Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals and remanded this case, holding that, for property to be commandeered, the government must exercise exclusive control over or obtain exclusive possession of the property such that the government could physically use it for an emergency management purpose.Appellant brought this suit arguing that his hospitality businesses were commandeered when the Governor issued emergency executive orders in response to the COVID-19 pandemic that imposed capacity limits for dining beginning in March 2020. As the owner of the commandeered property, Appellant argued, he was entitled to just compensation for the government's use under Minn. Stat. 12.34. The district court dismissed the commandeering claim, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the government exercises exclusive physical control or exclusive possession of private property when only the government may exercise control or possession of the property and the owner is denied all control over or possession of the property; and (2) remand to the district court for further proceedings was required in this case. View "Buzzell v. Walz" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers' Compensation Court of Appeals (WCCA) affirming the decision of the compensation judge finding that Respondent sustained an occupational disease of hearing loss and ordering Relator to pay medical benefits under Minn. Stat. 176.135, subd. 5, holding that further proceedings were required.Respondent developed hearing loss after a career of handling occupational safety and health compliance and monitoring workplace noise levels. Respondent filed a claim for workers' compensation benefits against Relator, his most recent employer. The compensation judge ruled in favor of Respondent and denied his claim for permanent partial disability (PPD) benefits. The WCCA affirmed and clarified that the PPD issue was moot because of a Pierringer settlement between Respondent and one of his former employers. The Supreme Court remanded the case, holding (1) the occupational disease finding was supported by the evidence; (2) the award of medical benefits was appropriate under Minn. Stat. 176.135, subd. 5; and (3) the compensation judge did not properly apply the Pierringer settlement precedent, potentially prejudicing Relator's interests. View "Sershen v. Metropolitan Council" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct a sentence, holding that any alleged procedural error was harmless and that the district court was not required to hold a sentencing hearing.Appellant was serving a sentence of life in prison for first-degree murder when he filed a motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9. In his motion, Appellant argued that his sentence was unlawful because he was not present during the pronouncement of his sentence, because the court failed to provide him an opportunity to personally address the court before it imposed a sentence, and because the court violated Minn. Stat. 609.035, subd. 1. The district court held (1) Appellant was correctly convicted of both first- and second-degree murder in violation of Minn. Stat. 609.04, and (2) Appellant's remaining claims were procedurally barred. The Supreme Court affirmed, holding that Appellant was not entitled to relief on his claims of error. View "Greer v. State" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for interference with privacy after concluding that his guilty plea was accurate, holding that Defendant's guilty plea was not accurate because the plain language of Minn. Stat. 609.746, subd. 1(b) did not apply to his conduct.Defendant admitted to using his cell phone to record a women while she was naked in her bed without obtaining her consent and knowing that she likely would not have consented. At issue was whether Minn. Stat. 609.746, subd. 1(b), the statute Defendant pleaded guilty to violating, covered his conduct. The Supreme Court answered the question in the negative, holding that Defendant's conduct was not prohibited by the plain language of section 609.746, subd. 1(b)(2). View "State v. McReynolds" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State of Minnesota Department of Natural Resources (DNR) and dismissing Plaintiff's complaint alleging a violation of the Minnesota Whistleblower Act, Minn. Stat. 181.932, subd. 1(1), holding that there was no error.After Plaintiff, a former regional director with DNR, was terminated she brought this action alleging that her reporting of suspected illegal activity at a hotel where she was staying for a work-related conference caused her termination. The district court granted summary judgment for DNR. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Plaintiff failed to establish a genuine issue of material fact for trial over whether her alleged protected activity was a motivating factor in the decision of the DNR to terminate Plaintiff; and (2) therefore, summary judgment was properly granted. View "Hanson v. State, Department of Natural Resources" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree murder, second-degree intentional murder, and first-degree arson, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that he was entitled to relief based on limitations that the district court placed on the presence of the public in the courtroom in response to the COVID-19 pandemic and that his motion for a hearing under Schwartz v. Minneapolis Suburban Bus Co., 104 N.W.2d 301 (Minn. 1960), and Minn. R. Crim. P. 26.03, subd. 20(6) should have been granted. The Supreme Court affirmed, holding (1) this Court will not exercise its limited discretion under the plain-error doctrine to grant relief based on objected-to limitations that the district court placed on the presence of the public in the trial courtroom due to the COVID-19 pandemic; and (2) the district court did not abuse its discretion by denying Defendant's request for a Schwartz hearing. View "Pulczinski v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting the motion for judgment on the pleadings filed by Defendant, Grant Park Association, and dismissing Plaintiff's action alleging that Defendant violated the Minnesota Common Interest Ownership Act of 1993, Minn. Stat. 515B.1-101 to .4-118, holding that the district court erred.After Defendant failed to respond to Plaintiff's request for the postal and e-mail addresses of all members of the Association Plaintiff brought this action alleging that Defendant violated the Act and the Association's bylaws by not turning over the records. The district court granted Defendant's motion for judgment for the pleadings. The court of appeals reversed. The Supreme Court affirmed, holding (1) an association must disclose all records that fall under the categories listed in Minn. Stat. 515B.3-118, including records of membership kept by the association; (2) Defendant's bylaws required the same level of disclosure as the Act; and (3) Plaintiff adequately pleaded his claims to survive a motion for judgment on the pleadings. View "Harkins v. Grant Park Ass'n" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing the petitions for writs of mandamus filed by Minnesota Voters Alliance, et al. (collectively, the Alliance), holding that the Alliance failed to show the violation of a duty clearly established by law.In the mandamus petitions, the Alliance alleged that Ramsey County, Olmsted County, and other entities violated their statutory obligations for appointing members to absentee ballot board during the 2020 general election. Specifically, Alliance argued that the statutory requirements for election judges also apply to deputy county auditors. The district court dismissed the petitions, and the court of appeals affirmed. The Supreme Court affirmed, holding that the district court properly dismissed the Alliance's mandamus petitions. View "Minnesota Voters Alliance v. County of Ramsey" on Justia Law

The Supreme Court affirmed the nonprecedential opinion of the court of appeals instructing the district court to consider whether Rebecca Bender presented newly discovered evidence warranting relief from a child support order, holding that the district court should have determined whether Bender's proffered evidence warranted relief.Years after marriage dissolution and child support proceedings between Bender and Peter Bernhard, Bender filed a motion to modify the child support termination order based on "newly discovered evidence" under Minn. Stat. 518.145, subd. 2(2) and Minn. R. Civ. P. 60.02. The district court denied the motion. The court of appeals reversed and remanded the case. The Supreme Court affirmed, holding (1) as may be just, a district court has discretion under section 518.145 to consider newly discovered evidence that arises after the court's underlying decision; and (2) the district court abused its discretion in finding that Bender's newly discovered evidence was not "new." View "Bender v. Bernhard" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court finding Defendant guilty of four counts of violence under Minn. Stat. 609.713, subd. 1, holding that section 609.713, subd. 1 does not violate the First Amendment.After he was charged, Defendant filed a motion to dismiss, claiming that the portion of section 609.713, subd. 1 that applies to threats of violence made "in a reckless disregard of the risk of causing such terror" was unconstitutionally overbroad. The district court denied the motion and found Defendant guilty. The court of appeals affirmed, concluding that even if the statute prohibited some protected speech, it was not facially overbroad under the First Amendment. The Supreme Court affirmed, holding (1) specific intent is not required to make a communication a true threat; (2) the statute punishes only reckless speech that is a true threat; and (3) because few situations of reckless but protected threats would be swept up in criminal prosecutions, the statute is not facially overbroad. View "State v. Mrozinski" on Justia Law