Justia Minnesota Supreme Court Opinion Summaries

Julian Valdez was convicted of second-degree unintentional felony murder for fatally shooting Pablo Gutierrez, who was allegedly attacking Valdez's stepbrother. The incident occurred after Gutierrez, who appeared agitated and unarmed, entered Valdez's garage and later got into a physical altercation with Valdez's stepbrother. Valdez retrieved a gun and, during the altercation, shot Gutierrez once, resulting in his death. Valdez claimed he acted in defense of his stepbrother, who was being choked by Gutierrez.The district court instructed the jury that Valdez had a duty to retreat before using force in defense of his stepbrother. Valdez was found guilty of second-degree unintentional felony murder. He appealed, arguing that the district court's instruction was erroneous. The Minnesota Court of Appeals agreed, concluding that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat. The court of appeals reversed Valdez's conviction and remanded for a new trial, finding that the erroneous instruction was not harmless beyond a reasonable doubt.The Minnesota Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat before acting in defense of his stepbrother. The court clarified that, to justifiably use force in defense of another, a defendant must subjectively believe that the person in peril has no reasonable possibility of safe retreat, and that belief must be objectively reasonable based on the information available at the time. The court also concluded that the erroneous instruction was not harmless, as it could not be said beyond a reasonable doubt that the error had no significant impact on the verdict. Therefore, Valdez's conviction was reversed, and the case was remanded for a new trial. View "State vs. Valdez" on Justia Law

Craig Reichel, a businessperson from Rochester, Minnesota, and his companies, including Reichel Foods, Inc., filed a legal malpractice lawsuit against the law firm Wendland Utz, LTD, and its former lawyer, Jerrie Hayes. Reichel alleged that despite an ultimately favorable outcome in prior litigation, the law firm’s negligence caused him to incur substantial attorney fees and costs. The underlying litigation involved a lawsuit filed by Craig’s brother, Bryan Reichel, claiming an equity interest in one of Craig’s companies. The district court issued several adverse rulings against Craig and his companies, leading to significant legal expenses. Eventually, the bankruptcy court confirmed Craig’s sole ownership of the companies, and the district court granted summary judgment in Craig’s favor.The Olmsted County District Court granted partial summary judgment in favor of Wendland Utz, dismissing Reichel Foods’ professional negligence claim on the grounds that Reichel Foods could not demonstrate that, but for the law firm’s conduct, it would have been successful in the underlying litigation. The district court did not address Reichel Foods’ other claims for breach of contract and breach of fiduciary duty, nor did it resolve the claims brought by Craig Reichel and his other companies.The Minnesota Supreme Court reviewed the case and concluded that the court of appeals lacked jurisdiction to decide claims still pending in the district court. The Supreme Court vacated the court of appeals’ rulings on those claims. Regarding the professional negligence claim of Reichel Foods, the Supreme Court held that a successful outcome in the underlying litigation does not categorically bar a legal malpractice claim. The court reversed the decision of the court of appeals affirming summary judgment on Reichel Foods’ professional negligence claim and remanded the case for further proceedings. View "Reichel vs. Wendland Utz, LTD" on Justia Law

A business dispute arose between M&M Creative Laminants, Inc. (M&M), a Pennsylvania company, and Cambria Company, LLC (Cambria), a Minnesota company. Cambria manufactures and sells quartz surface products, while M&M sells custom countertops and cabinetry. In 2009, the two companies entered into a business relationship where M&M would purchase finished quartz products from Cambria. In 2017, Cambria terminated the relationship, claiming M&M owed over $180,000 for delivered products. Cambria sued for the unpaid amount, and M&M counterclaimed under the Minnesota Franchise Act, alleging unfair termination practices.The district court granted summary judgment for Cambria on M&M’s counterclaim, ruling that M&M did not pay a franchise fee, a requirement under the Act to qualify as a franchise. The court noted that payments for goods at a bona fide wholesale price are excluded from the definition of a franchise fee. The court of appeals affirmed, agreeing that M&M did not pay a franchise fee and additionally concluded that M&M, being an out-of-state company, was precluded from bringing a claim under the Act.The Minnesota Supreme Court reviewed the case and concluded that the Minnesota Franchise Act does not categorically preclude an out-of-state company from enforcing a claim for unfair practices. However, the court agreed with the lower courts that M&M did not pay a franchise fee. The court found that M&M’s payments to Cambria for finished quartz products were at a bona fide wholesale price and did not include a hidden franchise fee. Therefore, the relationship between M&M and Cambria did not constitute a franchise under the Act. The Supreme Court affirmed the grant of summary judgment for Cambria. View "Cambria Company, LLC vs. M&M Creative Laminants, Inc." on Justia Law

In the late evening of January 24, 2022, Brandon Moore was driving a car with expired registration tabs when he was pursued by police. After a brief chase, Moore was arrested. During the search, officers found over six grams of methamphetamine in Moore's pockets, $3,400 in cash in the car's center console, and a handgun along with more than 110 grams of methamphetamine in the locked glove compartment. The key to the glove compartment was in the ignition.Moore was charged with aggravated first-degree controlled substance crime (sale and possession) and ineligible possession of a firearm. The jury found Moore guilty on all counts. The district court entered convictions for ineligible possession of a firearm and aggravated first-degree controlled substance crime for sale, sentencing Moore to 98 months in prison. Moore appealed, arguing that the evidence was insufficient to prove the firearm was "within immediate reach" as required by the statute because it was in a locked glove compartment.The Minnesota Court of Appeals affirmed the conviction, interpreting "within immediate reach" to include both spatial and temporal proximity, meaning the firearm was accessible without delay and close at hand. Moore then petitioned the Minnesota Supreme Court, which reviewed whether the evidence was sufficient to prove the firearm was "within immediate reach."The Minnesota Supreme Court held that "within immediate reach" does not require instant accessibility. The court concluded that the evidence was sufficient to prove the firearm was within Moore's immediate reach because he was in the driver’s seat and the key to the glove compartment was in the ignition. Therefore, the court affirmed the decision of the court of appeals. View "State vs. Moore" on Justia Law

In 2015, the appellant sexually assaulted a 9-year-old girl, but the crime was not reported until 2021. In the interim, the appellant committed an unrelated second-degree assault in 2016, for which he was convicted in 2017. After the 2015 sexual assault was disclosed in 2021, the appellant was charged and convicted of second-degree criminal sexual conduct.The district court found the appellant guilty of two counts of second-degree criminal sexual conduct. During sentencing, the court applied a sentencing enhancement under Minnesota Statutes section 609.3455, subdivision 3a, classifying the appellant as an engrained offender due to his prior conviction for second-degree assault. This resulted in an upward durational departure of 250 months in prison with a lifetime conditional release term. The appellant appealed, arguing that the term "previously committed" in the statute should mean a predatory crime committed before the commission of the present offense, not before the sentencing determination.The Minnesota Court of Appeals affirmed the district court's decision, holding that the statute required only that the predatory crime be committed before the sentencing determination. The appellant then sought review from the Minnesota Supreme Court.The Minnesota Supreme Court affirmed the lower court's decision, holding that for enhanced sentencing under Minnesota Statutes section 609.3455, subdivision 3a, a predatory crime is considered "previously committed" if it is committed before the fact-finder's sentencing-related determination that the offender is a danger to public safety. The court concluded that the plain language of the statute supports this interpretation, and thus, the appellant's 2017 assault conviction qualified as a "previously committed" predatory crime for the purposes of sentencing enhancement. View "State vs. Balsley" on Justia Law

On August 10, 2021, Jeron Garding was arrested for first-degree narcotics charges after a drug-dog sniff of his parked car led to the discovery of approximately 410 grams of methamphetamine. Garding moved to suppress the evidence, arguing that law enforcement lacked reasonable, articulable suspicion to conduct the drug-dog sniff. The district court held a contested omnibus hearing where State Trooper Jacob Bredsten testified about his observations, including the suspicious behavior of Garding and his passenger, signs of the passenger’s recent drug use, and a plastic bag in the backseat that appeared to contain drugs.The district court denied Garding’s motion to suppress, finding that Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff based on the totality of the circumstances. Garding was subsequently convicted of first-degree possession of narcotics after a stipulated facts trial, preserving his right to appeal the suppression ruling. The Minnesota Court of Appeals reversed the district court’s decision, concluding that the trooper lacked reasonable, articulable suspicion to justify the drug-dog sniff.The Minnesota Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that, under the totality of the circumstances, Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff. The court emphasized that the combination of the passenger’s signs of recent drug use, the appearance of the plastic bag in the backseat, and Garding’s flight to the woods provided sufficient grounds for the suspicion. Therefore, the district court did not err in denying Garding’s motion to suppress the evidence obtained from the search. View "State v. Garding" on Justia Law

Renee Vasko challenged her property tax assessment on two grounds: the revocation of her homestead classification and the assessed value of her property. In 2018, McLeod County sent a homestead application to Vasko’s property address, which was returned as undeliverable. The County learned from the City of Lester Prairie that there had been no measurable water use at the property since 2016. Consequently, the County revoked the homestead classification effective January 2, 2019, and assessed the property at $110,100.Vasko filed a petition in the Minnesota Tax Court, disputing the revocation of the homestead classification and the property’s assessed value. She presented evidence, including mail addressed to the property, utility records, and testimony, to establish occupancy and use of the property. Vasko also compared her property’s valuation to five other properties in the City to argue that her home was overvalued. The Tax Court found that Vasko did not occupy and use the property as a homestead in 2019 and upheld the County’s valuation, concluding that Vasko did not provide sufficient evidence to rebut the presumptive validity of the County’s assessment.The Minnesota Supreme Court reviewed the case and affirmed the Tax Court’s decision. The Court held that the Tax Court correctly placed the burden of proof on Vasko to show that the revocation of the homestead classification was unlawful and that the assessed value was incorrect. The Supreme Court found no clear error in the Tax Court’s findings that Vasko did not occupy and use the property as a homestead and that she failed to provide substantial evidence to challenge the County’s valuation. The decision of the Tax Court was affirmed. View "Vasko vs. County of McLeod" on Justia Law

A charter school was accused of manipulating attendance records to receive excess state aid. The Minnesota Department of Education (the Department) audited the school based on these allegations and found significant discrepancies, leading to a retroactive reduction in aid by over $1.3 million. The school appealed the audit results administratively, but the Department upheld its decision.The school then appealed to the Minnesota Court of Appeals, arguing that the Department should have investigated the allegations under a statute dealing with violations of law (Minn. Stat. § 127A.42) rather than the statute used for auditing aid distributions (Minn. Stat. § 127A.41). The Court of Appeals affirmed the Department's decision, stating that the Department had the authority to conduct the audit under the statute it used.The Minnesota Supreme Court reviewed the case to determine whether the Department was required to investigate under the statute related to violations of law. The court held that the Department had the statutory authority to audit the school under Minn. Stat. § 127A.41 and was not required to investigate under Minn. Stat. § 127A.42, even though the allegations involved potentially illegal activity. The court affirmed the decision of the Court of Appeals, concluding that the Department's actions were within its legal authority. View "Minnesota Internship Center vs. Minnesota Department of Education" on Justia Law

The case involves a challenge to the Re-Enfranchisement Act, which allows individuals convicted of felony-level offenses to vote once they are no longer incarcerated. The plaintiffs, individual taxpayers and the Minnesota Voters Alliance, argued that the Act violates the Minnesota Constitution by restoring only the right to vote rather than all civil rights. They also claimed that using public funds to educate and notify people about the new voting provision is unlawful if the Act itself is unconstitutional.The district court denied the petition, concluding that the plaintiffs lacked standing. The court determined that taxpayer standing requires a challenge to an illegal expenditure or waste of tax money, which the plaintiffs failed to demonstrate. The court also found that the Minnesota Voters Alliance lacked associational standing because its members did not have standing.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court clarified that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. The court held that the plaintiffs could not manufacture standing by pointing to incidental expenditures related to implementing the law. Since the plaintiffs' challenge was primarily against the substantive law itself and not the expenditures, they lacked the necessary standing. Consequently, the Minnesota Voters Alliance also lacked associational standing. The court did not address the merits of the case due to the lack of standing. View "Minnesota Voters Alliance vs. Hunt" on Justia Law

A Wisconsin-based corporation, Uline, Inc., sells industrial and packaging products and employs sales representatives who visit customers in Minnesota. Uline did not pay Minnesota income or franchise taxes for 2014 and 2015, claiming exemption under 15 U.S.C. § 381, which protects certain out-of-state business activities from state taxation. The Minnesota Commissioner of Revenue audited Uline and assessed taxes for those years, arguing that Uline's activities in Minnesota went beyond mere solicitation of orders.The Minnesota Tax Court upheld the tax assessment, finding that Uline's sales representatives engaged in activities beyond solicitation, specifically the preparation of "Market News Notes," which included detailed market research and competitor information. Uline appealed, arguing that these activities were either protected solicitation or de minimis and thus not subject to state taxation.The Minnesota Supreme Court reviewed the case to determine whether Uline's activities created a sufficient nexus with Minnesota to justify the imposition of state taxes. The court found that the preparation of Market News Notes by Uline's sales team went beyond the solicitation of orders because it involved detailed market research that served independent business functions. The court also determined that these activities were not de minimis, as they were regular and systematic, with over 1,600 Market News Notes prepared during the two years in question.The Minnesota Supreme Court affirmed the tax court's decision, holding that Uline's activities in Minnesota were not protected from state income or franchise taxation under 15 U.S.C. § 381 and were not de minimis. Therefore, Uline was subject to Minnesota state taxes for the years 2014 and 2015. View "Uline, Inc. vs. Commissioner of Revenue" on Justia Law