Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the district court granting summary judgment to Marvel, LLC in this negligence action, holding that an exculpatory clause purporting to release Marvel from "any and all claims" related to use of its inflatable amusement play area did not release Marvel from liability for its own negligence.Before seven-year-old Carter Justice attended a birthday party at an inflatable amusement play area owned by Marvel his mother signed a waiver of liability naming Justice. While there, Justice fell and hit his head on concrete floor, leading to several injuries. Justice sued Marvel when he turned eighteen. The district court granted summary judgment for Marvel, and the court of appeals affirmed. The Supreme Court reversed, holding that the waiver, strictly construed, did not release Marvel from liability for its own negligence. View "Justice v. Marvel, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the district court rejecting Wife's action against Husband seeking half of his retirement account or, alternatively, an equitable portion of the account, holding that the parties' omission of their largest asset from the dissolution decree made it impossible for the district court to determine whether the settlement was equitable.After the parties' marriage was dissolved through a joint petition for marriage dissolution Wife filed this action seeking half of Husband's retirement account. In objecting, Husband argued that he and Wife had intentionally omitted his retirement account from their joint petition pursuant to an unwritten side agreement. The district court concluded that the relief Wife sought was beyond the scope of a ** proper enforcement of clarification order and was time-barred to the extent it sought to reopen the decree. The court of appeals affirmed. The Supreme Court reversed, holding (1) district courts have the power to address omitted assets that fall outside the scope of the grounds set forth in Minn. Stat. 518.145, subd. 2 for reopening a dissolution decree; and (2) the parties' omission from the decree of their largest asset rendered it impossible for the district court to determine whether the settlement was equitable. View "In re Marriage of Pooley" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the order of the district court granting summary judgment to Defendants - mental healthcare providers - and dismissing Plaintiff's wrongful death action, holding that genuine issues of material fact existed.For three months, Brian Short received outpatient treatment for anxiety and depression. Thereafter, he shot and killed his wife, his three children, and himself. Plaintiff brought this wrongful death action. The district court granted summary judgment for Defendants, concluding that they did not have a duty to protect or control Brian or his wife and children absent a custodial relationship or foreseeability of harm. The court of appeals reversed, holding (1) Defendants owed a duty of care to Brian, and (2) genuine issues of material fact existed as to whether Defendants' conduct created a foreseeable risk to Brian's wife and children. The Supreme Court (1) affirmed as to Brian, holding that a mental healthcare provider owes a duty of reasonable care to its patient that is not negated by a lack of total control over the patient; and (2) reversed as to Brian's wife and children, holding that harm to the family members was outside the scope of the duty of care and unforeseeable as a matter of law. View "Smits v. Park Nicollet Health Services" on Justia Law

In this dispute among four siblings over the ownership of 200 acres of farmland the Supreme Court reversed the judgment of the court of appeals reversing the order of the district court that the farmland be distributed to Neal Johnson and Thomas Johnson, holding that the court of appeals failed to apply well-settled common law.This dispute stemmed from the last will and testament of the aunt of the four siblings in this case - Neal, Thomas, Sylvia Perron, and Lee Johnson. The aunt, Hazel Bach, devised the farmland to Neal and Thomas based on certain conditions that were resolved in an agreement between the parties. Although Lee, acting as co-personal representative, refused to honor the agreement, the district court ordered that the farmland be distributed to Neal and Thomas. The court of appeals reversed. The Supreme Court reversed, holding that Neal and Thomas were entitled to the 200 acres under Bach's will. View "In re Estate of Bach" on Justia Law

The Supreme Court reversed the judgment of the court of appeals construing a letter that Defendants submitted to the district court under Minn. R. Gen. Proc. 115.11 as a permissible tolling motion under Minn. R. Civ. App. P. 104.01, subd. 2 and accepting jurisdiction, holding that a request for permission to file a motion to reconsider pursuant to Rule 115.11 does not toll the time for appeal.In this dispute between commercial property owners over the allegedly fraudulent behavior of one of the owners during the refinancing of the property Defendants moved for summary judgment, arguing that Plaintiffs' claims were untimely and lacked merit. The district court granted the motion and dismissed the complaint with prejudice. Thereafter, Defendants filed the letter at issue seeking to correct an erroneous reference in the order. The district court issued an amended summary judgment order without directly responding to the letter. Defendants appealed, arguing that the appeal was untimely. The court of appeals accepted jurisdiction. The Supreme Court reversed, holding that the appeal was untimely, and therefore, the court of appeals erred by accepting jurisdiction. View "Stern 1011 First Street South, LLC v. Gere" on Justia Law

The Supreme Court affirmed the order of the court of appeals dismissing Appellant's appeal from the district court's denial of his petition to create a constructive trust, holding that the court of appeals did not err by dismissing the appeal for lack of appellate jurisdiction.Joseph Figliuzzi, who created a trust for holding wetland credits, sought to hold the credits in his own name rather than in the trust. After Figliuzzi died, Appellant brought this action seeking to confirm that the trust owned the subject credits and to establish a constructive trust over the disputed credits. The district court denied relief, concluding that Figliuzzi owned the credits at the time of his death. The court of appeals dismissed Appellant's ensuing appeal for lack of jurisdiction. The Supreme Court affirmed, holding (1) because the order being appealed from lacked finality, it could not be appealed under Minn. R. Civ. App. P. 103.03(g); and (2) the district court's order was not a denial of injunctive relief. View "In re Estate of Joseph Rocco Figliuzzi" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's complaint alleging that Defendant violated the Minnesota Bond Allocation Act, Minn. Stat. 474A.01-.21, holding that Plaintiff alleged a violation of the Act sufficient to support her common-law and statutory claims.Plaintiff, who leased and lived in one of Defendant's rent-restricted housing units, brought this putative class action alleging that Defendant violated the Act, which imposes rent limits on residential rental projects financed with tax-exempt municipal bonds. The district court dismissed the complaint for failure to state a claim upon which relief can be granted, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff stated a viable action, and therefore, the district court erred in dismissing her complaint. View "Thompson v. St. Anthony Leased Housing Associates II, LP" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for four counts of possession of pornographic work involving minors, holding that, assuming that Defendant had a reasonable expectation of privacy in his online cloud storage account, the government's search of his account was lawful under the private search doctrine.At issue in this case was the conduct of law enforcement officers who discovered digital child pornography files stores in Defendant's cloud storage account with Dropbox. Defendant moved to suppress the evidence acquired from his Dropbox account, arguing that the search violated his Fourth Amendment rights. The district court denied the motion to suppress. The court of appeals affirmed. The Supreme Court affirmed, holding that the warrantless search of Defendant's online cloud storage account did not violate the Fourth Amendment. View "State v. Pauli" on Justia Law

The Supreme Court reversed the judgment of the tax court denying summary judgment to Rainbow Early Education Center, an early childhood center, on its claim for a tax exclusion as a seminary of learning under Minn. Const. art. X, 1 and Minn. Stat. 272.02, subd. 5, holding that the tax court did not correctly apply the standard set forth in State v. Northwestern Preparatory School, 83 N.W.2d 242 (Minn. 1957).Rainbow petitioned for a property tax exemption, claiming status as a seminary of learning. Because prior decisions concerning the meaning of the phrase "seminaries of learning" centered on secondary or postsecondary institutions Rainbow cited licensure, facilities, programming, and rating by a government-administered best practices program in support of its claim that it was entitled to a property tax exemption . The tax court granted summary judgment to the County. The Supreme Court reversed, holding (1) an institution is an exempt seminary of learning when it has an educational purpose, provides a broad general education, and does so in a thorough and comprehensive manner; and (2) Rainbow presented uncontroverted evidence of each element. View "Under the Rainbow Early Education Center v. County of Goodhue" on Justia Law

The Supreme Court reversed the decision of the tax court finding that the Data Practices Act, Minn. Stat. 13.01-.90, prohibited Hennepin County from disclosing certain nonpublic data contained within its expert appraisal report and ordering portions of the County's expert report containing those data to be excluded at trial, holding that the tax court erred.At issue in the underlying property tax trial involving G&I IX OIC LLC was an expert report containing nonpublic data about comparable rental properties to establish the market value of G&I's office tower. The tax court determined that the County could not use the nonpublic data at trial without first securing the court's approval. The Supreme Court reversed, holding that the tax-code provision of Minn. Stat., subdivision 3, governed in this case and permitted the County to use its expert appraisal report, which were included in nonpublic data in "assessor's records" at trial. View "Tax Court v. County of Hennepin" on Justia Law