Justia Minnesota Supreme Court Opinion Summaries

A 15-year-old girl, S.W., left her home in Anoka County, Minnesota, without permission to stay with her mother’s cousin, A.G., in Wisconsin, where A.G. lived with the defendant, Paulson. After using methamphetamine together, Paulson assaulted A.G., took S.W. to his family’s property in Stacy, Minnesota, and kept her there for two days, during which he threatened her, provided her with drugs, and sexually assaulted her. S.W. was eventually recovered in Anoka County, where she reported the kidnapping and assaults to police.Paulson was initially charged in Anoka County District Court with first- and second-degree criminal sexual conduct. He moved to dismiss, arguing the offenses occurred in Isanti County, not Anoka County. The district court denied the motion, finding venue proper in Anoka County under Minnesota Statutes section 627.15, since S.W. was found there. The State later amended the complaint to add a kidnapping charge, to which Paulson entered an Alford plea. He did not challenge venue for the new charge. The district court accepted the plea and imposed sentence. On appeal, Paulson argued that his plea was invalid because the factual basis did not establish that venue was proper in Anoka County as required by Minnesota Statutes section 627.01. The Minnesota Court of Appeals rejected this argument, holding that venue is not an element of the offense.The Minnesota Supreme Court reviewed whether the statutory venue requirement is an element of the offense for purposes of the accuracy requirement of a guilty plea. The court held that the venue requirement in section 627.01 is not an element of the offense, and therefore, the factual basis for Paulson’s guilty plea was sufficient even though it did not establish venue. The decision of the court of appeals was affirmed. View "State of Minnesota vs. Paulson" on Justia Law

Samuel Alejondro Torrez was arrested for driving while impaired and driving after license cancellation. Law enforcement obtained a search warrant to test Torrez’s blood or urine, which he refused. Torrez was charged with first-degree test refusal and driving after license cancellation. Before trial, Torrez requested the district court to instruct the jury that the State must prove the arresting officer had probable cause to believe he was driving while impaired. The district court denied this request, and the jury found Torrez guilty on both counts.The Minnesota Court of Appeals affirmed Torrez’s conviction, concluding that the district court did not abuse its discretion by not including a probable cause element in the jury instructions. The court reasoned that the issuance of the search warrant already established probable cause.The Minnesota Supreme Court reviewed whether Minnesota Statutes section 169A.20, subdivision 2(2), requires the State to prove that the arresting officer had probable cause to believe the defendant was driving while impaired. The court held that the plain language of the statute does not require the State to prove probable cause for the refusal of a blood or urine test when a search warrant is involved. The court affirmed the decision of the court of appeals, concluding that the district court did not err in its jury instructions. View "State v. Torrez" on Justia Law

In September 2015, Bobby Lykins suffered severe physical and cognitive injuries from a work-related explosion. In 2017, Lykins, his employer Anderson Contracting, Inc., and its insurer SFM Mutual Insurance Co. agreed to a workers’ compensation settlement. An addendum to the settlement was agreed upon in 2018. Both agreements were approved by a compensation judge. In 2022, a conservator was appointed for Lykins, who then petitioned the Workers’ Compensation Court of Appeals (WCCA) to set aside the settlements, alleging they were invalid due to Lykins’ incapacity at the time of signing and fraud by omission.The WCCA found that the evidence raised significant questions about Lykins’ capacity when he signed the settlements and referred the matter to a compensation judge for further fact-finding. The WCCA instructed that if the compensation judge found Lykins appeared to be incapacitated at the time of the settlements, the matter should be referred to district court for a determination of incapacity.The Minnesota Supreme Court reviewed the case and clarified that the WCCA has the authority under Minnesota Statutes section 176.521, subdivision 3, to set aside an award if the settlement is invalid under section 176.521, subdivision 1(a). The Court affirmed the WCCA’s decision to refer the matter for fact-finding but vacated the part of the WCCA’s decision that required referral to district court. The Supreme Court held that the workers’ compensation courts have the authority to determine whether Lykins was incapacitated when he signed the settlements. The case was affirmed in part and vacated in part. View "Lykins vs. Anderson Contracting, Inc." on Justia Law

Fred Karasov joined a fitness center operated by Calhoun Orange in 2017 and signed a "Client Intake Form" containing liability-shifting provisions. In 2019, Karasov suffered cardiac arrest during a workout at the center, resulting in significant brain injuries. Tina Lund, Karasov's conservator, sued Calhoun Orange, alleging negligence. The district court granted summary judgment to Calhoun Orange on Lund's claims of negligence, negligent undertaking, and medical negligence, citing the exculpatory language in the Client Intake Form. A jury found in favor of Calhoun Orange on Lund's claim of willful and wanton negligence.Lund appealed the district court's summary judgment decision. The Minnesota Court of Appeals affirmed the district court's ruling, holding that the Client Intake Form's indemnification clause was enforceable and barred Lund's claims of ordinary negligence. Lund then sought review from the Minnesota Supreme Court.The Minnesota Supreme Court reviewed whether the Client Intake Form was enforceable to shield Calhoun Orange from liability for its own negligence. The court held that the indemnification clause in the form, which explicitly stated that the client agreed to indemnify the fitness center for "all acts of active or passive negligence," was a clear and unequivocal expression of the parties' intent to shift liability for negligence. Therefore, the clause was enforceable under the strict construction standard, and Lund's claims of ordinary negligence were barred. The court affirmed the decision of the court of appeals, upholding the district court's grant of summary judgment to Calhoun Orange. View "Lund vs. Calhoun Orange, Inc." on Justia Law

A dispute arose over the authority of the Red Lake Watershed District (the District) to conduct improvement proceedings for Polk County Ditch 39, which lies within the District but under the drainage authority of the Polk County Board of Commissioners. In 2017, landowners filed a petition with the District to improve Ditch 39, aiming to increase its capacity and length to capture overflow from another ditch, Ditch 66. The District accepted the petition and initiated proceedings, but Keystone Township and several landowners challenged the District's order, arguing that the District lacked authority as the ditch was not transferred from the county.The district court granted summary judgment in favor of Keystone, ruling that the District did not have the authority to order the improvement because it had not taken over the ditch from the county. The court of appeals reversed this decision, concluding that the District had the authority to conduct the improvement proceedings and that the proceedings substantially conformed to statutory requirements.The Minnesota Supreme Court reviewed the case and affirmed the court of appeals' decision. The court held that under Minn. Stat. § 103D.625, subd. 4, the District was authorized to conduct improvement proceedings for Ditch 39 without first taking over the ditch from the county. The court also concluded that the District's proceedings conformed to the statutory requirements, despite the involvement of county officials being inconsistent with the Watershed Law. The court rejected Keystone's procedural challenges, including the timeliness of the property owners' report and the final hearing notice, affirming that these did not affect the District's authority to establish the improvement project. View "In the Matter of Keystone Township vs. Red Lake Watershed District," on Justia Law

Burnsville Medical Building, LLC owns a three-story medical office building in Burnsville, Minnesota. Dakota County assessed the value of the property for 2021 taxes at $8,007,800. The taxpayer challenged this assessment, arguing that it overstated the property's value. The property was 25 years old, with 47,894 square feet of rentable space and an occupancy rate of 90.13 percent. The taxpayer presented an appraisal report by Kelsey K. Hornig, who used both the sales comparison approach and the income capitalization approach to value the property at $7,075,000 and $7,175,000, respectively.The Minnesota Tax Court held a trial and found that the taxpayer's appraisal overcame the prima facie validity of Dakota County's assessment. However, the tax court rejected Hornig's occupancy adjustment under the sales comparison approach, finding her testimony not credible and her adjustments internally inconsistent. The tax court also rejected Hornig's use of effective net rent to calculate potential gross income under the income capitalization approach, determining that the taxpayer did not present sufficient evidence to support reducing potential gross income by tenant improvement allowances or free rent.The Minnesota Supreme Court reviewed the case and affirmed the tax court's decision. The Supreme Court held that the tax court did not err in using market rent rather than effective net rent to calculate the property's potential gross income, as there was no evidence that the tenant improvement allowances or rent concessions were excessive or atypical. The Supreme Court also upheld the tax court's rejection of Hornig's occupancy adjustment, finding no clear error in the tax court's credibility determinations and factual findings. The final valuation of the property was set at $9,300,000. View "Burnsville Medical Building, LLC vs. County of Dakota" on Justia Law

Joanne Ecklund received long-term care services through Minnesota’s Medicaid program, the Minnesota Medical Assistance Program (MMAP). The Minnesota Department of Human Services (DHS) paid $66,052.62 in capitated payments to Medica, Ecklund’s managed care organization (MCO), which in turn paid $8,806.84 to care providers for Ecklund’s services. After Ecklund’s death in 2021, DHS sought to recover the $66,052.62 from her estate under Minnesota Statutes section 256B.15, subdivision 2(a)(1), which allows recovery of medical assistance payments for long-term care services provided to recipients aged 55 or older.The district court, adopting a referee’s recommendation, granted summary judgment in favor of the estate’s personal representative, Jerry Ecklund, limiting DHS’s recovery to the $8,806.84 paid by Medica to the care providers. The Minnesota Court of Appeals affirmed, interpreting the statute to limit DHS’s recovery to the amount actually paid to the providers.The Minnesota Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that Minnesota Statutes section 256B.15, subdivision 2(a)(1), allows DHS to recover the amount of capitation payments made to the MCO for long-term care services provided to the recipient. The court reasoned that the statute’s language and the broader statutory context support DHS’s interpretation, which aligns with federal guidance requiring states to recover capitation payments. The court concluded that DHS is entitled to recover the $66,052.62 in capitated payments from Ecklund’s estate. View "In re the Estate of: Ecklund" on Justia Law

Rodney Dean Bjornson, the relator, suffered two injuries while employed by McNeilus Companies, Inc. He received treatment at Mayo Clinic, with expenses paid by United Healthcare Services. Bjornson's attorney, David C. Wulff, sought Roraff fees for recovering medical benefits. The compensation judge awarded Wulff $49,000 in Roraff fees, finding that United paid $327,257.37 in medical benefits based on itemized medical bills from Mayo Clinic attached to Bjornson's Employee’s Claim Petition.The Workers’ Compensation Court of Appeals (WCCA) reviewed the case and concluded that the itemized bills from Mayo Clinic were not in the appellate record. The WCCA reversed the compensation judge’s award of Roraff fees due to insufficient evidence regarding the bills and modified the Roraff fees to $500, as per the statutory formula for unascertainable benefits amounts.The Minnesota Supreme Court reviewed the case to determine if Wulff presented sufficient evidence of the ascertainable dollar value of medical benefits. The court found that the WCCA did not assess whether the remaining evidence, including Wulff’s testimony and exhibits, was adequate to support the compensation judge’s conclusion. The Supreme Court reversed the WCCA's decision and remanded the case for further proceedings. The WCCA was directed to clarify whether the itemized medical bills were actual bills or a summary document and to determine if the evidence in the record was adequate to support the compensation judge’s conclusion. View "Bjornson v. McNeilus Companies, Inc." on Justia Law

The State charged Larry Joe Foster with second-degree intentional murder for the death of Daniel Bradley. Foster claimed that another person, R.J., committed the murder. The district court determined that Foster met the requirements to present an alternative perpetrator defense and allowed him to introduce evidence supporting his claim. Foster intended to call R.J. as a witness, but R.J. invoked his right against self-incrimination before the trial. Foster requested that R.J. be required to invoke this right in front of the jury, but the district court denied the request, citing the lack of probative value and the cumulative nature of the evidence.The jury found Foster guilty of second-degree murder. Foster appealed, arguing that the district court violated his constitutional rights by not allowing him to call R.J. to the stand. The Minnesota Court of Appeals affirmed Foster’s conviction, concluding that he had no constitutional right to call R.J. solely to invoke his right against self-incrimination.The Minnesota Supreme Court reviewed the case and held that when a defendant has satisfied the required test to present an alternative perpetrator defense, the district court has discretion to allow the defendant to call the alternative perpetrator as a witness, even if it is known that the alternative perpetrator will invoke their right against self-incrimination. However, the district court must apply the ordinary rules of evidence in making this determination. The Supreme Court concluded that the district court did not abuse its discretion in denying Foster’s request, as the invocation of the right against self-incrimination by R.J. would have been needlessly cumulative. The decision of the court of appeals was affirmed on different grounds. View "State v. Foster" on Justia Law

Eloisa Rubi Plancarte was convicted of misdemeanor indecent exposure under Minnesota Statutes section 617.23, subdivision 1(1) for exposing her breasts in a gas station parking lot. Plancarte argued that her breasts are not "private parts" under the statute and that her exposure was not "lewd." She also claimed that prosecuting her for conduct that men are allowed to engage in violated her constitutional right to equal protection. The district court denied her motion to dismiss, and she was found guilty in a stipulated-evidence trial.Plancarte appealed her conviction, but the court of appeals affirmed it in a divided opinion. The majority concluded that the evidence was sufficient to support the conviction, while the dissent argued that the statute requires lewd conduct in addition to exposure, which was not proven in this case.The Minnesota Supreme Court reviewed the case and concluded that the term "lewdly" in the statute refers to conduct of a sexual nature. The court found that the State did not present sufficient evidence to prove that Plancarte's exposure was lewd, as there was no indication that her conduct was of a sexual nature. Consequently, the court reversed Plancarte's conviction. The court did not address whether female breasts are "private parts" under the statute or the equal protection claim, as the decision on the lewdness element resolved the case. View "State v. Plancarte" on Justia Law