Justia Minnesota Supreme Court Opinion Summaries

A police officer attempted to stop a driver on a rural Minnesota highway shortly after midnight because he believed the van lacked a visible rear license plate or temporary registration. The driver, instead of stopping, turned on his hazard lights and continued driving for several miles with the officer in pursuit, ignoring repeated commands to stop. The pursuit ended only after additional officers joined and the driver stopped at a protest encampment. After his arrest, officers determined the van did have valid temporary registration, but the driver was charged with felony fleeing a peace officer in a motor vehicle.At trial in the District Court, the driver moved to suppress evidence of his flight, arguing that the initial traffic stop was unconstitutional and that the subsequent evidence of fleeing was “fruit of the poisonous tree.” The District Court denied the motion, finding the officer had an objective reason for the stop. A jury convicted the driver. On appeal, the Minnesota Court of Appeals held the traffic stop was unconstitutional but affirmed the conviction, concluding that the evidence of flight was admissible under existing law.The Minnesota Supreme Court reviewed whether, under the Minnesota Constitution, evidence of a defendant’s new crime—here, vehicular flight—committed in response to an unconstitutional seizure must be suppressed. The court held that courts should apply the four-factor attenuation test from State v. Warndahl to determine if such evidence is the fruit of the poisonous tree. Applying this test, the court found that the driver’s flight was an intervening act of free will that attenuated the connection to the unconstitutional stop, and thus, the exclusionary rule did not require suppression. The Supreme Court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

A police officer in Thief River Falls, Minnesota, attempted to stop Nicholas Engel’s van late at night because he did not see a rear license plate or visible temporary registration. Rather than pull over, Engel turned on his hazard lights and continued driving for several miles, despite the officer’s emergency lights, siren, and repeated verbal commands to stop. Engel eventually stopped only after additional officers arrived and boxed in his vehicle near a protest camp. He was arrested and charged with felony fleeing a peace officer in a motor vehicle.The Thief River Falls District Court denied Engel’s motion to suppress evidence of his vehicular flight, concluding the officer had an objective reason to initiate the stop. After a jury convicted Engel, the Minnesota Court of Appeals affirmed, though all panel members agreed the traffic stop was unconstitutional because the officer lacked reasonable, articulable suspicion for the stop. The majority held that suppression of evidence of Engel’s flight was not warranted, while the dissent argued that the flight was fruit of the unconstitutional seizure and should be suppressed.The Supreme Court of Minnesota reviewed the case to determine whether evidence of Engel’s vehicular flight, which constituted a new crime in response to an unconstitutional stop, must be suppressed under the exclusionary rule of the Minnesota Constitution. The court held that when a suspect commits a new crime after law enforcement commits a constitutional violation, courts must apply the four-factor attenuation test from State v. Warndahl to determine whether the evidence of the new crime is fruit of the poisonous tree. Applying this test, the court found Engel’s flight to be an intervening act not sufficiently connected to the unconstitutional stop to warrant suppression. The court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

The case involved the death of Sara Hagfors on April 9, 2021. Her husband, Keith D. Hagfors, sought to bring a wrongful death action on behalf of her next of kin. Eighteen days before the statute of limitations expired, he petitioned to be appointed as trustee, as required by Minnesota law. However, before receiving the appointment, he served a summons and complaint on several healthcare defendants, alleging wrongful death. He was officially appointed trustee five days later and then filed the complaint. He did not re-serve the summons after his appointment but before the limitations period expired.The Ramsey County District Court dismissed the complaint for lack of subject matter jurisdiction and failure to state a claim, concluding that Hagfors had not validly commenced the wrongful death action because he was not appointed trustee at the time of service. Hagfors attempted to have his appointment as trustee backdated via a nunc pro tunc order in the separate trustee proceeding, but the district court denied reconsideration, and Hagfors voluntarily dismissed any appeal related to that issue. The Minnesota Court of Appeals affirmed the district court, holding that serving the complaint before being appointed trustee rendered the action a nullity, and as an error-correcting court, it was bound by Minnesota Supreme Court precedent.The Minnesota Supreme Court reviewed the case to determine whether appointment as trustee is a condition precedent to commencing a wrongful death action under Minn. Stat. § 573.02. The court held that appointment as trustee is indeed a condition precedent to commencing such an action. Any attempt to begin a wrongful death action without being appointed trustee is a legal nullity, and subsequent appointment does not validate the original filing. The decision of the court of appeals was affirmed. View "Hagfors vs. Fairview Health Services" on Justia Law

In this case, the petitioner was convicted of second-degree unintentional felony murder, attempted second-degree murder, and first-degree aggravated robbery in connection with a 2013 incident in Minneapolis. The petitioner and his accomplice planned to commit robberies, ultimately attempting to rob several individuals. During the course of these events, the petitioner handed a pistol to his accomplice, who then used it to fatally shoot one of the victims. The petitioner subsequently pleaded guilty to the charges based on an aiding-and-abetting theory of liability.Following legislative changes in 2023 and 2024 that narrowed the scope of criminal liability for aiding and abetting second-degree felony murder, the petitioner sought to vacate his conviction under a new statutory procedure. He argued that he was not a “major participant” in the underlying felony and did not act with “extreme indifference to human life.” The Hennepin County District Court denied the petition without holding an evidentiary hearing, finding that the petitioner’s actions met both statutory criteria. The Minnesota Court of Appeals affirmed, applying a reasonable-probability standard that defined “reasonable probability” as “a probability sufficient to undermine confidence in the outcome of the case,” and concluded that the petitioner’s entitlement to relief was refuted by the record.The Supreme Court of Minnesota reviewed the case and clarified that the “reasonable probability” standard it previously articulated in State v. Zielinski, 32 N.W.3d 847 (Minn. 2026), applies to denials of petitions under this statutory scheme. The court held that the standard used by the court of appeals differed materially from the Zielinski standard. Consequently, the Supreme Court reversed the decision of the court of appeals and remanded the case for further proceedings using the correct legal standard. View "Grant vs. State of Minnesota" on Justia Law

A nonprofit organization and two registered Minnesota voters challenged the state’s requirement that absentee voters obtain a witness certification in order to cast an absentee ballot. The organization assists its members with the absentee voting process. The plaintiffs argued that the requirement violates two federal laws: the Voting Rights Act, by conditioning the right to vote on a “voucher” from a witness, and the Civil Rights Act’s Materiality Provision, by potentially denying the right to vote based on errors or omissions in witness certifications that are not material to determining voter eligibility.The case began in district court, where the Secretary of State moved to dismiss, arguing the plaintiffs lacked standing and failed to state claims. The district court denied the motion, finding the organization had standing. It ruled that the plaintiffs stated a claim under the Voting Rights Act for unregistered voters and under the Civil Rights Act for registered voters. The Secretary then sought discretionary review. The Minnesota Court of Appeals concluded the organization had standing but held that the witness certification requirement did not violate either federal law, reversing the district court and remanding with instructions to dismiss the case.The Minnesota Supreme Court reviewed the appeal. It held that the witness certification does not violate the Voting Rights Act for unregistered voters because it does not require proving eligibility by the voucher of another; the witness merely attests to the presentation of residency documentation, not personal knowledge of the voter’s qualifications. The court also held that, as to registered voters, the witness certification is not a paper relating to an “act requisite to voting” under the Civil Rights Act’s Materiality Provision, as it does not pertain to a determination of voter eligibility. The Minnesota Supreme Court affirmed the decision of the Court of Appeals, concluding that the plaintiffs failed to state claims under either federal law. View "Minnesota Alliance for Retired Americans Educational Fund vs. Simon" on Justia Law

A sexual assault counselor employed by a nonprofit mental health organization was asked multiple times by her supervisors to disclose the location and information regarding a minor victim, whom law enforcement and county officials were seeking in connection with a probation violation. The counselor refused to provide this information without the victim’s consent, citing the statutory sexual-assault-counselor privilege. Despite her refusal, and after continued pressure, the counselor was ultimately terminated from her position. She then brought claims against her employer under the Minnesota Whistleblower Act and for common-law wrongful discharge, arguing that disclosing the information would have violated the sexual-assault-counselor privilege.The Washington County District Court granted the employer’s motion to dismiss for failure to state a claim, finding that the facts alleged did not support that the requested disclosure would violate the privilege statute. The Minnesota Court of Appeals affirmed, holding that the sexual-assault-counselor privilege is limited to disclosures made in the context of a court action or proceeding, or before someone authorized to receive evidence, and that the counselor had not alleged such circumstances.The Supreme Court of Minnesota affirmed the decision of the court of appeals. The court held that the sexual-assault-counselor privilege in Minnesota Statutes section 595.02, subdivision 1(k), applies only in an “action or proceeding, civil or criminal, in court or before any person who has authority to receive evidence.” Because the counselor did not allege she was ordered to disclose information in such a context, her claims under the Minnesota Whistleblower Act and for common-law wrongful discharge failed as a matter of law. The court declined to extend the privilege or recognize a broader common-law claim, emphasizing that any broader confidentiality protections would need to come from the legislature. View "Wredberg vs. Canvas Health, Inc." on Justia Law

After being discharged from employment as a painter in March 2024, the appellant applied for unemployment benefits. The Minnesota Department of Employment and Economic Development (DEED) determined that the appellant was ineligible for benefits due to employment misconduct and mailed a determination of ineligibility to his last known address on April 29, 2024, informing him of a 20-day appeal period. The appellant did not receive the determination within the allotted time because he was temporarily homeless following an eviction. He filed an appeal on June 20, 2024, after the 20-day deadline had passed, explaining his circumstances regarding late receipt of the notice.An unemployment law judge (ULJ) dismissed the appeal as untimely, stating there was no legal authority to consider the late appeal. The appellant requested reconsideration, reiterating his explanation and disputing the grounds for his discharge. The ULJ affirmed the dismissal as factually and legally correct. The appellant then petitioned the Minnesota Court of Appeals for a writ of certiorari. The Court of Appeals affirmed the ULJ’s dismissal, holding that there were no exceptions or extensions to the statutory appeal deadline under Minn. Stat. § 268.101, subd. 2(f).The Minnesota Supreme Court reviewed whether a ULJ may consider an explanation for a late appeal from a determination of ineligibility for unemployment benefits. The Court held that the statutory language is clear: a ULJ must dismiss an untimely appeal without discretion to consider mitigating circumstances or explanations for the late filing. As a result, the Supreme Court affirmed the decision of the Court of Appeals, confirming that the statutory appeal deadline is absolute and not subject to exceptions. View "Oslund vs. The Paint Genie, Inc." on Justia Law

The dispute centers on a closely held pharmaceutical company owned by members of the Evenstad family. In 2017, the family sold part of the business and reorganized the remaining assets into a new entity, ACOVA, Inc. Serene Warren, a beneficial owner of shares through family trusts, alleged that her interests were unfairly prejudiced during this process and subsequent redemption of shares. She sought a buyout of her interests in ACOVA under Minnesota Statutes section 302A.751, which provides relief in actions by shareholders against a corporation.The case began in Hennepin County District Court, where Warren filed multiple claims against ACOVA, her family members, and the family trustee. After a lengthy trial, the district court found unfairly prejudicial conduct by the respondents and ordered redemption payments to Warren’s trusts, along with final distributions to shareholders. Respondents later asserted that Warren lacked “statutory standing” under section 302A.751, arguing she was a beneficial owner, not a shareholder. The district court declined to address this argument, reasoning that the relief granted did not implicate the cited precedent.On appeal, the Minnesota Court of Appeals concluded that Warren lacked standing to pursue claims under section 302A.751 as she was not a shareholder, and held that this issue could not be waived because standing is jurisdictional. The court reversed the district court’s award of relief under section 302A.751 and remanded for further proceedings on alternative grounds for Warren’s standing.The Minnesota Supreme Court reviewed whether Warren’s status as a beneficial owner affected her standing and whether the respondents’ challenge was waived. The Court held that Warren had injury-in-fact standing, and her status as a shareholder only affected the legal sufficiency of her claims, which could be forfeited by respondents if not timely raised. The Court concluded respondents had forfeited their challenge, reversed the Court of Appeals’ decision, and remanded for further proceedings. View "Warren vs. ACOVA, Inc." on Justia Law

The dispute concerns property owners whose buildings sustained storm damage and were insured under a policy with an appraisal clause and a two-year limitations period for legal action. Four days before the limitations period expired, the owners filed insurance claims and requested that the insurer toll the limitations period. Two days before expiration, they demanded appraisal. When the insurer had not responded to either demand by the expiration date, the owners sued, seeking declaratory relief regarding coverage and appraisal and asserting that future denial of their demands would constitute breach of contract.The Rice County District Court dismissed the complaint without prejudice, finding no justiciable controversy to support either the declaratory judgment or breach-of-contract claims, thereby lacking subject matter jurisdiction. The Minnesota Court of Appeals affirmed dismissal of the breach-of-contract claim but reversed as to the declaratory judgment claim, concluding that the complaint sufficiently alleged a justiciable controversy for declaratory relief and remanded that claim for further proceedings.Upon review, the Minnesota Supreme Court held that neither claim presented a justiciable controversy. The Court determined that merely alleging a demand for appraisal and tolling, and noting the insurer’s lack of agreement, did not establish an actual conflict or imminent injury, especially since the insurer was not yet obligated to respond under the policy’s terms. Similarly, for the breach-of-contract claim, the Court found that allegations of hypothetical future breaches did not suffice for justiciability. The Supreme Court affirmed the appellate court’s dismissal of the breach-of-contract claim and reversed its reinstatement of the declaratory judgment claim, reinstating the district court’s order dismissing both claims. View "CVC Investments LLP vs. State Farm Fire and Casualty Company" on Justia Law

A homeowner contracted with a builder to construct a new home. Towards the end of the project, the homeowner raised concerns about defects in the work, including gaps in the roof fascia, the basement floor’s appearance, and stair damage. When the builder failed to resolve these issues, the homeowner withheld payments. The builder responded by filing a mechanic’s lien against the property and suing to enforce the lien, as well as for breach of contract. The homeowner counterclaimed for breach of contract and negligence, also asserting affirmative defenses that damages should offset any amounts owed.The Hennepin County District Court held a jury trial. The jury found that the homeowner breached the contract and awarded damages to the builder, but also found the builder negligent and awarded greater damages to the homeowner. The district court determined that the mechanic’s lien was valid in the amount of the jury award to the builder but was fully offset by the homeowner’s negligence damages. Despite this offset, the district court awarded the builder attorney fees and costs under Minnesota Statutes section 514.14. The Minnesota Court of Appeals affirmed, holding that the negligence claim did not support a recoupment defense and that the district court did not abuse its discretion awarding attorney fees.The Minnesota Supreme Court reviewed the case. It held that when a homeowner’s recoupment defense eliminates a contractor’s mechanic’s lien because the damages caused by negligent construction exceed the lien amount, the lien is extinguished. Therefore, the lien cannot serve as the basis for an award of attorney fees and costs to the contractor under Minnesota Statutes section 514.14. The Supreme Court reversed the Court of Appeals and remanded the case to the district court for proceedings consistent with its opinion. View "Sustainable 9, LLC vs. Coleman" on Justia Law