Justia Minnesota Supreme Court Opinion Summaries

A state trooper brought his patrol vehicle to a car dealership for service, accompanied by his canine, Diesel. During the visit, Diesel attacked and injured an employee, Cristina Berrier, without provocation. Berrier suffered serious injuries and subsequently sued the Minnesota State Patrol, alleging negligence and later indicating her intention to pursue a claim under Minnesota’s strict liability dog-bite statute, Minn. Stat. § 347.22.The district court denied the State Patrol’s motion to dismiss, concluding that Berrier’s complaint sufficiently pleaded her statutory claim and that the dog-bite statute waived sovereign immunity. The State Patrol appealed, and the Minnesota Court of Appeals reversed, holding that the State Patrol was immune from suit under the doctrine of sovereign immunity. The appellate court did not address whether Berrier adequately pleaded her statutory dog-bite claim.The Minnesota Supreme Court reviewed the case to determine if the dog-bite statute waived sovereign immunity. The court concluded that the language of Minn. Stat. § 347.22, which imposes liability on the "owner" of a dog, was sufficiently plain, clear, and unmistakable to waive sovereign immunity. The court emphasized that the statute’s broad application to any dog owner, including state entities, served the public policy interest of protecting individuals from dog attacks and ensuring their full recovery. Consequently, the court reversed the appellate court’s decision and remanded the case for further proceedings. View "Hennesy vs. Minnesota State Patrol" on Justia Law

In December 2015, Sean Michael Wocelka’s daughter disclosed during a forensic interview that her father had touched her intimate parts using a toy giraffe. The incident occurred shortly before Christmas. Officers found the toy giraffe in Wocelka’s home, and he was charged with three counts of second-degree criminal sexual conduct. At trial, Wocelka’s daughter testified consistently with her initial statement. The jury found Wocelka guilty of two counts of second-degree criminal sexual conduct for the December 2015 incident.The district court convicted Wocelka of one count under Minnesota Statutes section 609.343, subdivision 1(a), which criminalizes sexual contact with a complainant under 13 years old by an actor more than 36 months older. Wocelka petitioned for postconviction relief, arguing that his conduct did not meet the statutory definition of “sexual contact.” The district court denied the petition as untimely and on the merits. The Minnesota Court of Appeals affirmed the district court’s decision on the merits without addressing the timeliness issue.The Minnesota Supreme Court reviewed the case to determine whether the use of an object to make contact with a complainant’s intimate parts constitutes “sexual contact” under Minnesota Statutes section 609.341, subdivision 11(a)(i). The court held that the term “touching” includes bringing an object into contact with the complainant’s intimate parts. Therefore, the court affirmed that Wocelka’s actions met the statutory definition of “sexual contact” and upheld his conviction for second-degree criminal sexual conduct. View "Wocelka vs. State of Minnesota" on Justia Law

Pedro and Aida Alonzo filed a personal injury lawsuit against Richard Menholt and Menholt Farms, alleging negligent selection of an independent contractor. The case arose from an accident where Alberto Lopez, a driver for Braaten Farms, crossed the centerline and collided with Pedro Alonzo's semi-truck, causing serious injuries. Lopez had a suspended license and a history of driving offenses. Menholt Farms had hired Braaten Farms to haul sugar beets, but neither Menholt Farms nor Braaten Farms conducted thorough background checks on Lopez.The district court granted summary judgment in favor of Menholt Farms, recognizing the tort of negligent selection of an independent contractor but finding no genuine issue of material fact regarding Menholt Farms's alleged negligence. The court concluded that Menholt Farms had no duty to inquire into Braaten Farms's hiring practices or Lopez's qualifications. The Minnesota Court of Appeals affirmed the district court's decision, holding that Minnesota does not recognize the claim and that, even if it did, no genuine issue of material fact existed.The Minnesota Supreme Court reviewed the case and recognized the tort of negligent selection of an independent contractor under Minnesota common law. The court noted that the tort is supported by the Restatement (Second) of Torts and is analogous to other recognized claims like negligent hiring. However, the court was evenly divided on whether the district court erred in granting summary judgment, leading to an affirmation of the lower court's decision by default. The court emphasized that the duty of care in selecting an independent contractor depends on the risk involved and the nature of the work, requiring a higher degree of care for more dangerous or specialized tasks. View "Alonzo vs. Menholt" on Justia Law

The case revolves around Harry Jerome Evans, who was convicted of first-degree murder of a peace officer in 2006. The officer, Sergeant Gerald Vick, was shot during an undercover investigation at a bar in Saint Paul. Evans was identified as the shooter by Sergeant Joseph Strong, who was with Vick at the time, and by a trial witness. Evans's cousin, A.K., also testified that Evans had shot Vick. Evans claimed that A.K. was the actual shooter and that Vick was not performing official duties at the time of the shooting due to his intoxication. Evans was sentenced to life in prison without the possibility of release.Evans appealed his conviction multiple times in both state and federal courts. His appeals were consistently denied, with courts rejecting his claims of ineffective assistance of counsel, prosecutorial misconduct, and allegations that A.K. had admitted to being the actual shooter. Evans also filed petitions for postconviction relief and motions to correct his sentence, all of which were denied.In the current petition, Evans sought postconviction relief, arguing that his petition met the newly-discovered-evidence and interests-of-justice exceptions to the statutory time bar. The district court denied the petition, concluding that the facts alleged in the petition did not meet either exception. Evans appealed this decision.The Minnesota Supreme Court affirmed the district court's decision. The court found that Evans's petition did not meet the requirements of the newly-discovered-evidence exception, as the evidence was either not new, not exonerating, or was known or knowable by Evans at the time of trial. The court also found that Evans's petition did not meet the requirements of the interests-of-justice exception, as Evans did not allege that an injustice prevented him from filing his petition in a timely manner. View "Evans vs. State" on Justia Law

The case revolves around a dispute over a family farm in Minnesota. Richard and Paulette Dunn entered into a contract for deed with their son, Rory, for the sale of their family farm. The contract stipulated that Rory could not sell, assign, or otherwise transfer his interest in the farm without the Dunns' written consent. However, Rory died two years later without a will, and his interest in the farm was transferred to his young son by intestate succession. Jeffrey Kuhn, the personal representative of Rory’s estate, intended to divide the property and sell a portion of the farm on the open market. The Dunns responded by cancelling the contract for deed, arguing that the intestate transfer of Rory’s interest to his son without their consent was a breach of the contract.The district court ruled in favor of the Dunns, stating that the intestate transfer of Rory’s interest in the farm violated the consent-to-transfer provision and materially breached the contract for deed. However, the court of appeals reversed this decision, concluding that the intestate transfer of Rory’s estate as a result of Rory’s inaction did not violate the consent-to-transfer provision.The Minnesota Supreme Court was asked to decide whether an intestate transfer of an interest in a family farm breaches a consent-to-transfer provision in a contract for deed. The court held that the intestate transfer of Rory’s interest in the farm violated the consent-to-transfer provision and that this violation was a material breach of the contract for deed. Therefore, the court reversed the decision of the court of appeals. View "Kuhn vs. Dunn" on Justia Law

The case involves Nicholas Sterry, an inmate at the Moose Lake Correctional Facility, who filed a lawsuit against the Minnesota Department of Corrections (DOC) and Correctional Officer Ashley Youngberg. Sterry alleged that Youngberg sexually assaulted and harassed him while he was working in the prison kitchen. The DOC was aware of Youngberg's history of harassment but had not disciplined her prior to the incidents involving Sterry. Sterry's lawsuit included claims of battery, intentional and negligent infliction of emotional distress, and negligence under a theory of vicarious liability.The district court dismissed Sterry's claims, concluding that the DOC was immune from the suit under the Minnesota State Tort Claims Act because Youngberg was not acting within the scope of her employment when the alleged assault occurred. Sterry appealed this decision, and the court of appeals reversed the district court's ruling. The court of appeals found that Sterry's complaint alleged sufficient facts to survive the motion to dismiss, as it was consistent with common law principles of vicarious liability applicable to private employers.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court held that a state employer could be held vicariously liable for an employee’s intentional tort under the Minnesota State Tort Claims Act if the tort is related to the duties of the employee and occurs within work-related limits of time and place. The court also found that Sterry's complaint alleged sufficient facts to survive the DOC's motion to dismiss. The court concluded that Sterry's claim could allow a jury to find that Youngberg was acting within the scope of her employment when the alleged assault occurred, under circumstances where the DOC would be liable under common law for vicarious liability. View "Sterry v. Minnesota Department of Corrections" on Justia Law

The case revolves around a dispute over attorney fees awarded under Minnesota Statutes section 117.031(a) in an eminent domain proceeding. The State of Minnesota, through the Department of Transportation (MnDOT), seized a portion of Joseph Hamlin's property under the "quick take" provision of Minnesota eminent domain law. Hamlin was awarded attorney fees after the compensation he received was more than 40% greater than MnDOT's final offer. The attorney fees awarded exceeded the amount Hamlin owed his attorney under a contingent fee agreement.MnDOT appealed the district court's decision, arguing that the term "reasonable" in section 117.031(a) should limit the attorney fee award to the amount owed in the contingent fee agreement. The district court had applied the lodestar method (a method for calculating attorney fees based on the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate) and awarded Hamlin $63,228 in attorney fees. The court of appeals affirmed the district court's decision, holding that "reasonable attorney fees" in section 117.031(a) are calculated under the lodestar method and are not limited by any existing agreement between the landowner and his attorney.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court reiterated its previous holding in County of Dakota v. Cameron that "reasonable attorney fees" in section 117.031(a) refers to attorney fees calculated by the lodestar method. Therefore, an award of reasonable attorney fees is not capped by a contingent fee agreement. The court concluded that a landowner's fee agreement with their attorney does not limit an award of attorney fees because "reasonable attorney fees" under section 117.031(a) means attorney fees calculated using the lodestar method. View "State v. Schaffer" on Justia Law

The case revolves around the appellant, McKinley Juner Phillips, who was convicted of first-degree premeditated murder and second-degree intentional murder for the stabbing death of his wife, Shavon Phillips. The appellant had conceded at trial that he caused the death of his wife but had requested that the jury be given instructions for first-degree heat-of-passion manslaughter in addition to the instructions for first-degree premeditated murder and second-degree intentional murder. The district court denied the requested instruction, reasoning that the evidence did not support a heat-of-passion instruction.The appellant appealed the district court's decision, arguing that the court committed reversible error by denying the requested instruction. The appellant's argument was based on the premise that the jury's finding of premeditation does not necessarily preclude a finding of heat-of-passion.The Minnesota Supreme Court, however, affirmed the district court's decision. The Supreme Court held that the appellant was not prejudiced by the district court’s decision not to instruct the jury on first-degree heat-of-passion manslaughter because the court gave instructions on both first-degree premeditated murder and second-degree intentional murder and the jury found the appellant guilty of first-degree premeditated murder. The court reasoned that the mental states of premeditation and heat of passion cannot coexist, and since the jury found the appellant guilty of premeditated murder, it would not have found him guilty of heat-of-passion manslaughter. View "Phillips v. State" on Justia Law

The case revolves around Tokvan Ly, a man suffering from severe mental illness, who was incarcerated in the Scott County Jail. The district court found Ly incompetent to face criminal proceedings and ordered him committed to the care of the appellant, Jodi Harpstead, the Commissioner of Human Services. The law requires that persons in Ly's position be prioritized for admission to state-operated treatment programs and be admitted within 48 hours. However, Ly was not admitted within this timeframe. Fifteen days after his commitment, Ly remained in jail and was not receiving the specialized treatment needed for his severe mental illness. Consequently, he filed a petition for writs of mandamus and habeas corpus, alleging that the Commissioner was failing to comply with a mandatory duty to admit him to treatment within 48 hours under the Priority Admission statute and seeking damages resulting from his delayed admission to treatment.The district court issued a peremptory writ of mandamus that determined the Commissioner’s liability solely on the facts as alleged in Ly’s petition, and set the issue of mandamus damages for a fact trial. The Commissioner appealed the district court’s order, contending that she could immediately appeal the order before entry of final judgment. The court of appeals disagreed and dismissed the appeal for lack of jurisdiction.The Minnesota Supreme Court concluded that the basis for appeal from an order issuing a peremptory writ of mandamus under Rule 103.03(g) has been extinguished, and that appeal must instead proceed from a final judgment under Minn. R. Civ. App. P. 103.03(a). The court further concluded that an order issuing a peremptory writ is not appealable under Rule 103.03(a) as a form of irregular judgment, and that the district court order currently on appeal does not satisfy the finality requirement of that rule. However, the court invoked its inherent authority and its authority under Minn. R. Civ. App. P. 102 to suspend the final judgment requirement of Rule 103.03(a), reverse the decision of the court of appeals, exercise jurisdiction over the Commissioner’s underlying appeal, and remand to the court of appeals to consider the merits of the appeal. View "Ly v. Harpstead" on Justia Law

The case involves Angel Ignacio Sardina-Padilla, who was convicted of first-degree premeditated murder for the death of Jose Genis Cuate. Sardina-Padilla appealed the conviction, arguing that the district court erred in denying his motion to suppress evidence obtained from a warrant to search his Facebook accounts. He claimed that the warrant application failed to establish probable cause and did not satisfy minimal constitutional requirements for particularity. He also argued that the district court abused its discretion by summarily denying his petition for postconviction relief, which alleged ineffective assistance of counsel.The district court had denied Sardina-Padilla's motion to suppress the evidence obtained from the June warrant, concluding that the totality of the circumstances described in the June warrant application suggested that the accounts likely contained relevant evidence. The court also concluded that the June warrant satisfied minimal constitutional requirements for particularity.On appeal, the Supreme Court of Minnesota affirmed the district court's decision. The court found that the district court did not err in finding that the warrant application alleged that Sardina-Padilla asked someone to delete his Facebook account during a jail call. The court also concluded that the June warrant was sufficiently particular, considering the circumstances of the case, the nature of the crimes under investigation, and whether the officers could have provided a more precise description of the evidence sought. Finally, the court concluded that there was no reasonable probability that the trial’s outcome would have been different if counsel had successfully challenged the tracking data, and therefore, the district court did not abuse its discretion by summarily denying Sardina-Padilla’s petition for postconviction relief. View "State v. Sardina-Padilla" on Justia Law