Justia Minnesota Supreme Court Opinion Summaries

A woman with a history of serious mental illness was civilly committed after being found incompetent to stand trial for a criminal vehicular homicide. She was diagnosed with schizoaffective disorder, bipolar type, and persistent psychosis, and resided in a secure state hospital. After multiple unsuccessful attempts with medication and therapy, her treating psychiatrist petitioned the district court for authorization to administer electroconvulsive therapy (ECT), asserting it was necessary due to her refractory symptoms and inability to consent.The District Court for Dakota County appointed two examiners, both of whom agreed that ECT was medically necessary and reasonable under the Price v. Sheppard balancing test, which weighs the patient’s need for treatment against the intrusiveness of the prescribed treatment. After considering the examiners’ reports and testimony, the district court authorized ECT, finding clear and convincing evidence that the treatment was necessary and reasonable. The patient appealed, arguing that the district court erred by not separately analyzing whether ECT was “necessary to preserve [her] life or health” as required by Minn. Stat. § 253B.03, subd. 6(b). The Minnesota Court of Appeals affirmed, holding that the Price/Jarvis balancing test subsumed the statutory requirement.The Minnesota Supreme Court reviewed whether the Price/Jarvis balancing test adequately addresses the statutory language requiring that treatment be “necessary to preserve the life or health” of a committed patient. The court held that the balancing test does address this requirement, as it requires a court to determine that treatment is both necessary and reasonable. Therefore, the Supreme Court affirmed the decision of the court of appeals, upholding the district court’s authorization of ECT. View "In the Matter of the Civil Commitment of: Graeber" on Justia Law

The taxpayer owned a residential property in Hennepin County, Minnesota, and disputed the county's valuation assessments for the property covering years 2018 through 2023. The taxpayer alleged that county officials overvalued his property by failing to consider environmental factors, misclassifying its location, and improperly using computer algorithms. He claimed the valuation process was discriminatory due to his disability and asserted violations of both federal and state law. His complaint, filed in Hennepin County District Court, sought monetary damages, injunctive relief, and a public apology.Respondents moved to dismiss or transfer the case to the Minnesota Tax Court. The district court determined that all claims related to the property’s valuation or the assessment process fell under Minnesota’s tax laws and chapter 278, and transferred the case, including pending motions, to the tax court. The tax court dismissed four enumerated counts in the complaint (unjust enrichment, malfeasance, disability discrimination, and constitutional rights violations), ruling they were property tax assessment claims subject to the exclusive remedy of chapter 278. Claims for valuation years 2018–2021 were time-barred, and the 2023 claim was dismissed without prejudice, leaving only the 2022 valuation claim for trial.The Minnesota Supreme Court reviewed the case, considering whether the tax court had subject matter jurisdiction, whether dismissal of the four counts was proper, and whether the trial dismissal of the 2022 valuation claim was correct. The court held that the tax court had jurisdiction because the district court properly transferred the case and all claims arose under tax law. It affirmed that chapter 278 provides the exclusive remedy for property tax assessment claims and that the taxpayer failed to present substantial evidence to overcome the statutory presumption of the county’s assessed value. The Supreme Court affirmed the tax court’s decision. View "Lockhart vs. Hennepin County" on Justia Law

Twin infants who are eligible for tribal membership were placed in emergency foster care with licensed, non-tribal foster parents after being born with serious medical issues. The county obtained temporary legal custody of the children through a Child in Need of Protection or Services (CHIPS) proceeding, and the children were eventually moved from the foster parents’ home to the home of maternal relatives who are members of the same tribe as the children. The foster parents, after learning of the planned move, sought to intervene permissively in the CHIPS case, filed a third-party custody petition, and moved to stay the placement change, arguing in part that tribal placement preference statutes were unconstitutional.The Minnesota District Court denied the foster parents’ motions to intervene and for a stay, and dismissed the third-party custody petition without considering their constitutional arguments. The Minnesota Court of Appeals affirmed in part, reversed in part, and remanded. It directed the district court to reconsider intervention and third-party custody, and addressed the constitutionality of the Minnesota Indian Family Preservation Act (MIFPA), finding it constitutional. On remand, the district court again denied intervention and dismissed the third-party custody petition, concluding the foster parents were not proper parties and could not file such petitions in the ongoing CHIPS proceeding.The Minnesota Supreme Court consolidated the appeals. It held that the district court did not abuse its discretion in denying permissive intervention, as such intervention was not in the children’s best interests. The court also held that a third-party custody petition is not available in juvenile court CHIPS proceedings and may only be brought as a petition to transfer custody by a party to the action. Because the foster parents were not parties, the court declined to address their constitutional challenges to ICWA and MIFPA, and vacated the Court of Appeals’ discussion of those constitutional issues. The court affirmed in part, vacated in part, and remanded for further proceedings. View "In the Matter of the Welfare of the Children of: L.K." on Justia Law

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