Justia Minnesota Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the court of appeals concluding that a Blakely violation committed by the district court at a sentencing hearing was harmless beyond a reasonable doubt, holding that the Blakely violation was harmless beyond a reasonable doubt.After a jury trial, Defendant was found guilty to two counts of criminal sexual conduct. The complaint alleged that the offenses were committed sometime between 2004 and 2018, but at sentencing, the district court determined that Defendant's offenses were committed after August 1, 2006. The court of appeals affirmed Defendant's sentence, concluding (1) the lower court's determination of Defendant's offense dates was a violation of Blakely v. Washington, 542 U.S. 196 (2004), and its progeny; but (2) the error was harmless. The Supreme Court affirmed, holding that although the district court erred in determining that date of Defendant's offense without receiving a Blakely waiver from Defendant, but the error was harmless beyond a reasonable doubt. View "State v. Reimer" on Justia Law

Posted in: Criminal Law
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In this property dispute, the Supreme Court affirmed in part and reversed in part the decision of the court of appeals determining that Joseph and Jennifer Roach's appeal was not barred by their acceptance of a remittitur on future damages and that the Roaches could seek attorney fees, holding that attorney fees were not authorized under the watershed statute, Minn. Stat. 103D.545, subd. 3.The Roaches, whose home was damaged during the construction of a home on property owned by Thomas and Sandra Alinder, brought nuisance and other claims against the Alinders and the company that built the home. After years of litigation, a jury trial was held to address damages. The jury awarded the Roaches damages. The Roaches moved for attorney fees. The district court denied the motion on the grounds that section 103D.545, subd. 3, did not apply. The district court further conditionally ordered a new trial unless the Roaches accepted a remittitur of the future damages award to zero. The Roaches accepted the remittitur and appealed the denial of attorney fees. The Supreme Court held (1) the Roaches were permitted to appeal issues separate and distinct from the subject of the remittitur order; but (2) attorney fees were not authorized under the statute. View "Roach v. County of Becker" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily denying Appellant's third petition for postconviction relief as untimely, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of first-degree murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed Defendant's conviction and sentence on direct appeal. In 2017, Defendant filed an unsuccessful petition for postconviction relief. In 2019, more than two years after his conviction became final, Defendant filed a second petition for postconviction relief that was also unsuccessful. In 2020, Defendant filed his third petition for postconviction relief. The district court determined that the claim was time-barred under Minn. Stat. 590.01, subd. 4(a) and denied relief. The Supreme Court affirmed, holding that Defendant's third petition for postconviction relief was untimely. View "Griffin v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court determining that the district court, and not the arbitrator, was to decide whether the parties' dispute was subject to arbitration, holding that the district court correctly concluded that the parties' dispute was not subject to arbitration.Glacier Park Iron Ore Properties, LLC alleged that United States Steel Corporation (U.S. Steel) aided and abetted a breach of the fiduciary duty of Great Northern Iron Ore Properties Trust and sought recession of a lease that U.S. Steel signed with the Trust. Glacier Park filed a motion to stay proceedings pending arbitration and to compel the parties to engage in arbitration. The district court denied the motion, concluding that the court, not arbitrators, should decide the meaning of the arbitration clause at issue in this case and, thus, the arbitrability of the dispute. The district court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding that because there was not clear and unmistakable evidence that the parties intended to delegate arbitrability to the arbitrator, whether the parties' breach of fiduciary claim was arbitrable was a question for the court. View "Glacier Park Iron Ore Properties, LLC, v. United States Steel Corp." on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals holding that the City of Waconia's ordinance was subject to the procedural requirements of Minn. Stat. 462.357 for municipal zoning, including notice and a public hearing.After Appellants began building a dock extending from their lakeshore property into the lake the City adopted an ordinance that prohibited the construction of the dock. When the construction was nearly complete the City filed a complaint seeking a permanent injunction under the new ordinance to halt further construction and require the dock's removal. The district court granted summary judgment for the City. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Appellants' appeal was timely; (2) the City's ordinance was subject to the procedural requirements of section 462.357; and (3) because the City failed to comply with the procedural requirements of section 462.357, the ordinance was void, and the permanent injunction against Appellants was also void. View "City of Waconia v. Dock" on Justia Law

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In this landlord-tenant dispute, the Supreme Court reversed the decision of the court of appeals affirming the district court's denial of Tenant's claim for treble damages under Minn. Stat. 504B.231, holding that remand was required for the court of appeals to address one remaining issue left unaddressed by its decision.Landlord resorted to self-help measures to remove Tenant from a residential premises. Tenant filed a petition for possession of residential rental property following unlawful removal under Minn. Stat. 504B.375 (the lockout petition) and sought treble damages for ouster under section 504B.231. The district court dismissed the lockout petition, concluding that Tenant was not a "residential tenant" and that Landlord did not act in bad faith. The court of appeals affirmed. The Supreme Court reversed, holding (1) to recover treble damages under section 504B.231, tenants must established that their landlord removed them from a residential premises unlawfully and in bad faith; and (2) remand was required for the court of appeals to determined whether Tenant was a tenant under section 504B.231(a). View "Reimringer v. Anderson" on Justia Law

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The Supreme Court affirmed in part and reversed in part Defendant's conviction of first-degree premeditated murder, second-degree intentional murder, and being an ineligible person in possession of a firearm, holding that the entry of a conviction for the offense of second-degree intentional murder violated Minn. Stat. 609.04.Specifically, the Supreme Court held (1) the district court did not err in denying two requests for advisory counsel to assume full representation of Defendant's defense because Defendant did not make a valid request; (2) the record supported the district court's finding that Defendant voluntarily waived his right to counsel; and (3) the district court violated section 609.04 when it entered a conviction for the offense of second-degree intentional murder. View "State v. Woods" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the district court dismissing Plaintiff's election contest filed under Minn. Stat. 209.021, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) Plaintiff was not prejudiced by the delay in providing notice of the election contest to the Chief Justice; (2) Plaintiff's claim asserting a violation of her civil rights under the Voting Rights Act, 52 U.S.C. 10101, was not properly asserted on appeal; and (3) the district court did not err in dismissing Plaintiff's election contest for failure to state a legally sufficient claim upon which relief could be granted. View "Bergstrom v. McEwen" on Justia Law

Posted in: Election Law
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The Supreme Court reversed the judgment of the district court amending a spousal maintenance award granting in favor of Respondent, Appellant's former wife, holding that the district court abused its discretion in deciding it could not consider the principal of certain cash gifts as an available source of income for spousal maintenance.After almost five years of dissolution-related court proceedings, Appellant moved to eliminate or amend a spousal maintenance award granted in favor of Respondent on the ground that there had been a substantial change of circumstances making the initial award "unreasonable and unfair." The motion stemmed, in part, from two cash gifts given to Appellant by her parents after the divorce totaling $500,000. The district court concluded that the spousal maintenance statute prohibited it from considering the principal of the cash gifts as a financial resource available for Appellant's self-support. The court of appeals affirmed. The Supreme Court reversed, holding that post-dissolution gifts received by a maintenance recipient are a financial resource a district court may consider under the spousal maintenance statute. View "Honke v. Honke" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of theft under a principal theory of criminal liability and of being an indelible person in possession of a firearm, holding that the district court erred when it failed to conduct a Confrontation Clause analysis surrounding the testimonial statement of a nontestifying co-conspirator, but the error was harmless.On appeal, Defendant argued that the district court violated his right to confrontation by admitting his co-conspirator's statements to the police when Defendant had no opportunity to cross-examine his co-conspirator. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the district court violated Defendant's right to confrontation when it admitted the disputed statements into evidence at trial; but (2) the violation of the Confrontation Clause was harmless beyond a reasonable doubt. View "State v. Sutter" on Justia Law