Justia Minnesota Supreme Court Opinion Summaries

Michael Benson was civilly committed to the Minnesota Sex Offender Program in 1993. In 2020, he petitioned for a reduction in custody, which the Special Review Board recommended denying. Benson then sought a rehearing and reconsideration from the Commitment Appeal Panel (CAP). He filed a motion to cross-examine witnesses and participate in his defense, expressing a preference to proceed pro se. The CAP allowed limited cross-examination by Benson but required his appointed counsel to be present and conduct initial questioning. Benson refused to participate under these conditions, leading the CAP to dismiss his petition.Benson appealed to the Minnesota Court of Appeals, arguing that the right to counsel under Minnesota Statutes section 253D.20 is waivable. The court of appeals affirmed the CAP's decision, holding that the right to counsel in section 253D.20 is not waivable, based on its precedent. The court also noted that Benson forfeited his constitutional arguments by not raising them at the CAP hearing.The Minnesota Supreme Court reviewed the case to determine whether a civilly committed person can waive the right to counsel under section 253D.20. The court concluded that the right to counsel is waivable, provided the waiver is knowing and intelligent. The court found the statutory language ambiguous but interpreted it in light of legislative intent, common law, and constitutional considerations. The court reversed the court of appeals' decision and remanded the case to the CAP to determine if Benson's waiver of counsel was knowing and intelligent. If so, the CAP must allow him to represent himself. View "In re Matter of the Civil Commitment of Benson" on Justia Law

Matthew Eric Zinda filed a petition under Minn. Stat. § 204B.44, requesting that Steve Simon, Minnesota Secretary of State, and Deborah Erickson, Crow Wing County Auditor, exclude Josh Heintzeman from the 2024 primary and general election ballots for State Representative for Legislative District 6B. Heintzeman had filed an affidavit of candidacy listing his party as “Republican.” Zinda argued that Heintzeman did not seek the nomination of a major political party because he did not specify “Republican Party of Minnesota” and thus should not be on the primary ballot.The Minnesota Supreme Court directed the parties to file responses and memoranda. Zinda was the only other candidate who filed an affidavit of candidacy for the Republican primary for the same office, listing his party as “Republican Party of Minnesota.” The court noted that Heintzeman won the Republican primary and would appear on the general election ballot as the Republican candidate.The Minnesota Supreme Court held that Zinda did not prove that the respondents committed an error by placing Heintzeman on the primary ballot. The court found that the term “Republican” is understood to refer to the Republican Party of Minnesota, as Minnesota law precludes other parties from using the word “Republican” on the ballot. The court also concluded that Minn. Stat. § 204B.06, subd. 1, does not require candidates to list the full name of a major political party on their affidavit of candidacy. Therefore, the court denied Zinda’s petition, allowing Heintzeman to remain on the ballot as a Republican candidate. View "Zinda v. Simon" on Justia Law

The case involves Joseph Rued, who reported a potential sexual abuse incident involving his son to Scott County Health and Human Services. The County investigated and concluded that no abuse had occurred. Rued requested reconsideration, but the County upheld its initial finding. Rued then appealed to the Minnesota Department of Human Services (DHS) for a fair hearing, which was denied by the Commissioner based on a recommendation from a human services judge.Rued subsequently appealed the Commissioner’s decision to the Scott County District Court. Under Minnesota Statutes section 256.045, subdivision 7, an appeal must be served on the Commissioner and any adverse party of record within 30 days. Rued served the notice on the Commissioner but failed to serve Scott County. Despite this, a Scott County attorney appeared at the initial hearing and argued that the district court lacked jurisdiction due to the failure to serve the County. The district court ruled that the County had waived any objection to personal jurisdiction by appearing at the hearing and denied Rued’s request for appeal on the merits.The Minnesota Court of Appeals vacated the district court’s decision, holding that the failure to serve the County deprived the district court of subject matter jurisdiction. The court did not address whether Rued was entitled to a hearing on the no-maltreatment determination.The Minnesota Supreme Court reviewed the case and held that the 30-day time limit for serving a notice of appeal under section 256.045, subdivision 7, is a waivable limitations period, not a requirement for subject matter jurisdiction. The Court also clarified that adequate service of the notice of appeal is necessary for personal jurisdiction. The case was reversed and remanded to the district court to allow the County to either waive its defense related to the limitations period or move for dismissal on that basis. View "Rued vs. Commissioner of Human Services" on Justia Law

In February 2021, Timothy Heller moved into his brother's house in Hennepin County, where his girlfriend, Lacy Krube, joined him. Shortly after, Lacy was asked to leave. The next day, Lacy was found severely beaten and later died from a stomach injury. Heller was arrested and charged with first-degree domestic abuse murder. Evidence included Heller's past domestic abuse against multiple victims and a witness testimony that Heller admitted to hitting Lacy.The Hennepin County District Court convicted Heller of first-degree domestic abuse murder. Heller appealed, arguing errors in jury instructions, admission of past abuse evidence, expert testimony on lethality factors, and exclusion of alternative-perpetrator evidence. The district court had allowed evidence of Heller's past abuse, including a 2000 conviction for abusing J.L., and expert testimony on lethality factors, but excluded certain evidence related to Heller's alternative-perpetrator defense.The Minnesota Supreme Court reviewed the case. It held that any error in the venue instruction was harmless beyond a reasonable doubt. The court found that evidence of singular acts of abuse against different victims constituted a past pattern of domestic abuse under Minnesota law. The court also ruled that the district court did not abuse its discretion in admitting evidence of Heller's past abuse, as it showed a consistent pattern of behavior. However, the court found that admitting expert testimony on lethality factors was an error, but it was harmless. The court upheld the exclusion of certain alternative-perpetrator evidence, finding no abuse of discretion.The Minnesota Supreme Court affirmed the district court's decision, concluding that the errors identified did not significantly impact the verdict. View "State vs. Heller" on Justia Law

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