Justia Minnesota Supreme Court Opinion Summaries

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the decision of the district court granting the Commissioner of Correction's motion to dismiss Plaintiff's action seeking declaratory and injunctive relief, holding that some of the facts alleged in the complaint stated a claim upon which relief could be granted.Defendant pleaded guilty with several crimes. After Defendant began serving his sentence the Commissioner denied his application for the Challenge Incarceration Program on the grounds that persons required to register as predatory offenders are not eligible for that program. Defendant then brought this action alleging that the predatory offender registration statute and some of its collateral consequences denied him due process as applied to his charged, but not convicted, enumerated offense of kidnapping. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in dismissing Defendant's claim of substantive and procedural due process violations based on his alleged fundamental right to parent his child. View "Werlich v. Schnell" on Justia Law

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The Supreme Court reversed the decision of the court of appeals concluding that the Minnesota Public Utilities Commission erred by approving affiliated-interest agreements under Minn. Stat. 216B.48, subdivision 3 without first considering whether environmental review was necessary, holding that the Commission was not required to conduct review under Minn. Stat. Ch. 116D before approving affiliated-interest agreements that govern construction and operation of a Wisconsin power plant by a Minnesota utility.At issue was whether chapter 116D - the Minnesota Environmental Protection Act (MEPA) - requires the Commission to conduct an environmental review before deciding to approve affiliated-interest agreements that will govern the construction and operation of a power plant in a neighboring state. The Commission in this case that its jurisdiction was limited to power plants proposed to be built in Minnesota, and therefore, the power plant in this case was not subject to Minnesota's permitting and environmental review regulations. The court of appeals reversed. The Supreme Court reversed, holding that MEPA did not apply. View "In re Minnesota Power's Petition for Approval of the EnergyForward Resource Package" on Justia Law

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The Supreme Court reversed the decision of the court of appeals denying Appellants' petition for a writ of mandamus after the district court denied Appellants' motion to transfer venue or, an the alternative, their motion asserting forum non conveniens, holding that the term "several" as used in the context of venue motions means "separate."In this medical malpractice case, Appellants, the two defendants, filed a motion for a change of venue under Minn. Stat. 542.10, which allows "several defendants residing in different counties" to compel the transfer of venue when the majority of them wish to transfer venue. In denying the motion, the district court concluded that the two defendants did not constitute several defendants under the statute. The court of appeals agreed and denied Appellants' petition for a writ of mandamus. The Supreme Court reversed, holding that the word "several" in section 54.10 means "separate." View "Manselle v. Krogstad" on Justia Law

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In this insurance dispute, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing the district court's determination that the insurance policy at issue covered all of the claimed property damage and that a Miller-Shugart settlement agreement was reasonable and unenforceable against Insurer, holding that the policy did not cover all of the claimed property damage.The court of appeals concluded that the settlement agreement was "unreasonable as a matter of law and unenforceable" against the insurer because the agreement failed to allocate between covered and uncovered claims. The Supreme Court reversed in part, holding (1) the policies in this case covered some, but not all, of the property damage claimed by the insured; and (2) determining the reasonableness of an unallocated Miller-Shugart settlement agreement involves a two-step inquiry set forth in this opinion. View "King's Cove Marina, LLC v. Lambert Commercial Construction LLC" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction, holding that the State's discovery motion at Defendant's first court appearance seeking to photograph transitory scratches on Defendant's arms was not a critical stage of the criminal proceeding that required the presence of defense counsel.At Defendant's first appearance on criminal sexual conduct charges the State made a discovery motion to take photographs of transitory scratch marks on Defendant's arms. At issue was whether the discovery motion was a critical stage of the proceedings entitling Defendant to have counsel present. The court of appeals concluded that the discovery hearing on the "otherwise-valid" discovery request to noninvasively photograph scratches was not a critical stage of the proceedings. The Supreme Court affirmed, holding that there was no violation of Defendant's Sixth Amendment right to counsel under the circumstances of this case. View "State v. Zaldivar-Proenza" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of third-degree depraved mind murder under Minn. Stat. 609.195(a), holding that Defendant failed to show that an erroneous jury instruction affected his substantial rights.Defendant had an alcohol concentration of more than twice the legal limit when he drove his snowmobile at nearly sixty miles an hour across a frozen lake, fatally injuring an eight-year-old boy. When instructing the jury, the district court used the model jury instruction for third-degree depraved mind murder, which tells jurors that the underlying act must be "committed in a reckless or wanton manner with the knowledge that someone may be killed." Defendant challenged the instruction on appeal. The Supreme Court affirmed, holding (1) the instruction at issue materially misstated the law; but (2) Defendant failed to establish that the error affected his substantial rights. View "State v. Coleman" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court determining that the interior of a private motor vehicle is not a public place when it is not regularly held open to the public, holding that the court of appeals did not err.At issue was whether the driver of a motor vehicle is in a public place for purposes of Minn. Stat. 624.7142, subd. 1(4), which prohibits a person who is under the influence of alcohol from carrying a pistol in a public place. The district court dismissed the count charging Defendant with a violation of the statute. The court of appeals reversed and reinstated the charge. The Supreme Court affirmed, holding that the Legislature intended to prohibit an impaired person from carrying a pistol on public streets even when that person is inside a motor vehicle. View "State v. Serbus" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the judgment of the district court denying Plaintiff's claim in conciliation court against Defendants seeking replevin of her dog Oliver on the grounds that Plaintiff had abandoned Oliver, holding that, under Minn. Stat. 345.75, Plaintiff did not abandon her dog.At issue was whether section 345.75, which governs the abandonment of tangible personal property, abrogates by implication the common law governing the abandoning of tangible personal property. The court of appeals held that section 345.75 abrogated the common law of abandonment of tangible personal property by necessary implication. The Supreme Court affirmed in part and reversed in part, holding (1) section 345.75 does not abrogate by implication the common law of abandonment of tangible personal property; and (2) Plaintiff did not abandon her dog under the statue, and the district court erred in concluding that Plaintiff abandoned her dog under the common law. View "Zephier v. Agate" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Appellant's fourth petition for postconviction relief, holding that the district court did not abuse its discretion in summarily denying Appellant's petition.After the Supreme Court reversed Appellant's first conviction on direct appeal, Appellant was convicted of first-degree murder while committing or attempting to commit a kidnapping. The Supreme Court affirmed. In his fourth petition for postconviction relief Appellant challenged his sentence, among other claims. The district court denied the petition without a hearing, holding that Appellant's sentence was lawful and that his remaining claims were untimely. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "Hannon v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the court of appeals determining that Minn. Stat. 169A.20, subd. 1(7) is a strict liability offense that does not require the State to prove knowledge as an element of the crime, holding that Defendant's conviction was valid.Defendant pleaded guilty to operating a motor vehicle with a schedule I or schedule II controlled substance in his body. Defendant subsequently sought to withdraw his guilty plea under Minn. R. Crim. P. 15.05, subd. 1, arguing that his guilty plea was invalid because he did not admit that he knew or had reason to know that amphetamine was present in his body at the time he was operating his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that strict liability was appropriate because there was a clear legislative intent to dispense with a mens rea requirement. View "State v. Schwartz" on Justia Law

Posted in: Criminal Law