Justia Minnesota Supreme Court Opinion Summaries

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

A police officer applied for a search warrant for a residence based on information from a confidential reliable informant (CRI). The CRI reported that, within the previous 72 hours, they had visited the residence and observed people smoking methamphetamine and meth pipes inside. The CRI was not directed by law enforcement to visit the house and had a history of providing reliable information to the police. Based on this information, a district court judge issued a search warrant. When the warrant was executed, officers found drug paraphernalia and items testing positive for methamphetamine. The resident was charged with two drug-related offenses.The defendant moved to suppress the evidence, arguing that the warrant was not supported by probable cause. The Swift County District Court denied the motion, finding the warrant application sufficient. After a jury found the defendant guilty, the Minnesota Court of Appeals affirmed the conviction in a divided opinion. The majority held that the totality of the circumstances, including the CRI’s reliability and basis of knowledge, established probable cause, and rejected the argument that corroboration of the CRI’s tip was always required. The dissent argued that corroboration was necessary and that the lack of it meant probable cause was lacking.The Minnesota Supreme Court reviewed the case to clarify whether corroboration of a confidential reliable informant’s tip is an independent requirement for probable cause. The court held that corroboration is not an independent requirement but is always a relevant factor in the totality-of-the-circumstances analysis. Applying this standard, the court concluded that the limited, uncorroborated observations in the warrant application did not establish a fair probability that contraband or evidence of a crime would be found in the house at the time of the search. The court reversed the decision of the court of appeals and remanded the case for further proceedings. View "State of Minnesota vs. Nagle" on Justia Law

The appellant was convicted by a jury of three counts of first-degree murder and three counts of second-degree murder for the deaths of three individuals in 1995. He was sentenced in 1996 to three consecutive life sentences, as required by statute for first-degree murder. At the time of sentencing, a probation agent advised the court that a presentence investigation (PSI) would not affect the sentence because the law mandated life imprisonment. The appellant did not receive a PSI, and a post-sentence investigation was to be conducted by the Department of Corrections. Over the years, the appellant challenged his convictions and sentences through multiple postconviction petitions, all of which were denied.In 2024, the appellant filed a motion to correct or reduce his sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, arguing that the lack of a PSI and alleged errors in calculating his criminal history score rendered his sentences unlawful. The State argued that the motion was actually a postconviction petition subject to the two-year statute of limitations under Minnesota Statutes § 590.01, subdivision 4, and that the court lacked jurisdiction. The Carver County District Court agreed with the State, denied the motion, and stated it lacked jurisdiction, but did grant jail credit for time served.The Minnesota Supreme Court reviewed the case and held that the district court erred in concluding it lacked jurisdiction to hear the appellant’s motion under Rule 27.03, subdivision 9, because such motions are not subject to the statutory time bar and, even if they were, the time bar is not jurisdictional. However, the Supreme Court affirmed the district court’s denial of relief, holding that the appellant’s mandatory life sentences were lawful. The absence of a PSI and the alleged miscalculation of the criminal history score did not render the sentences unlawful, as neither the PSI statute nor the sentencing guidelines apply to mandatory life sentences for first-degree murder. View "Riley vs. State of Minnesota" on Justia Law

A transgender woman sought to compete in the women’s division of powerlifting competitions organized by a national governing body. After registering and applying for a therapeutic use exemption to take a medication as part of her gender-affirming care, she was informed that the organization’s policy categorically barred transgender women from competing in the women’s division. The organization justified its policy by asserting that transgender women have an unfair competitive advantage due to “male physiology.” The woman’s competition card was revoked, and she was denied participation.The case was first heard in the Minnesota District Court, which granted partial summary judgment in favor of the plaintiff on her claims of sexual orientation discrimination in both public accommodations and business, as well as sex discrimination in business, under the Minnesota Human Rights Act (MHRA). The district court found the organization’s policy facially discriminatory and not justified by a legitimate business purpose. However, it denied summary judgment on the claim of sex discrimination in public accommodations, citing a statutory exemption for athletic events. The court also issued injunctive relief, ordering the organization to cease discriminatory practices and revise its policy.On appeal, the Minnesota Court of Appeals reversed the district court’s grant of partial summary judgment and injunctive relief, finding genuine issues of material fact regarding the organization’s motivation and the applicability of the legitimate business purpose defense.The Minnesota Supreme Court held that the organization’s policy was facially discriminatory and constituted direct evidence of discrimination based on sexual orientation under the MHRA. The court reinstated summary judgment for the plaintiff on the public accommodations claim, as no statutory defense was asserted. However, it found a genuine dispute of material fact regarding the legitimate business purpose defense for the business discrimination claim, affirming the appellate court’s reversal on that issue. The case was remanded for further proceedings. View "Cooper vs. USA Powerlifting" on Justia Law

Atravius Weeks was indicted for first-degree premeditated murder, first-degree domestic abuse murder, and second-degree intentional murder after he confessed to shooting and killing Cortney Henry in Dakota County, Minnesota. The incident occurred in June 2021, and Weeks was apprehended shortly after the crime. At trial, Weeks raised concerns about the racial composition of the jury panel, noting that Black individuals were underrepresented compared to the county’s population. He argued that the jury pool did not reflect a fair cross-section of the community, as required by the Constitution.The Dakota County District Court denied Weeks’s request for a new jury panel and, after a jury found him guilty on all counts, entered convictions for all three murder charges. Weeks’s direct appeal was stayed to allow him to file a postconviction petition, which included an expert affidavit suggesting that the use of voter registration and driver’s license lists for jury selection systematically underrepresents Black people. The district court summarily denied the postconviction petition, finding that Weeks failed to show systematic exclusion of Black jurors under the three-prong test from State v. Williams, and cited prior Minnesota cases holding that the jury selection process does not systematically exclude people of color.The Minnesota Supreme Court reviewed the case and held that the district court abused its discretion by summarily denying the postconviction petition. The Supreme Court found that, when the facts alleged are viewed in the light most favorable to Weeks, the record does not conclusively show he is entitled to no relief, and genuine issues of material fact remain regarding systematic exclusion. The Court also held that the district court violated Minnesota Statutes section 609.04 by entering convictions for both first-degree domestic abuse murder and second-degree intentional murder in addition to first-degree premeditated murder. The Supreme Court reversed and remanded for an evidentiary hearing and ordered the vacation of the lesser murder convictions. View "State of Minnesota vs. Weeks" on Justia Law

A personal care assistance provider agency in Minnesota was audited by the Department of Human Services (DHS) for recordkeeping deficiencies related to its provision of services under the state’s Medicaid program. The agency, which served both traditional and PCA Choice recipients, was found to have various documentation errors, including missing or incomplete care plans and timesheets, as well as timesheets lacking required elements. DHS did not allege fraud or that services were not provided, but sought to recover over $420,000 in payments, arguing that these deficiencies constituted “abuse” under state law and justified monetary recovery.After an evidentiary hearing, an administrative law judge (ALJ) recommended limited recovery for some missing documentation but rejected most of DHS’s claims, finding that DHS had not shown the deficiencies resulted in improper payments. The DHS Commissioner disagreed, ordering full repayment. The Minnesota Court of Appeals reversed the Commissioner’s decision, holding that DHS must prove not only that the provider engaged in “abuse” but also that the abuse resulted in the provider being paid more than it was entitled to receive. The court also determined that provider agencies must maintain care plans for both traditional and PCA Choice recipients in their files.The Minnesota Supreme Court affirmed in part, reversed in part, and remanded. It held that, to obtain monetary recovery under Minn. Stat. § 256B.064, subd. 1c(a), DHS must prove either: (1) the provider engaged in conduct described in subdivision 1a and, had DHS known of the conduct before payment, it would have been legally prohibited from paying under a statute or regulation independent of subdivision 1a; or (2) the payment resulted from an error such that the provider received more than authorized by law. The Court also held that provider agencies must keep care plans for all PCA services, including PCA Choice, in their files. View "In the Matter of the SIRS Appeal by Best Care, LLC" on Justia Law

After being arrested and jailed following an alleged assault on hospital staff, an individual was found incompetent to proceed in a criminal case and was civilly committed as mentally ill. The district court appointed counsel to represent him in the civil commitment proceedings. Under Minnesota law at the time, civilly committed patients in jail were entitled to priority admission to a state-operated treatment program within 48 hours of the commitment order. Despite this, the individual remained in jail for over a month. His court-appointed counsel then petitioned for writs of mandamus and habeas corpus to enforce his statutory right to timely admission to a treatment facility.The district court granted the writ of mandamus, ordering the Commissioner of Human Services to admit the patient to a treatment facility, and directed the county sheriff to transport him accordingly. When the county refused to pay the appointed counsel for work performed in the extraordinary writ proceedings, the district court ordered the county to pay, finding that the counsel’s work was directly related to the civil commitment and that representation extended to all proceedings under the relevant statute.The Minnesota Court of Appeals reversed the district court’s order regarding payment for the extraordinary writ proceedings, holding that such proceedings were not “under” the civil commitment statute and thus did not entitle the patient to court-appointed counsel or require payment by the county. However, the appellate court affirmed the order for payment for representation in the initial commitment proceedings.The Minnesota Supreme Court reversed the appellate court’s decision, holding that a petition for an extraordinary writ to enforce a civilly committed patient’s right to timely admission to a state-operated treatment program is a proceeding under the civil commitment statute. Therefore, the patient is entitled to the assistance of court-appointed counsel in such proceedings, and the county must pay a reasonable sum for that representation. View "In the Matter of the Civil Commitment of: Swope" on Justia Law

A tenant entered into a lease for an apartment in Minneapolis that was subsidized under the Section 8 project-based voucher program, with the local public housing authority paying most or all of the rent directly to the landlord. After the tenant fell behind on utility payments, her electricity was disconnected, and she and her boyfriend broke into the building’s utility closet to restore power, inadvertently affecting other units. The landlord learned of this breach but continued to accept three months of rental payments from the public housing authority on the tenant’s behalf. Later, the landlord filed an eviction action based on the tenant’s breach of the lease.The Hennepin County District Court dismissed the tenant’s counterclaim regarding the utility shutoff and, following the Minnesota Court of Appeals’ decision in Westminster Corp. v. Anderson, held that the common law doctrine of waiver by acceptance of rent did not apply to rental payments made by a public housing agency. The district court found the tenant had materially breached the lease and did not address her retaliation defense. The Minnesota Court of Appeals affirmed the district court’s rulings on the waiver and breach issues but remanded for consideration of the retaliation defense.The Minnesota Supreme Court reviewed only the waiver issue. It overruled Westminster, holding that the common law rule—whereby a landlord who accepts rent with knowledge of a tenant’s breach waives the right to evict for that breach—applies equally to private and publicly subsidized tenancies. The court clarified that whether a landlord has accepted rent for purposes of this doctrine is a factual question, to be determined by the totality of the circumstances, including the landlord’s conduct after payment. The Supreme Court reversed the court of appeals and remanded for further proceedings. View "Hook & Ladder Apartments, L.P. v. Nalewaja" on Justia Law