the golf course, Hennepin County assessed seven years of deferred taxes totaling $2,622,720.41. Hollydale paid the amount but contested the calculation, arguing that the County failed to cap the market value at the bona fide sale price.Hollydale filed a petition in district court, later transferred to the tax court, challenging the County's assessment. Hennepin County moved to dismiss the petition, arguing it was untimely because Hollydale should have challenged the valuations annually. The tax court denied the motion, holding that the petition was timely as it was filed within 60 days of the notice of deferred taxes, thus the tax court had jurisdiction.Hennepin County sought certiorari review of the tax court's order. The Minnesota Supreme Court reviewed whether the tax court's order denying the motion to dismiss was a "final order" under Minn. Stat. § 271.10, subd. 1, which would allow for immediate appeal. The court reaffirmed its decision in Beuning Family LP v. County of Stearns, which held that such orders are not final and thus not immediately appealable. The court also declined to exercise discretionary review under Minn. R. Civ. App. P. 105.1, finding no compelling reason for immediate appeal and determining that judicial economy would be better served by allowing the tax court to resolve the merits of the case.The Minnesota Supreme Court dismissed the writ of certiorari, concluding that the tax court's order was not a final order and that the interests of justice did not warrant discretionary review. View "County of Hennepin v. Hollydale Land LLC" on Justia Law

A deputy from the Ramsey County Sheriff’s Department stopped Kyaw Be Bee’s vehicle on a public roadway in Saint Paul and found a BB gun under the driver’s seat. Bee was charged with carrying a BB gun in a public place, a gross misdemeanor under Minn. Stat. § 624.7181, subd. 2 (2024). The statute defines “public place” to include property owned or controlled by a governmental unit and private property open to the public, excluding certain private properties and specific locations.The district court dismissed the complaint for lack of probable cause, ruling that the interior of a motor vehicle on a public roadway is not a “public place” under the statute. The State appealed, and the Minnesota Court of Appeals reversed the district court’s decision. The appellate court held that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway, referencing the statutory context and a related exemption for transporting firearms in vehicles.The Minnesota Supreme Court reviewed the case to determine whether the interior of a private motor vehicle on a public road is a “public place” under Minn. Stat. § 624.7181, subd. 1(c). The court concluded that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway. The court reasoned that the statute’s exemptions and related provisions indicate that a motor vehicle on a public road is considered a public place. Consequently, the Supreme Court affirmed the decision of the court of appeals, reinstating the charge against Bee. View "State of Minnesota vs. Bee" on Justia Law

In 2018, Joshua Chiazor Ezeka was convicted by a Hennepin County jury of first-degree premeditated murder, first-degree attempted murder, and second-degree assault for killing Birdell Beeks while shooting at a rival gang member. He was sentenced to life in prison without the possibility of release for the murder, and additional consecutive sentences for the other charges. On direct appeal, the Minnesota Supreme Court affirmed his convictions but remanded for resentencing on the attempted murder charge due to an excessive sentence.After resentencing, Ezeka filed a petition for postconviction relief in 2022, which the district court denied without an evidentiary hearing. The district court concluded that even if the facts alleged in the petition were proven, Ezeka was not entitled to relief. The court also found that most of his claims were procedurally barred as they were known or should have been known at the time of his direct appeal.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the new evidence presented by Ezeka, including reports of general discriminatory practices by the Minneapolis Police Department and the Hennepin County Attorney’s Office, did not meet the legal standard for newly discovered evidence as it did not directly pertain to his case and would not have changed the trial's outcome. The court also found that the alleged failure to disclose this evidence did not constitute a Brady violation as it was not material to the case.Additionally, the court rejected Ezeka’s claims of ineffective assistance of trial and appellate counsel, concluding that his trial counsel’s performance was not objectively unreasonable and that there was no prejudice resulting from the alleged deficiencies. The court determined that the district court did not abuse its discretion in summarily denying the petition for postconviction relief. View "Ezeka vs. State of Minnesota" on Justia Law

Edgard Francisco Talave Latino was charged with misdemeanor domestic assault after an incident with M.T.L., with whom he had a prior romantic and sexual relationship. Latino and M.T.L. met in 2020 and had an on-again, off-again relationship that ended in November 2021. Shortly after their breakup, Latino went to M.T.L.'s apartment, where an argument ensued, and he assaulted her.The district court found Latino guilty of misdemeanor domestic assault, determining that he and M.T.L. had been involved in a significant romantic or sexual relationship, thus meeting the statutory definition of "family or household member." Latino waived his right to a jury trial, and the district court made this finding based on the evidence presented.Latino appealed, arguing that the statutory definition of "family or household member" should only apply to current relationships, not former ones. The Minnesota Court of Appeals disagreed, affirming the conviction by referencing its decision in Sperle v. Orth, which held that former relationships could qualify under the statute. The court of appeals concluded that the evidence was sufficient to prove that Latino and M.T.L. had been in a significant romantic or sexual relationship.The Minnesota Supreme Court reviewed the case to determine whether the statutory definition of "family or household member" includes former significant romantic or sexual relationships. The court held that the definition does include former relationships, subject to the statutory factors of length, type, frequency of interaction, and time since termination. The court found that the evidence was sufficient to support the district court's finding that Latino and M.T.L. had been involved in such a relationship, affirming the decision of the court of appeals. View "State vs. Talave Latino" on Justia Law

Deborah Jane Clapp, a Minneapolis homeowner and taxpayer, filed a declaratory judgment action against the Minneapolis Public Schools and its officials. Clapp challenged the constitutionality of racial and ethnic preference provisions in a collective bargaining agreement between the school district and its teachers' union. She sought to stop the school district from implementing and spending public money on these provisions, alleging they violated the Minnesota Constitution's Equal Protection Guarantee.The district court dismissed Clapp's complaint, ruling that she lacked standing and that her claims were not ripe. Clapp appealed, and the Minnesota Court of Appeals reversed the district court's decision, concluding that Clapp had taxpayer standing and that her claims were ripe for judicial review. The school district then petitioned for review by the Minnesota Supreme Court.The Minnesota Supreme Court reviewed the case and focused on the issue of taxpayer standing. The court held that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. In this case, the court found that the alleged unlawful disbursements were merely incidental to the central dispute, which was the constitutionality of the racial and ethnic preference provisions in the collective bargaining agreement. Therefore, Clapp lacked taxpayer standing to bring her claims. The court reversed the decision of the court of appeals, upholding the district court's dismissal of Clapp's complaint. View "Clapp vs. Sayles-Adams" on Justia Law

Berry Alexander Davis was involved in the kidnapping and murder of Monique Baugh and the attempted murder of her boyfriend, Jon, on New Year’s Eve in 2019. Baugh was abducted, placed in a U-Haul truck, and fatally shot. Davis and a co-defendant, Cedric Lamont Berry, were charged with first-degree premeditated murder, attempted first-degree premeditated murder, and kidnapping. The State's theory was that Davis and Berry attacked Jon on behalf of Lyndon Wiggins, who had a falling out with Jon. Detective Briana Johnson testified about the relationship between Davis, Berry, and Wiggins, indicating they were involved in drug dealing together. Davis waived his right to testify, and the jury found him guilty on all counts. He was sentenced to life in prison without the possibility of release.On direct appeal, Davis argued that the district court erred in joining his trial with Berry’s and that Detective Johnson’s testimony was inadmissible and prejudicial. The Minnesota Supreme Court rejected these arguments and affirmed his conviction and sentence. Davis also filed a pro se supplemental brief raising several claims, including that his sentence violated his constitutional right to a sentencing jury under Blakely v. Washington. The court found these claims lacked merit.Davis subsequently filed a postconviction petition alleging ineffective assistance of trial and appellate counsel and constitutional violations in his sentencing. The district court summarily denied the petition without an evidentiary hearing, concluding that even if Davis proved the facts alleged, he would not be entitled to relief as a matter of law.The Minnesota Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the district court did not abuse its discretion in denying Davis’s postconviction petition without an evidentiary hearing, as his claims failed on their merits as a matter of law. View "Davis vs. State" on Justia Law