Justia Minnesota Supreme Court Opinion Summaries

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

A commercial tenant in Minneapolis, Seven Acquisition LLC, operated its business in a building owned by 700 Hennepin Holdings LLC and subject to a mortgage held by a bank. After the landlord failed to repair a leaking roof, Seven withheld rent, leading to an eviction action. Seven prevailed in arbitration against the landlord and was awarded damages. The landlord then defaulted on the mortgage, prompting the bank to initiate foreclosure proceedings and request the appointment of Gregg Williams as receiver. Despite claims of independence, Seven alleged Williams had significant prior business with the bank’s agent. As receiver, Williams controlled the property, but Seven alleged he refused necessary repairs and acted to evict them for the bank’s benefit.In response, Seven sought to have Williams removed as receiver, arguing he was not independent and failed in his duties, but the Hennepin County District Court denied this motion as untimely and unsupported by good cause. Seven then filed a separate lawsuit against Williams, asserting negligence and breach of fiduciary duty. The district court dismissed the negligence claim based on quasi-judicial immunity, but allowed the fiduciary duty claim to proceed, finding factual questions regarding Williams’s independence and actions.Williams appealed, and the Minnesota Court of Appeals reversed, holding that quasi-judicial immunity protected Williams from suit for all actions taken within the scope of his receivership, regardless of motive or alleged conspiracy with the bank. The Supreme Court of Minnesota affirmed this decision. The court held that quasi-judicial immunity shields a court-appointed receiver from lawsuits for actions taken within the scope of the appointment, even if the receiver is alleged to have acted at the direction of a party or with improper motive. The complaint’s allegations were found insufficient to defeat this immunity. The decision of the court of appeals was affirmed. View "Seven Acquisition LLC vs. Williams" on Justia Law

Police officers investigated suspected fentanyl sales at an apartment in East Grand Forks, Minnesota, in 2022. After surveillance and a search warrant, they found Mohamed Abdulgani Ahmed at the apartment, arrested him, and discovered 775 fentanyl pills, cash, and Ahmed’s wallet in the bedroom closet. Forensic analysis confirmed the pills contained fentanyl weighing approximately 77.5 grams. Ahmed admitted to selling some fentanyl pills but denied knowledge of the large bag of pills. Text messages from Ahmed’s phone indicated involvement in fentanyl sales with his roommate, A.F., and others. Ahmed was charged with conspiracy to commit first-degree sale of controlled substances, first-degree sale, and second-degree possession of controlled substances.The District Court for Polk County entered convictions for all three counts after a jury trial. Ahmed appealed, arguing errors in the prosecution’s closing argument and other issues. The Minnesota Court of Appeals affirmed the convictions for conspiracy and sale but reversed and remanded for the district court to vacate the conviction for second-degree possession, as it was a lesser-included offense under Minnesota law.The Supreme Court of Minnesota reviewed whether the prosecutor’s statement—that the State need not prove Ahmed knew the conspiracy involved more than fifty grams of fentanyl—was plain error. The court held that, under Minnesota Statutes section 152.096 and its prior decision in State v. Kuhnau, the State must prove the defendant intended the commission of every element of the underlying offense, including the statutory weight threshold. The prosecutor’s misstatement was plain error affecting Ahmed’s substantial rights and was prejudicial. The Supreme Court reversed in part, vacated in part, and remanded for a new trial on all three challenged counts. View "State of Minnesota vs. Ahmed" on Justia Law

A 16-year-old girl disclosed to her high school advisor that her stepfather had sexually abused her, prompting a police investigation. The accused was charged with first-degree criminal sexual conduct, based on allegations that he committed multiple acts of sexual penetration against his minor stepdaughter over a period of about two years, beginning when she was around nine years old. The complainant described several acts of abuse, including cunnilingus and fellatio, occurring on different occasions and in different locations. Other family members and professionals testified about her disclosures and related observations. The defendant denied the allegations, and his defense emphasized inconsistencies in the complainant’s account and testimony from other relatives.After a jury trial, the Hennepin County District Court found the defendant guilty of both first- and second-degree criminal sexual conduct, entering judgment on the first-degree charge and sentencing him to 144 months in prison. The defendant appealed to the Minnesota Court of Appeals, arguing that the district court’s failure to provide a jury instruction requiring specific unanimity—that is, requiring jurors to agree on which specific act constituted the charged offense—constituted plain error. The Court of Appeals affirmed the conviction, relying in part on its prior decision in State v. Rucker, which held that a specific-unanimity instruction was not required under similar circumstances.The Supreme Court of Minnesota reviewed the case and held that, under its recent decision in State v. Keyes, when a single count is charged but the evidence involves multiple distinct acts, each capable of independently satisfying the statutory elements, a specific-unanimity jury instruction is required. The Court concluded that the district court’s failure to provide such an instruction was plain error that affected the defendant’s substantial rights. The Supreme Court of Minnesota reversed the first-degree conviction and remanded for a new trial on that charge. View "State of Minnesota vs. Yang" on Justia Law

A police officer with 25 years of service sought workers’ compensation benefits after being diagnosed with post-traumatic stress disorder (PTSD). The officer had experienced numerous traumatic events during his career and began psychological treatment in 2021. He was diagnosed with PTSD by a licensed psychologist, who relied on the DSM-5 for the diagnosis. The City, disputing the claim, had its own psychologist conduct an independent psychological evaluation (IPE) using the same DSM edition, who concluded that the officer did not meet the criteria for PTSD but instead had alcohol abuse disorder. Subsequently, the officer’s psychologist conducted a follow-up evaluation using the updated DSM-5-TR, issuing a “lifetime” PTSD diagnosis.A compensation judge found the officer entitled to a statutory presumption that his PTSD was work-related but determined that the City had rebutted this presumption, relying on the City’s expert’s opinion despite it being based on the earlier DSM-5. The judge found the City’s expert more persuasive and denied the officer’s claim for benefits.The Workers’ Compensation Court of Appeals (WCCA) vacated the compensation judge’s order, holding that the City’s expert opinion could not be considered because it was not based on the most recently published DSM edition. The WCCA ruled that only an IPE using the most recent DSM edition could rebut the statutory presumption and made its own finding that the City failed to rebut the presumption.The Minnesota Supreme Court reviewed the case. It held that the most recently published edition of the DSM includes text revisions, but an IPE is not the only way to rebut the statutory presumption. The Court also held that a compensation judge is not barred from considering an IPE based on an outdated DSM edition. The Supreme Court reversed the WCCA’s decision and remanded for consideration of additional arguments not previously addressed. View "Rowe vs. City of Minneapolis" on Justia Law

A homeowner hired a general contractor to perform a remodeling project, which included electrical work provided by a subcontractor. During construction, a fire occurred at the home, allegedly due to improper electrical work by both the general contractor and the subcontractor. The homeowner’s insurer paid for the fire damage and, acting as subrogee, brought a negligence and breach of contract action against both contractors. After the fire, the homeowner discontinued the services of both contractors and later hired a new general contractor to complete the project.The Minnesota District Court granted summary judgment in favor of the contractors, dismissing the insurer’s claims as time-barred under the two-year statute of limitations for defective construction claims involving improvements to real property, as set out in Minn. Stat. § 541.051, subd. 1. The district court found that the statute of limitations began to run when the homeowner terminated the contract with the original general contractor, concluding that the action was not timely filed.On appeal, the Minnesota Court of Appeals reversed the district court's decision. The appellate court interpreted the statute to mean that the statute of limitations does not begin until the entire construction project is terminated, substantially completed, or abandoned, not merely upon termination of the contract with the general contractor.The Supreme Court of Minnesota reviewed the case to resolve the statutory interpretation issue. The court held that, for purposes of the statute of limitations under Minn. Stat. § 541.051, subd. 1, the termination of the contract with the general contractor constitutes “termination … of the construction or the improvement to real property.” As a result, the Supreme Court reversed the Court of Appeals and reinstated the district court’s dismissal of the insurer’s claims as time-barred. View "American Family Insurance Company vs. NB Electric, Inc." on Justia Law

In 2016, Tyrel Patterson and three accomplices participated in a burglary and robbery that resulted in the death of James Herron. Patterson was indicted on two counts of first-degree felony murder and ultimately pleaded guilty to one count under an aiding and abetting theory. He admitted to planning and executing the robbery, being armed, and robbing a resident, but maintained he was outside the house when Herron was fatally shot. He was sentenced to life in prison with the possibility of release after 30 years.Years later, Patterson petitioned the Scott County District Court to vacate his conviction under a new Minnesota law (the Act) that provides relief for certain felony murder convictions based on aiding and abetting, if the defendant did not cause the death or intentionally aid with the intent to cause death. The district court initially found a reasonable probability that Patterson could be entitled to relief, but ultimately denied his petition without holding an evidentiary hearing. The court relied on transcripts and findings from the trial of a co-defendant, concluding that Patterson caused Herron’s death.The Supreme Court of Minnesota reviewed the district court’s denial for abuse of discretion. It held that the district court erred by making credibility determinations without first holding an evidentiary hearing, as required by precedent and the Act’s procedural framework. The court reversed the district court’s decision and remanded the case for an evidentiary hearing to properly resolve disputed material facts and assess the credibility of the parties. The main holding is that a district court cannot make credibility determinations in proceedings under the Act without first conducting an evidentiary hearing. View "Patterson vs. State of Minnesota" on Justia Law