Justia Minnesota Supreme Court Opinion Summaries

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

Alex Lancaster, who operates an adult foster care program in his home, received a correction order from Olmsted County on behalf of the Minnesota Department of Human Services (DHS) after a home inspection. The correction order cited two violations: failure to provide resident access to the upstairs living room and dining area. Lancaster did not request reconsideration of the correction order within the 20-day deadline.Lancaster appealed the correction order to the Minnesota Court of Appeals by petitioning for a writ of certiorari. The court of appeals dismissed the appeal, determining that the correction order was not a quasi-judicial decision and therefore not appealable by writ of certiorari. Lancaster then petitioned for further review.The Minnesota Supreme Court reviewed the case to determine whether a DHS correction order is appealable by writ of certiorari. The court held that a correction order is not a judicial or quasi-judicial decision because it does not bind and irrevocably fix the legal rights of the license holder. Instead, it merely notifies the license holder of alleged violations and the possibility of future sanctions if the violations are not corrected. As a result, the correction order does not meet the criteria for a quasi-judicial decision, which includes a binding decision regarding a disputed claim.The Minnesota Supreme Court affirmed the court of appeals' dismissal of Lancaster’s appeal, concluding that the correction order was not appealable by writ of certiorari. View "Lancaster vs. Department of Human Services" on Justia Law

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