Justia Minnesota Supreme Court Opinion Summaries

A man was found shot and killed on a snow-covered trail in Saint Louis County, Minnesota. The investigation quickly focused on three individuals: the appellant, his girlfriend, and another accomplice. Key evidence included the murder weapon, Facebook messages discussing plans to harm the victim, and DNA on the weapon matching the appellant. The girlfriend, who was an eyewitness, testified to having seen the appellant shoot the victim. Law enforcement obtained a warrant to search multiple Facebook accounts—those of the appellant, his girlfriend, and the other accomplice—uncovering messages implicating the appellant.After initially pleading guilty to first-degree murder, the appellant challenged the conviction in postconviction proceedings. The Minnesota Supreme Court in Bonnell v. State vacated the guilty plea, remanding the case for trial. Before trial, the appellant moved to suppress evidence from the Facebook searches, arguing that the warrant lacked specificity. The Saint Louis County District Court denied the motion and admitted the evidence at trial, over defense objection. The jury convicted the appellant of first-degree premeditated murder.On direct appeal, the Supreme Court of Minnesota held, as a matter of first impression, that a sender of an electronic message does not retain a reasonable expectation of privacy in a copy of the message stored in the recipient’s separate and independent account or device. Thus, the appellant’s Fourth Amendment protections were not triggered by searches of his accomplices’ Facebook accounts. However, the appellant did have a reasonable expectation of privacy in his own Facebook accounts, and the warrant authorizing those searches was invalid for lack of particularity. Despite this error, the court concluded it was harmless beyond a reasonable doubt because the remaining evidence was overwhelming. The court also found that any errors in admitting certain prior bad acts evidence were harmless. The conviction was affirmed. View "State of Minnesota vs. Bonnell" on Justia Law

The case involves an individual who was indicted for first-degree premeditated murder following the shooting death of his wife inside their shared home. The defendant did not dispute firing the fatal shot but claimed he did so during a struggle with an alleged intruder. Evidence at trial included a 911 call from the victim moments before her death, testimony regarding the absence of forced entry at the scene, the defendant’s financial difficulties leading to imminent home foreclosure and eviction, and his statements to police about the events and his actions that morning. There was also testimony about the trajectory of the gunshot, the state of the home, and the behavior of the defendant following the incident.A Ramsey County grand jury indicted the defendant, and he pleaded not guilty, electing a jury trial. At trial in Ramsey County District Court, the defendant twice moved for a judgment of acquittal before the verdict, arguing insufficient evidence; both motions were denied using the direct-evidence standard. The jury found the defendant guilty of first-degree premeditated murder, and the district court entered a conviction and imposed a life sentence without the possibility of release.On direct appeal, the Minnesota Supreme Court considered whether the circumstantial evidence was sufficient to support the conviction and whether the district court applied the correct standard in ruling on pre-verdict motions for acquittal. The Supreme Court held that the circumstantial evidence, when viewed as a whole, supported only the inference that the defendant caused his wife’s death with premeditation and intent. The Court also held that, when ruling on motions for acquittal made and decided before a verdict is returned, a district court should apply the direct-evidence standard, even if the case relies entirely on circumstantial evidence. The conviction was affirmed. View "State of Minnesota vs. Firkus" on Justia Law

A driver backed her car into a pedestrian in a bar parking lot shortly after the bar’s closing time. When police arrived, she admitted to drinking three beers before driving. The responding officers did not observe any signs of physical impairment, and the driver successfully completed an initial horizontal gaze nystagmus (HGN) test. Both officers expressed that they did not believe the driver was impaired, and one officer sought to administer a preliminary breath test (PBT) primarily to document his investigation. The driver initially declined the PBT but later consented after additional field sobriety tests indicated impairment; the PBT and a subsequent DataMaster test showed an alcohol concentration above the legal limit. The Commissioner of Public Safety revoked her driver’s license.The revocation was challenged in the District Court through an implied consent hearing. The court weighed all circumstances and found that, despite the absence of physical signs of impairment and the minor nature of the accident, the driver’s admission to drinking, the timing and location, and the fact she struck a pedestrian provided reasonable suspicion to request the PBT. The District Court upheld the license revocation. The Minnesota Court of Appeals reversed, reasoning that the initial reasonable suspicion was dispelled by the driver’s satisfactory HGN test and lack of physical indications of impairment.The Minnesota Supreme Court reviewed the case and applied a de novo standard to the District Court’s legal conclusion. The Supreme Court held that, under the totality of circumstances, the officer’s request for the PBT was supported by reasonable suspicion of impaired driving, which was not dispelled by other factors that diminished but did not conclusively negate suspicion. The Court reversed the decision of the Court of Appeals, reinstating the revocation. View "Lorsung vs. Commissioner of Public Safety" on Justia Law

Following a single-vehicle accident in Lino Lakes, Minnesota, law enforcement officers encountered the driver, who displayed signs consistent with alcohol consumption, including slurred speech and bloodshot eyes. After a preliminary breath test yielded insufficient samples but indicated alcohol presence, the driver was transported to a hospital. A trooper obtained a search warrant and requested blood or urine samples from the driver, but none were provided. The driver was subsequently charged with second-degree test refusal and third-degree driving while impaired.The Anoka County District Court held a jury trial where both officers and the driver testified with conflicting accounts regarding the hospital interaction. At the close of trial, the driver requested a jury instruction clarifying that the State must prove actual unwillingness to submit to testing, citing precedent from State v. Ferrier. The district court denied this request, instructing the jury only that refusal must be proven. The jury convicted the driver of test refusal but acquitted on the DWI charge. On appeal, the Minnesota Court of Appeals affirmed the conviction, holding that the district court’s instructions adequately stated the law and, even if erroneous, any error was harmless because of substantial evidence supporting refusal.The Minnesota Supreme Court reviewed whether the district court abused its discretion by denying the requested instruction. The Court held that when the jury is instructed that refusal must be proven, the district court does not abuse its discretion by declining to further instruct on “actual unwillingness.” The Court reasoned that the term “refuse” is commonly understood and does not require additional definition for jurors. Accordingly, the Supreme Court affirmed the Court of Appeals’ decision. View "State of Minnesota vs. Schmeichel" on Justia Law

Unity McGill was murdered on the dance floor of The Red Carpet Nightclub in St. Cloud, Minnesota, by three assailants who had previously been removed from the premises following an earlier assault but were permitted to reenter without adequate communication among staff or use of a metal detecting wand. The nightclub, operated by R.C. of St. Cloud, Inc., had policies to remove anyone involved in a fight, yet these protocols were not properly followed. McGill’s brother, Alvin Glay, acting as trustee for the next of kin, brought a wrongful death civil suit against R.C. under an innkeeper negligence theory, arguing that R.C. failed to use reasonable care to protect patrons.The Stearns County District Court denied summary judgment for R.C., finding that whether the attack was foreseeable was a close factual question suitable for a jury. At trial, the jury found R.C. negligent for failing to prevent McGill’s death but determined R.C.’s negligence was not the direct cause, and thus did not hold R.C. liable. Glay’s motion for a new trial was denied as to R.C.’s liability, but granted for damages against the assailants. The Minnesota Court of Appeals reversed the district court’s denial of a new trial on R.C.’s liability, finding the jury instructions on superseding intervening cause were confusing and prejudicial.The Minnesota Supreme Court reviewed whether the district court’s jury instruction on superseding intervening cause was erroneous and prejudicial. The Court held that Glay did not invite error in the instructions and that it was improper to instruct the jury on superseding intervening cause when the same conduct (the attack) was both the basis for innkeeper negligence and the alleged superseding cause. The jury instructions were found likely to confuse and mislead, and the error was prejudicial. The Supreme Court affirmed the Court of Appeals and ordered a new trial on R.C.’s liability. View "Glay vs. R.C. of St. Cloud, Inc." on Justia Law

A federally recognized tribe, which operates casinos under a tribal-state compact allowing video games of chance, objected when the Minnesota Racing Commission approved a 2023 amendment to a racetrack’s card club plan. This amendment allowed Running Aces Casino, Hotel & Racetrack to add an additional dealer table and 11 player stations featuring electronic table games. These electronic games use a live dealer and transmit images of physical cards to player stations, where patrons interact via video screens. Minnesota law limits commercial operation of such gambling devices and video games of chance to tribes and restricts the number of card tables at racetrack card clubs. The tribe argued that the Commission’s approval constituted an unlawful expansion of gambling, infringing upon its statutorily protected competitive environment.After the Racing Commission approved Running Aces’s request, the tribe petitioned the Minnesota Court of Appeals for review. The tribe contended that the Commission erred by permitting racetracks to operate devices reserved for tribes, by exceeding the statutory table limit, and by applying an unpromulgated rule. The Racing Commission and Running Aces challenged the tribe’s standing. The Minnesota Court of Appeals concluded that the tribe had standing due to its legally protected market-restricted interest, but rejected its arguments on the merits, affirming the Commission’s decision.On further appeal, the Minnesota Supreme Court reviewed the issue of standing de novo and held that the tribe does have standing to challenge the Commission’s decision, as the statutory scheme creates a competition-restricted environment protecting the tribe’s interest in operating video games of chance. However, because the Supreme Court was evenly divided on the merits of the tribe’s challenge to the Commission’s decision, it affirmed the Court of Appeals’ decision without expressing an opinion on those merits. View "In the Matter of the Minnesota Racing Commission's Approval of Running Aces Casino, Hotel & Racetrack's Request to Amend its Plan of Operation" on Justia Law

Employees of a property management company reported to the Minnesota Attorney General that their employer had failed to pay legally required wages and overtime, allegedly using subsidiaries to evade wage laws. Acting on these complaints, the Attorney General issued a civil investigative demand (CID) to the company and its subsidiaries in October 2019, seeking documents relevant to wage practices. The company challenged the CID in court, resulting in over three years of litigation before it ultimately provided the requested documents in July 2022. Following the conclusion of the CID litigation, the Attorney General filed a civil enforcement action in June 2023, alleging violations of the Minnesota Fair Labor Standards Act (MFLSA) related to wage theft.The Ramsey County District Court granted the company’s motion to dismiss the MFLSA claim under Minnesota Rule of Civil Procedure 12.02(e), finding the claim was barred by the two-year statute of limitations set forth in Minn. Stat. § 541.07(5). The court determined the claim accrued by late 2019, when the employees first came forward. The Minnesota Court of Appeals affirmed, rejecting the Attorney General’s argument that litigation over the CID should toll the limitations period, and citing a lack of precedent for such tolling.On review, the Minnesota Supreme Court held that litigation over a civil investigative demand issued under Minn. Stat. § 8.31 tolls the statute of limitations for a subsequent civil enforcement action, provided the CID and the enforcement action concern the same alleged unlawful practice. The Supreme Court reversed the dismissal of the MFLSA claim and remanded the case to the district court for further proceedings, establishing a narrow rule that tolling applies specifically during CID litigation under the Attorney General’s investigative authority. View "State of Minnesota v. Madison Equities, Inc." on Justia Law

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