Justia Minnesota Supreme Court Opinion Summaries

A vacancy was created on the Orono City Council in November 2024 when a councilmember resigned with more than two years remaining in his term. At the time, the City of Orono did not have a special-election ordinance. The mayor appointed a replacement to fill the seat. Subsequently, in February 2025, the city council enacted a special-election ordinance and adopted a resolution to hold a special election to fill the remainder of the term.Dennis Walsh, who had appointed the replacement, petitioned the Hennepin County District Court under Minnesota Statutes section 204B.44 to quash the special election. He argued the relevant statute required the appointed councilmember to serve the remainder of the term because no special-election ordinance was in place at the time of the vacancy, and that holding a special election would improperly remove the appointee in violation of the Minnesota Constitution. The City of Orono and its city clerk opposed the petition, asserting statutory authority for their actions.The Hennepin County District Court denied Walsh’s petition, finding that the city was authorized to hold a special election and that passage of the ordinance after the vacancy did not violate the statute or constitution. Walsh sought accelerated review.The Minnesota Supreme Court affirmed the district court’s decision. It held that claims challenging the special election were properly raised under section 204B.44. Substantively, the court determined Minnesota Statutes section 412.02, subdivision 2a, permits a statutory city to enact and apply a special-election ordinance after a vacancy is filled by appointment, so long as more than two years remain in the term. Further, holding a special election in these circumstances does not constitute an unconstitutional removal of an inferior officer under article VIII, section 5, of the Minnesota Constitution. View "Walsh vs. City of Orono" on Justia Law

Christopher Thigpen applied for and received unemployment benefits from the Minnesota Department of Employment and Economic Development (DEED) for 104 weeks spanning March 2020 to March 2022. During this period, Thigpen was employed as a personal care assistant, earning weekly wages, but reported to DEED each week that he had not worked or received other income. This misrepresentation led to Thigpen receiving overpayments totaling $39,605 in standard and pandemic unemployment benefits. In April 2022, DEED reviewed his account, confirmed his employment during the relevant period, and determined that he had obtained the overpayments due to misrepresentation. As a result, DEED assessed a penalty of 40 percent of the overpaid amount, imposed 1 percent monthly interest, and barred Thigpen from receiving any future unemployment benefits until repayment, subject to a statutory ten-year cancellation period.Thigpen appealed the determination before an unemployment law judge, arguing that he did not intend to defraud DEED and misunderstood the forms. After multiple evidentiary hearings, the unemployment law judge found Thigpen’s explanations not credible, upheld the finding of misrepresentation, and applied the statutory penalty, interest, and benefit ineligibility.Thigpen requested certiorari review from the Minnesota Court of Appeals, challenging the sufficiency of evidence, burden of proof, denial of due process, and constitutionality of the penalties under the Excessive Fines Clauses of the U.S. and Minnesota Constitutions. The Court of Appeals rejected all arguments, specifically finding the penalties proportionate and comparable to those for similar offenses in Minnesota and other states.On further appeal, the Minnesota Supreme Court affirmed the Court of Appeals, holding that the penalty, interest, and benefit ineligibility for unemployment benefit misrepresentation do not violate the Excessive Fines Clauses, as they are not grossly disproportionate to the gravity of the offense and are consistent with penalties in Minnesota and other jurisdictions. View "Thigpen vs. Best Home Care LLC" on Justia Law

A police officer stopped a vehicle driven by the appellant for traffic violations and discovered that his driver’s license had been canceled. During the stop, the officer smelled a strong odor of marijuana coming from the vehicle. Citing only the odor as justification, the officer conducted a warrantless search of the car. During the search, the officer found ammunition in a locked safe in the backseat. The appellant was prohibited by law from possessing ammunition and was subsequently charged with that offense, as well as with driving after cancellation.The trial court, the Scott County District Court, granted the appellant’s motion to suppress the ammunition, ruling that the search violated his constitutional rights. This ruling came after the Minnesota Supreme Court’s decision in State v. Torgerson, which held that the smell of marijuana alone is not sufficient to establish probable cause for a warrantless vehicle search. The State appealed. The Minnesota Court of Appeals reversed the district court’s decision, holding that the good-faith exception to the exclusionary rule applied because, at the time of the search, officers could reasonably have relied on existing appellate precedent that arguably permitted such searches.The Supreme Court of Minnesota, reviewing the case, rejected the application of the good-faith exception. The court held that there was no binding appellate precedent specifically authorizing warrantless vehicle searches based solely on the smell of marijuana at the time of the search, and previous Minnesota Supreme Court decisions had emphasized the need to evaluate the totality of the circumstances. The court concluded that the good-faith exception did not apply, reversed the decision of the Court of Appeals, and remanded the case to the district court for further proceedings. View "State of Minnesota vs. Douglas" on Justia Law

The case centers on an incident in which Lisa Dawn Oliver was arrested following a violent confrontation involving her former partner, P.L., who had custody of their daughter. After Oliver and her friend attempted to take the child from P.L.’s apartment, an argument ensued. During the altercation, Oliver was alleged to have cut P.L.’s neck with a concealed weapon and was heard threatening to kill him. P.L. required medical treatment for the wound, but the injury did not meet the statutory definition of “great bodily harm.”Initially charged with attempted second-degree intentional murder, Oliver later faced additional charges of attempted first-degree assault-harm and second-degree assault with a dangerous weapon causing substantial bodily harm. A jury acquitted her of attempted murder but convicted her of both attempted first-degree assault-harm and second-degree assault. The Dakota County District Court entered a conviction for attempted first-degree assault-harm and sentenced Oliver to 45 months in prison.The Minnesota Court of Appeals reversed the conviction for attempted first-degree assault-harm, holding that such an offense does not exist under Minnesota law. The majority found that the statutory scheme for assault is based on harm inflicted rather than intended, and that the specific intent required for attempt crimes conflicted with the general intent element of first-degree assault-harm. The appellate court remanded for sentencing on the lesser second-degree assault conviction.The Minnesota Supreme Court reviewed the case and reversed the Court of Appeals. The Supreme Court held that attempted first-degree assault-harm, charged under the attempt statute, is a recognized crime in Minnesota. The Court ruled there is no statutory or logical conflict between the specific intent required for attempt and the general intent required for first-degree assault-harm. The case was remanded for the Court of Appeals to consider other issues not previously addressed. View "State of Minnesota vs. Oliver" on Justia Law

A man was charged with attempted first-degree premeditated murder and unlawful possession of a firearm following a shooting in Duluth. The victim could not identify the shooter, and evidence at the scene included two guns and DNA samples. Investigators initially obtained a search warrant for DNA samples from the suspect, but after the validity of that warrant was challenged in a co-defendant’s case, the State agreed not to use any evidence obtained from it. Instead, the State sought and received a court order under a Minnesota procedural rule to collect a buccal swab (cheek swab) from the defendant for DNA analysis. This DNA evidence, along with recorded jail calls and texts from an alleged accomplice, was presented at trial. The defendant was convicted by a jury and sentenced to prison.The Minnesota Court of Appeals reversed the convictions, holding that the warrantless collection of the buccal swab violated constitutional protections against unreasonable searches and seizures, and that this error was not harmless beyond a reasonable doubt. The court also held that the defendant was not entitled to a jury instruction requiring corroboration of accomplice testimony, because the accomplice’s statements were not made under oath.Upon review, the Minnesota Supreme Court agreed with the appellate court. It held that collecting a buccal swab for DNA analysis without a warrant or a valid exception constitutes an unreasonable search under both the United States and Minnesota Constitutions. The court rejected arguments that the procedural rule or a court order could replace a warrant, and found no applicable exception to the exclusionary rule. The court also clarified that the statutory term “testimony” in Minnesota’s accomplice-corroboration statute means only statements made under oath. The Supreme Court affirmed the reversal of the convictions and remanded for a new trial. View "State of Minnesota vs. Steeprock" on Justia Law

In August 2022, the appellants filed a complaint and petition in Rice County District Court, seeking to prevent the use of electronic voting machines with embedded modems in the upcoming November 2022 general election. They alleged that these machines were not properly certified or secure, in violation of Minnesota law, and requested an order restraining the county from using the modem functions during the election. The complaint named the Director of Rice County Property Tax and Elections as a defendant, and the Minnesota Secretary of State intervened as a party.The Rice County District Court dismissed the section 204B.44 claim in January 2023, citing several jurisdictional defects, including mootness because the 2022 election had already occurred, and insufficient service of process on all candidates as required by statute. The Minnesota Court of Appeals affirmed the dismissal, focusing on the lack of service to all candidates as the basis for its decision and did not address the other grounds identified by the district court.The Minnesota Supreme Court reviewed the case and held that the appellants’ claim under Minnesota Statutes section 204B.44 was moot because the relief sought pertained solely to the 2022 general election, which had already taken place. The court rejected the argument that the claim could be redirected to future elections and clarified that section 204B.44 challenges must be specific to a single election. The Supreme Court affirmed the decision of the Court of Appeals, but did so on the alternative ground of mootness, without reaching the issue of service of process on all candidates. View "Benda for Common-sense vs. Anderson" on Justia Law

After being involved in a head-on collision during a snowstorm, the appellant was detained by police on suspicion of driving while impaired. Law enforcement obtained a search warrant authorizing a blood test, but not a urine test. The appellant refused to submit to both the blood test (for which there was a warrant) and a urine test (for which there was not). He was subsequently charged with first-degree test refusal. The appellant moved to suppress evidence of his refusals and to dismiss the charge, arguing that the statutes required refusal of both tests to sustain a conviction and that, because there was no warrant for a urine test, his prosecution violated the Fourth Amendment.The District Court denied the appellant’s motion, concluding that the relevant statutes did not require warrants for both blood and urine tests to prosecute for test refusal. The appellant waived his right to a jury trial, and the District Court found him guilty of first-degree test refusal based on stipulated facts. On appeal, the Minnesota Court of Appeals affirmed the conviction, holding that the statutory language required only refusal of the test authorized by the warrant and that there was no requirement for law enforcement to obtain warrants for both types of tests.The Minnesota Supreme Court reviewed the case and held that when a warrant authorizes only one type of chemical test—either blood or urine—a person’s refusal to submit to that specific test is sufficient for a conviction under Minn. Stat. §§ 169A.20, subd. 2(2), and 171.177, subd. 2. The Court further held that a conviction for refusing a warranted chemical test does not violate the Fourth Amendment. The decision of the Court of Appeals was affirmed, though on different grounds. View "State of Minnesota vs. Lueck" on Justia Law

In September 2017, John Lacy was shot and killed in Minneapolis. Tescil Romalis Mason-Kimmons was indicted for first-degree murder and faced a potential life sentence. Surveillance footage, witness statements, and physical evidence linked Mason-Kimmons to the crime, but some witness descriptions did not match his appearance. Shortly before trial, Mason-Kimmons’s attorney stated he was unprepared and would provide ineffective assistance if forced to proceed. Mason-Kimmons subsequently pled guilty to second-degree intentional murder and received a 366-month prison sentence.After sentencing, Mason-Kimmons filed a direct appeal, which was stayed to allow him to seek postconviction relief in the Hennepin County District Court. He argued that his guilty plea was involuntary due to ineffective assistance of counsel, specifically that his attorney’s lack of preparedness pressured him into pleading guilty. The district court denied his petition without an evidentiary hearing. The Minnesota Court of Appeals affirmed the denial of his involuntary plea claims but remanded for an evidentiary hearing on the ineffective assistance claim. After further proceedings, the district court again denied relief, finding Mason-Kimmons was not prejudiced by his attorney’s deficient advice. The court of appeals affirmed, concluding there was no reasonable probability Mason-Kimmons would have insisted on going to trial but for counsel’s advice.The Minnesota Supreme Court reviewed the case, focusing on whether Mason-Kimmons was prejudiced by his attorney’s constitutionally deficient advice. The court held that there was a reasonable probability Mason-Kimmons would have gone to trial if not for his counsel’s lack of preparedness and advice to plead guilty. The Supreme Court found both prongs of the Strickland test for ineffective assistance of counsel were met, reversed the lower courts’ decisions, and remanded to allow Mason-Kimmons to withdraw his guilty plea. View "Mason-Kimmons vs. State of Minnesota" on Justia Law

An employee began working at a foundry in Minnesota and, after developing back problems, was placed on a lifting restriction by her doctor. She informed her employer of this restriction, but the employer terminated her employment without attempting to provide accommodations. The employee then applied for unemployment benefits, prompting the employer to complete a questionnaire for the Department of Employment and Economic Development (DEED) regarding her termination and disability. In the questionnaire, the employer indicated it had not tried to accommodate her condition.The employee subsequently filed a lawsuit under the Minnesota Human Rights Act, alleging disability discrimination and failure to accommodate. During discovery, the employer sought to exclude the DEED questionnaire from evidence at trial, arguing it was absolutely privileged under Minnesota Statutes section 268.19, subdivision 2(c). The District Court agreed and excluded the document, reasoning that information created solely for unemployment insurance purposes was inadmissible in other civil proceedings. After a bench trial, the District Court ruled in favor of the employer and dismissed the employee’s claims. The Minnesota Court of Appeals affirmed, holding that the questionnaire was absolutely privileged and inadmissible.The Supreme Court of Minnesota reviewed the case to determine whether section 268.19, subdivision 2(c), bars admission of such documents in civil cases. The court held that the phrase “absolutely privileged” in the statute provides immunity from liability for information submitted to DEED, but does not create a general rule of inadmissibility for such evidence in unrelated civil proceedings. Because the employee’s discrimination claim was not based on the content of the DEED questionnaire, its exclusion was erroneous. However, the court found the error was not prejudicial, as the excluded evidence was cumulative of other admitted evidence. The Supreme Court affirmed the decision of the Court of Appeals, but on different grounds. View "McBee vs. Team Industries, Inc." on Justia Law

A middle school math teacher employed by a Minneapolis public school was injured while playing basketball with students during an afterschool practice. The teacher participated in the activity to strengthen relationships with students, which was encouraged by the school’s administration and reflected in the school’s mission and teacher evaluation standards. The injury, a ruptured ACL, occurred approximately 30 minutes after the official end of the teacher’s workday, at the school gym, and required surgery and time off work. The teacher sought workers’ compensation benefits, but the self-insured school district denied liability, arguing the injury did not arise out of or in the course of employment and was excluded under a statutory provision for injuries incurred during voluntary employer-sponsored recreational programs.After an administrative hearing, a workers’ compensation judge found the injury compensable, concluding it arose out of and in the course of employment, and that the statutory exclusion for voluntary recreational programs did not apply because the activity was for the benefit of students, not employees. The school district appealed to the Workers’ Compensation Court of Appeals (WCCA), which affirmed the compensation judge’s decision, agreeing that the exclusion did not bar the claim and that the injury occurred in the course of employment.The Minnesota Supreme Court reviewed the case. It held that the teacher’s injury occurred “in the course of” employment under Minnesota Statutes section 176.021, subdivision 1, because the injury happened at the workplace, within a reasonable time after the workday, and during an employment-related activity. The Court further held that the exclusion in section 176.021, subdivision 9, applies only to voluntary employer-sponsored recreational programs that are for the benefit of employees, not students. The Supreme Court affirmed the WCCA’s decision. View "Lindsay vs. Minneapolis Public School District (SSD1)" on Justia Law