Justia Minnesota Supreme Court Opinion Summaries

Robert Lee Baker, III, was charged with second-degree intentional murder after he shot and killed Maurice Anderson. The incident occurred after Anderson and an accomplice robbed Baker and his girlfriend at gunpoint while they were in a car. As the robbers were leaving with Baker's property, Baker exited the car with a firearm and demanded the return of his belongings. Anderson raised his gun in response, and Baker shot him multiple times, resulting in Anderson's death.At trial, Baker claimed self-defense and defense of others, but the district court refused to instruct the jury on these defenses. The court concluded that Baker was not entitled to the instructions because he failed to establish that he was not the initial aggressor and that he did not have a reasonable means to retreat. The jury found Baker guilty of second-degree intentional murder, and he was sentenced to 438 months in prison. The court of appeals affirmed the conviction, but on different grounds, concluding that Baker's use of deadly force was unreasonable as a matter of law.The Minnesota Supreme Court reviewed the case to determine whether the district court abused its discretion by refusing to instruct the jury on self-defense and defense of others. The court held that the proper standard for determining whether a defendant is entitled to a jury instruction on self-defense or defense of others is whether the defendant produced reasonable evidence to support their claim. The court concluded that Baker presented sufficient evidence to support his claims of self-defense and defense of others, and that the district court's failure to give these instructions was not harmless. Therefore, the Minnesota Supreme Court reversed the decision of the court of appeals and remanded the case for a new trial. View "State of Minnesota vs. Baker" on Justia Law

Almanzo Cotton was found guilty by a jury of second-degree intentional murder and second-degree unintentional murder for beating his girlfriend, Kim Laen Theng, to death. The district court sentenced Cotton to 306 months imprisonment and ordered him to pay $2,362 in restitution to the Minnesota Crime Victims Reparations Board (the Board) to cover the cremation expenses paid by Theng’s daughter, S.T. S.T. had paid for the cremation using her personal credit card and later received funds from a GoFundMe campaign. She also submitted a claim to the Board, which awarded her the full amount of $2,362.Cotton challenged the restitution order, arguing that the GoFundMe proceeds should be considered a collateral source that offset the economic loss. The district court, however, concluded that the GoFundMe funds did not constitute recoupment of the cremation expenses from a collateral source and affirmed the restitution order. The court of appeals upheld the district court’s decision but remanded for the inclusion of a payment schedule.The Minnesota Supreme Court reviewed the case and held that the district court may not consider collateral sources when awarding restitution to the Board under Minn. Stat. § 611A.045, subd. 1(a). The court concluded that the exclusive factors for determining restitution are the amount of economic loss sustained by the victim and the income, resources, and obligations of the defendant. The collateral-source provision of the Minnesota Crime Victims Reparations Act does not apply in this context. The Supreme Court affirmed the decision of the court of appeals. View "State of Minnesota vs. Cotton" on Justia Law

Dontae White was convicted of second-degree intentional murder for the shooting death of Kevin Beasley. Beasley's mother, H.T., requested restitution for funeral expenses totaling $15,778.68. White argued that the life-insurance proceeds H.T. received should be subtracted from the restitution amount. The district court disagreed and ordered White to pay the full amount requested, reasoning that life insurance is intended to provide financial security and not just cover funeral expenses.The district court's decision was appealed, and the Minnesota Court of Appeals affirmed the restitution order. The court of appeals found that life insurance proceeds should not be considered when determining the amount of economic loss sustained by a family member of a deceased person for restitution purposes. The court distinguished life insurance from other types of insurance, noting that life insurance provides financial assistance beyond specific expenses like funeral costs.The Minnesota Supreme Court reviewed the case to determine whether life-insurance proceeds should be considered in calculating economic loss for restitution under Minn. Stat. § 611A.045, subd. 1(a)(1). The court held that life-insurance proceeds paid to a family member of the deceased should not be considered in determining the amount of economic loss sustained by the family member as a result of the murder. The court reasoned that life insurance is an investment contract intended to provide financial security, not merely to cover specific expenses. Therefore, the court affirmed the decision of the court of appeals, upholding the full restitution order. View "State of Minnesota vs. White" on Justia Law

Dakota Drug, Inc., a wholesale drug distributor, was subject to the Wholesale Drug Distributor Tax in Minnesota. The dispute arose over whether rebate amounts paid to Dakota Drug’s customers under rebate agreements should be included in the company’s “gross revenues” for tax purposes. Dakota Drug argued that these rebate amounts should not be included because they were contractually obligated to return the rebates to customers, either through account credits or checks.The Minnesota Tax Court reviewed the case and granted summary judgment in favor of Dakota Drug. The court determined that the rebate amounts did not constitute “gross revenues” as defined by Minn. Stat. § 295.50, subd. 3, which describes gross revenues as “total amounts received in money or otherwise.” The court concluded that Dakota Drug did not “receive” the rebate amounts because they were obligated to pay these amounts to customers once the rebates were earned.The Minnesota Supreme Court reviewed the case and affirmed the Tax Court’s decision. The Supreme Court held that under Minn. Stat. § 295.52, subd. 3, “gross revenues” do not include rebate amounts paid to a wholesale drug distributor’s customer pursuant to a rebate agreement. The court reasoned that Dakota Drug did not come into possession of the rebate amounts as they were contractually obligated to return these amounts to the customers. Therefore, the rebate amounts were not part of the “total amounts received in money or otherwise” and should not be included in Dakota Drug’s gross revenues for tax purposes. View "Dakota Drug, Inc. vs. Commissioner of Revenue" on Justia Law

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