Justia Minnesota Supreme Court Opinion Summaries

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The Supreme Court affirmed the decision of the court of appeals holding that a law enforcement officer lawfully expanded the scope of the underlying traffic stop in this case, holding the court of appeals did not err.Defendant was convicted of first-degree driving while impaired and possessing an opened bottle or receptacle containing an alcoholic beverage. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence because the officer impermissibly expanded the scope of the underlying traffic stop by asking Defendant if he had consumed any beer from the open case in his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances known to the officer and the legitimate inferences to be drawn from them raised a reasonable articulable suspicion of other criminal activity sufficient to expand the scope of the traffic stop. View "State v. Taylor" on Justia Law

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The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) upholding a compensation judge's order requiring Employer to reimburse Employee for medical cannabis, holding that the WCCA erred.Employee was injured while working for Employer. After multiple rounds of medical intervention proved to be unsuccessful, Employee's doctor certified her for participation in the state's medical cannabis program. Employee sought reimbursement for the cost of the cannabis from Employer. Employer asserted in response that the federal prohibition in the federal Controlled Substances Act (CSA), 21 U.S.C. 801-971, on the possession of cannabis preempted the requirement under Minnesota law that an employer pay for an injured employee's medical treatment when that treatment is medical cannabis. The WCCA declined to address the preemption argument and upheld the compensation judge's order. The Supreme Court reversed, holding (1) the WCCA lacked subject matter jurisdiction to determine the preemption issue; and (2) the CSA preempted the compensation court's order mandating Employer to pay for Employee's medical cannabis. View "Musta v. Mendota Heights Dental Center & Hartford Insurance Group" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily denying Appellant's claims for postconviction relief, holding that the district court did not abuse its discretion.After a jury trial, Defendant was convicted of first-degree premeditated murder as a principal and as an aider and abettor and sentenced to life in prison without the possibility of release. Defendant later moved for postconviction relief, alleging that the State committed Brady violations during his criminal trial and other grounds for relief. The district court denied Defendant's petition for postconviction relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant was not entitled to relief on his claims for postconviction relief. View "Thoresen v. State" on Justia Law

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The Supreme Court reversed the decision of the workers' compensation court of appeals (WCCA) affirming the decision of the compensation judge granting Respondent's claim petition seeking reimbursement from his former employer for the cost of medical cannabis, holding that the WCCA erred.At issue before the Supreme Court was whether the WCCA correctly concluded that it lacked subject matter jurisdiction to decide arguments that require interpreting federal law and whether the federal Controlled Substances Act (CSA), 21 U.S.C. 801-971, preempts the requirement in Minnesota law for an employer to reimburse an injured employee for the cost of medical treatment, Minn. Stat. 176.135, subd. 1(a). The Supreme Court held (1) the WCCA lacked subject matter jurisdiction to decide whether the relevant federal law preempted the relevant Minnesota law in this case; and (2) the CSA preempted the compensation court's order mandating Relators to pay for Respondent's medical cannabis. View "Bierbach v. Digger's Polaris" on Justia Law

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The Supreme Court reversed Defendant's conviction of depraved-mind murder and remanded this case to the district court for Defendant to be sentenced on a second-degree manslaughter conviction, holding that Defendant could not be convicted of depraved-mind murder.Justine Ruszczyk called the police out of concern for a woman she heard screaming, but when Ruszczyk approached the police vehicle that came in response to her call, Defendant fired his service weapon at her from the passenger seat. A jury acquitted Defendant of second-degree intentional murder but found him guilty of third-degree depraved-mind murder and second-degree manslaughter. At issue was whether, in addition to second-degree manslaughter, Defendant could also be convicted of depraved-mind murder. The Supreme Court held that he could not and reversed his conviction. View "State v. Noor" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree criminal sexual conduct, holding that the modified plain error doctrine was not satisfied in this case.On appeal, Defendant argued that a statement made by the prosecutor during his jury trial required reversal of his conviction and a new trial. At issue was the prosecutor's statement to the jury during closing argument that a unanimous verdict on one element of the offense - specifically, whether Defendant acted with force or with coercion to accomplish the act of sexual penetration - was not required. The court of appeals affirmed, holding (1) the phrase "force or coercion in Minn. Stat. 609.342(a)(e)(i) sets forth alternative means for completing the sexual penetration element of the offense; and (2) therefore, a unanimous jury verdict on whether Defendant used force or coercion was not necessary. The Supreme Court affirmed, holding that no relief was warranted in this case. View "State v. Epps" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirmed Defendant's conviction but remanding the case to the district court for Defendant to be resentenced in accordance with modified guidelines, holding that the court of appeals did not err.Defendant was convicted and sentenced for criminal sexual conduct. At issue on appeal was whether a Minnesota Sentencing Guideline and associated commentary adopted by the Minnesota Sentencing Guidelines Commission but not ratified by the Legislature could abrogate the common law amelioration doctrine, which applies to a statute that mitigates the punishment for "acts committed before its effective date, as long as no final judgment has been reached." The court of appeals held (1) unratified statements by the Minnesota Sentencing Guidelines Commission could not abrogate the amelioration doctrine because they did not constitute a "statement by the Legislature"; and (2) Defendant was entitled to the benefit of a change in the Sentencing Guidelines adopted by the Commission in 2019, which resulted in a reduction of Defendant's criminal history score. The Supreme Court affirmed, holding that Defendant was entitled to resentencing under the amelioration doctrine. View "State v. Robinette" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the court of appeals reversing the decision of the district court granting Defendant's motion to suppress his statements to his probation officer and a polygraph administrator about his criminal conduct, holding that suppression of the statements was not required.Specifically, the Supreme Court held (1) Defendant made the statements at issue without invoking his constitutional privilege against self-incrimination, and the penalty exception to the general rule that a person cannot assert the privilege against self-incrimination without first invoking the privilege did not apply; (2) the portion of Minn. Stat. 634.03 requiring exclusion of confessions "made under the influence of fear produced by threats" excludes confessions made under circumstances where the inducement to speak was such that there was a fair risk that the confession was false; and (3) exclusion of Defendant's statements was not required in this case. View "State v. McCoy" on Justia Law

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The Supreme Court affirmed the judgment of the Tax Court upholding that constitutionality of the Minnesota sales or use tax for aircraft purchases, holding that Minn. Const. art. X, 5 bars only the application of duplicative personal property taxes to aircraft.Article X, section 5 allows the Legislature to tax aircraft using the airspace over Minnesota "in lieu of all other taxes." Relators purchased aircraft outside of the state, paid the use tax, paid a separate annual tax imposed on aircraft, and then requested a refund of the use tax. When the refunds were denied, Relators sued the Department of Revenue, arguing that the use tax is unconstitutional under Minn. Const. art. X, 5. The Tax Court granted summary judgment for the Commissioner of Revenue. The Supreme Court affirmed, holding (1) the phrase "[a]ny such tax on aircraft shall be in lieu of all other taxes," as used in article X, section 5, prohibits only the application of duplicative personal property taxes on aircraft; and (2) the tax imposed on aircraft by Minn. Stat. 297A.82 does not violate article X, section 5. View "Sheridan v. Commissioner of Revenue" on Justia Law

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The Supreme Court reversed the decision of the court of appeals determining that the district court judge presiding in the prosecution of Defendant was not disqualified or prohibited from presiding over Defendant's case, holding that Minn. R. Crim. P. 26.03, subd. 14(3) was violated when the judge continued to preside over Defendant's case.Defendant was charged with violating a domestic abuse no contact order. During trial, Defendant filed a motion to remove the judge for bias, arguing that the judge had claimed knowledge of a disputed fact and had contacted a potential witness regarding the disputed fact. Defendant's motion was denied, and he was convicted. The court of appeals affirmed. The Supreme Court reversed, holding (1) the judge's conduct during a pretrial proceeding reasonably caused the judge's impartiality to be questioned; (2) subdivision 14(3) was therefore violated when the judge continued to preside over Defendant's case; and (3) reversal of Defendant's conviction and a remand for a new hearing were required to pressure the public's confidence in the judicial system. View "State v. Malone" on Justia Law

Posted in: Criminal Law