Justia Minnesota Supreme Court Opinion Summaries

Joanne Ecklund received long-term care services through Minnesota’s Medicaid program, the Minnesota Medical Assistance Program (MMAP). The Minnesota Department of Human Services (DHS) paid $66,052.62 in capitated payments to Medica, Ecklund’s managed care organization (MCO), which in turn paid $8,806.84 to care providers for Ecklund’s services. After Ecklund’s death in 2021, DHS sought to recover the $66,052.62 from her estate under Minnesota Statutes section 256B.15, subdivision 2(a)(1), which allows recovery of medical assistance payments for long-term care services provided to recipients aged 55 or older.The district court, adopting a referee’s recommendation, granted summary judgment in favor of the estate’s personal representative, Jerry Ecklund, limiting DHS’s recovery to the $8,806.84 paid by Medica to the care providers. The Minnesota Court of Appeals affirmed, interpreting the statute to limit DHS’s recovery to the amount actually paid to the providers.The Minnesota Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that Minnesota Statutes section 256B.15, subdivision 2(a)(1), allows DHS to recover the amount of capitation payments made to the MCO for long-term care services provided to the recipient. The court reasoned that the statute’s language and the broader statutory context support DHS’s interpretation, which aligns with federal guidance requiring states to recover capitation payments. The court concluded that DHS is entitled to recover the $66,052.62 in capitated payments from Ecklund’s estate. View "In re the Estate of: Ecklund" on Justia Law

Rodney Dean Bjornson, the relator, suffered two injuries while employed by McNeilus Companies, Inc. He received treatment at Mayo Clinic, with expenses paid by United Healthcare Services. Bjornson's attorney, David C. Wulff, sought Roraff fees for recovering medical benefits. The compensation judge awarded Wulff $49,000 in Roraff fees, finding that United paid $327,257.37 in medical benefits based on itemized medical bills from Mayo Clinic attached to Bjornson's Employee’s Claim Petition.The Workers’ Compensation Court of Appeals (WCCA) reviewed the case and concluded that the itemized bills from Mayo Clinic were not in the appellate record. The WCCA reversed the compensation judge’s award of Roraff fees due to insufficient evidence regarding the bills and modified the Roraff fees to $500, as per the statutory formula for unascertainable benefits amounts.The Minnesota Supreme Court reviewed the case to determine if Wulff presented sufficient evidence of the ascertainable dollar value of medical benefits. The court found that the WCCA did not assess whether the remaining evidence, including Wulff’s testimony and exhibits, was adequate to support the compensation judge’s conclusion. The Supreme Court reversed the WCCA's decision and remanded the case for further proceedings. The WCCA was directed to clarify whether the itemized medical bills were actual bills or a summary document and to determine if the evidence in the record was adequate to support the compensation judge’s conclusion. View "Bjornson v. McNeilus Companies, Inc." on Justia Law

The State charged Larry Joe Foster with second-degree intentional murder for the death of Daniel Bradley. Foster claimed that another person, R.J., committed the murder. The district court determined that Foster met the requirements to present an alternative perpetrator defense and allowed him to introduce evidence supporting his claim. Foster intended to call R.J. as a witness, but R.J. invoked his right against self-incrimination before the trial. Foster requested that R.J. be required to invoke this right in front of the jury, but the district court denied the request, citing the lack of probative value and the cumulative nature of the evidence.The jury found Foster guilty of second-degree murder. Foster appealed, arguing that the district court violated his constitutional rights by not allowing him to call R.J. to the stand. The Minnesota Court of Appeals affirmed Foster’s conviction, concluding that he had no constitutional right to call R.J. solely to invoke his right against self-incrimination.The Minnesota Supreme Court reviewed the case and held that when a defendant has satisfied the required test to present an alternative perpetrator defense, the district court has discretion to allow the defendant to call the alternative perpetrator as a witness, even if it is known that the alternative perpetrator will invoke their right against self-incrimination. However, the district court must apply the ordinary rules of evidence in making this determination. The Supreme Court concluded that the district court did not abuse its discretion in denying Foster’s request, as the invocation of the right against self-incrimination by R.J. would have been needlessly cumulative. The decision of the court of appeals was affirmed on different grounds. View "State v. Foster" on Justia Law

Eloisa Rubi Plancarte was convicted of misdemeanor indecent exposure under Minnesota Statutes section 617.23, subdivision 1(1) for exposing her breasts in a gas station parking lot. Plancarte argued that her breasts are not "private parts" under the statute and that her exposure was not "lewd." She also claimed that prosecuting her for conduct that men are allowed to engage in violated her constitutional right to equal protection. The district court denied her motion to dismiss, and she was found guilty in a stipulated-evidence trial.Plancarte appealed her conviction, but the court of appeals affirmed it in a divided opinion. The majority concluded that the evidence was sufficient to support the conviction, while the dissent argued that the statute requires lewd conduct in addition to exposure, which was not proven in this case.The Minnesota Supreme Court reviewed the case and concluded that the term "lewdly" in the statute refers to conduct of a sexual nature. The court found that the State did not present sufficient evidence to prove that Plancarte's exposure was lewd, as there was no indication that her conduct was of a sexual nature. Consequently, the court reversed Plancarte's conviction. The court did not address whether female breasts are "private parts" under the statute or the equal protection claim, as the decision on the lewdness element resolved the case. View "State v. Plancarte" on Justia Law

In 2002, Fred Williamson was fatally shot while in a car in Minneapolis. B.H., a passenger in Williamson's car, initially claimed he did not see the shooter. Later, B.H. was indicted on unrelated federal drug charges and agreed to provide substantial assistance in Williamson's murder investigation in exchange for a potential sentence reduction. At trial, B.H. identified Leroy Roderick Paul as the shooter. Paul was convicted of first-degree murder during a drive-by shooting and sentenced to life in prison. His conviction was affirmed on direct appeal.Paul filed a petition for postconviction relief in 2023, claiming the State violated Brady v. Maryland and Giglio v. United States by not disclosing the specific terms of B.H.'s plea agreement. The district court denied the petition without an evidentiary hearing, finding no factual support for Paul's claim and determining the petition was untimely under the two-year statutory time bar.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the evidence presented by Paul, even if accepted as true, did not support his claim that B.H. had negotiated a specific sentence. The court also found that Paul's petition was untimely and did not meet the exceptions for newly discovered evidence or interests of justice. The court concluded that the district court did not abuse its discretion in summarily denying the petition. View "Paul v. State" on Justia Law

Henry Lee Brown was involved in a fatal collision in 2021 while driving near his home in Minneapolis. After hitting and killing a pedestrian, Brown did not stop at the scene and drove home without notifying the police. He was charged with two counts of criminal vehicular homicide, including leaving the scene of a collision. Brown initially pled not guilty but later changed his plea to guilty for leaving the scene after causing the collision. He admitted to driving the vehicle and leaving the scene but claimed he was unconscious at the time of the collision due to a medical incident.The district court denied Brown's motion to withdraw his guilty plea and sentenced him to 58 months in prison. Brown appealed, arguing that the statute required the State to prove he was volitionally operating the vehicle at the time of the collision. The court of appeals affirmed the district court's decision, holding that the statute did not require volitional operation at the time of the collision.The Minnesota Supreme Court reviewed the case to determine whether the criminal vehicular homicide statute required proof of volitional operation at the time of the collision. The court concluded that the statute does not require an act of operation at the time of the collision. Instead, an act of operating a motor vehicle that takes place before a collision can satisfy the statute's requirements. The court affirmed the decision of the court of appeals on other grounds, holding that Brown's factual basis for his guilty plea was adequate because he admitted to volitionally operating the vehicle before losing consciousness, causing the pedestrian's death, and leaving the scene without returning. View "State v. Brown" on Justia Law

Dawn Simonson was employed by Douglas County as a histologist and suffered a lower back injury in 1996 while performing her job duties. The injury left her permanently and totally disabled, and she received workers' compensation benefits. When Simonson turned 67 in 2023, her employer stopped paying her permanent total disability (PTD) benefits based on a statutory retirement presumption. Simonson claimed she would have worked past age 67 and sought to rebut the presumption.A compensation judge initially found that Simonson had not rebutted the retirement presumption, applying factors from a previous case, Davidson v. Thermo King. The judge concluded that Simonson's intent to retire weighed in favor of the employer, while her financial need weighed in her favor, and other factors were neutral or irrelevant. The Workers’ Compensation Court of Appeals (WCCA) reversed this decision, concluding that the proper standard of proof to rebut the presumption was a preponderance of the evidence and that Simonson had met this burden based on her financial need.The Minnesota Supreme Court reviewed the case and affirmed the WCCA's determination that the preponderance-of-the-evidence standard applies when an employee seeks to rebut the retirement presumption. However, the Supreme Court found that the WCCA erred in emphasizing financial need as the primary factor. Instead, the court held that the relevant question is whether the employee would have retired anyway, even if not disabled, considering various factors such as the availability of work, retirement arrangements, age, work history, and willingness to forgo social security benefits. The case was remanded to the compensation judge for further findings consistent with this opinion. View "Simonson v. Douglas County" on Justia Law

A father, Travis W. Kalis, was ordered by a district court in 2013 to pay $1,145 per month in child support to the mother of his children, Leslie E. Sheehy Lee. In 2015, the parties discussed modifying this amount through a private agreement, but no written agreement was executed. Despite this, Kalis began making reduced payments of $1,000 per month via Venmo, which later decreased to $500 per month. In 2022, after Kalis stopped making prompt payments, Sheehy Lee sought enforcement of the original court order through the county child support agency, which notified Kalis that he owed over $30,000 in arrearages.A child support magistrate (CSM) concluded that the parties had reached an extrajudicial agreement to modify Kalis’s child support obligation and determined that Kalis did not owe any arrearages. Sheehy Lee sought review in the district court, arguing that the forgiveness of arrearages was an impermissible retroactive modification of the child support order. The district court declined to grant relief, and the court of appeals affirmed, concluding that the parties had reached a fair and reasonable agreement.The Minnesota Supreme Court reviewed the case and held that extrajudicial agreements to modify child support orders are invalid as a matter of law. The court emphasized that child support orders can only be modified by a court and within the limits set by Minnesota Statutes section 518A.39, subdivision 2(f), which prohibits retroactive modifications of child support orders except from the date of service of notice of the motion to modify. The court also clarified that the statutory exception allowing for an alternative effective date applies only to subsequent court-issued child support orders, not to extrajudicial modifications. The decision of the court of appeals was reversed, and the case was remanded for further proceedings. View "Lee v. Kalis" on Justia Law

A Nashwauk police officer observed a vehicle swerving and initiated a traffic stop, identifying the driver as Christopher Lee Manska. The officer noted signs of intoxication and discovered Manska's driver's license had been canceled. Manska refused a chemical test, and a search of his vehicle revealed marijuana. He was charged with multiple offenses, including driving while impaired and possession of marijuana. Manska sought the audit trail of the dash camera footage, claiming the footage had been tampered with.The district court denied Manska's motion to compel the audit trail, finding his claims of tampering unsupported and not credible. The court of appeals affirmed, concluding that Manska failed to show the information sought would be "material and favorable" to his defense, applying a higher standard than required.The Minnesota Supreme Court reviewed the case, determining that the lower courts applied the wrong standard. The correct standard under Minn. R. Crim. P. 9.01, subd. 2(3), requires only that the information sought "may relate to the guilt or innocence of the defendant." The Supreme Court concluded that Manska made an adequate showing that the audit trail may relate to his guilt or innocence, as it could reveal discrepancies in the dash camera footage that would challenge the officer's credibility.The Supreme Court reversed the lower courts' decisions and remanded the case. On remand, the district court must require the State to disclose the audit trail. If the audit trail shows tampering, Manska is entitled to a new suppression hearing. If no tampering is found, the conviction stands. View "State v. Manska" on Justia Law

In 2021, Ryan Martens disclosed to his therapist that he had engaged in sexual contact with his children's babysitter when she was 17 years old. The therapist, a mandated reporter, filed a maltreatment report with Kanabec County authorities. At the time of the disclosure, the victim was 18 years old. Martens was subsequently charged with third-degree criminal sexual conduct.The district court denied Martens's motion to exclude the therapist's report and testimony, ruling that the therapist-client privilege did not apply because the report was mandatory under the mandated-reporter statute. A jury found Martens guilty, and the court of appeals affirmed the conviction, concluding that the mandated-reporter statute required the therapist to file the report.The Minnesota Supreme Court reviewed the case to determine whether the mandated-reporter statute, Minn. Stat. § 260E.06, subd. 1(a), requires a report when the maltreated child is over 18 at the time of disclosure. The court held that the statute mandates a report if the reporter knows or has reason to believe that a child has been maltreated within the preceding three years, even if the child reaches adulthood before the disclosure. Consequently, the court affirmed the lower court's decision, ruling that the district court did not err in admitting the therapist's report and testimony. View "State of Minnesota vs. Martens" on Justia Law