Justia Minnesota Supreme Court Opinion Summaries

The case centers on an incident in which Lisa Dawn Oliver was arrested following a violent confrontation involving her former partner, P.L., who had custody of their daughter. After Oliver and her friend attempted to take the child from P.L.’s apartment, an argument ensued. During the altercation, Oliver was alleged to have cut P.L.’s neck with a concealed weapon and was heard threatening to kill him. P.L. required medical treatment for the wound, but the injury did not meet the statutory definition of “great bodily harm.”Initially charged with attempted second-degree intentional murder, Oliver later faced additional charges of attempted first-degree assault-harm and second-degree assault with a dangerous weapon causing substantial bodily harm. A jury acquitted her of attempted murder but convicted her of both attempted first-degree assault-harm and second-degree assault. The Dakota County District Court entered a conviction for attempted first-degree assault-harm and sentenced Oliver to 45 months in prison.The Minnesota Court of Appeals reversed the conviction for attempted first-degree assault-harm, holding that such an offense does not exist under Minnesota law. The majority found that the statutory scheme for assault is based on harm inflicted rather than intended, and that the specific intent required for attempt crimes conflicted with the general intent element of first-degree assault-harm. The appellate court remanded for sentencing on the lesser second-degree assault conviction.The Minnesota Supreme Court reviewed the case and reversed the Court of Appeals. The Supreme Court held that attempted first-degree assault-harm, charged under the attempt statute, is a recognized crime in Minnesota. The Court ruled there is no statutory or logical conflict between the specific intent required for attempt and the general intent required for first-degree assault-harm. The case was remanded for the Court of Appeals to consider other issues not previously addressed. View "State of Minnesota vs. Oliver" on Justia Law

A man was charged with attempted first-degree premeditated murder and unlawful possession of a firearm following a shooting in Duluth. The victim could not identify the shooter, and evidence at the scene included two guns and DNA samples. Investigators initially obtained a search warrant for DNA samples from the suspect, but after the validity of that warrant was challenged in a co-defendant’s case, the State agreed not to use any evidence obtained from it. Instead, the State sought and received a court order under a Minnesota procedural rule to collect a buccal swab (cheek swab) from the defendant for DNA analysis. This DNA evidence, along with recorded jail calls and texts from an alleged accomplice, was presented at trial. The defendant was convicted by a jury and sentenced to prison.The Minnesota Court of Appeals reversed the convictions, holding that the warrantless collection of the buccal swab violated constitutional protections against unreasonable searches and seizures, and that this error was not harmless beyond a reasonable doubt. The court also held that the defendant was not entitled to a jury instruction requiring corroboration of accomplice testimony, because the accomplice’s statements were not made under oath.Upon review, the Minnesota Supreme Court agreed with the appellate court. It held that collecting a buccal swab for DNA analysis without a warrant or a valid exception constitutes an unreasonable search under both the United States and Minnesota Constitutions. The court rejected arguments that the procedural rule or a court order could replace a warrant, and found no applicable exception to the exclusionary rule. The court also clarified that the statutory term “testimony” in Minnesota’s accomplice-corroboration statute means only statements made under oath. The Supreme Court affirmed the reversal of the convictions and remanded for a new trial. View "State of Minnesota vs. Steeprock" on Justia Law

In August 2022, the appellants filed a complaint and petition in Rice County District Court, seeking to prevent the use of electronic voting machines with embedded modems in the upcoming November 2022 general election. They alleged that these machines were not properly certified or secure, in violation of Minnesota law, and requested an order restraining the county from using the modem functions during the election. The complaint named the Director of Rice County Property Tax and Elections as a defendant, and the Minnesota Secretary of State intervened as a party.The Rice County District Court dismissed the section 204B.44 claim in January 2023, citing several jurisdictional defects, including mootness because the 2022 election had already occurred, and insufficient service of process on all candidates as required by statute. The Minnesota Court of Appeals affirmed the dismissal, focusing on the lack of service to all candidates as the basis for its decision and did not address the other grounds identified by the district court.The Minnesota Supreme Court reviewed the case and held that the appellants’ claim under Minnesota Statutes section 204B.44 was moot because the relief sought pertained solely to the 2022 general election, which had already taken place. The court rejected the argument that the claim could be redirected to future elections and clarified that section 204B.44 challenges must be specific to a single election. The Supreme Court affirmed the decision of the Court of Appeals, but did so on the alternative ground of mootness, without reaching the issue of service of process on all candidates. View "Benda for Common-sense vs. Anderson" on Justia Law

After being involved in a head-on collision during a snowstorm, the appellant was detained by police on suspicion of driving while impaired. Law enforcement obtained a search warrant authorizing a blood test, but not a urine test. The appellant refused to submit to both the blood test (for which there was a warrant) and a urine test (for which there was not). He was subsequently charged with first-degree test refusal. The appellant moved to suppress evidence of his refusals and to dismiss the charge, arguing that the statutes required refusal of both tests to sustain a conviction and that, because there was no warrant for a urine test, his prosecution violated the Fourth Amendment.The District Court denied the appellant’s motion, concluding that the relevant statutes did not require warrants for both blood and urine tests to prosecute for test refusal. The appellant waived his right to a jury trial, and the District Court found him guilty of first-degree test refusal based on stipulated facts. On appeal, the Minnesota Court of Appeals affirmed the conviction, holding that the statutory language required only refusal of the test authorized by the warrant and that there was no requirement for law enforcement to obtain warrants for both types of tests.The Minnesota Supreme Court reviewed the case and held that when a warrant authorizes only one type of chemical test—either blood or urine—a person’s refusal to submit to that specific test is sufficient for a conviction under Minn. Stat. §§ 169A.20, subd. 2(2), and 171.177, subd. 2. The Court further held that a conviction for refusing a warranted chemical test does not violate the Fourth Amendment. The decision of the Court of Appeals was affirmed, though on different grounds. View "State of Minnesota vs. Lueck" on Justia Law

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