Justia Minnesota Supreme Court Opinion Summaries

In August 2022, the appellants filed a complaint and petition in Rice County District Court, seeking to prevent the use of electronic voting machines with embedded modems in the upcoming November 2022 general election. They alleged that these machines were not properly certified or secure, in violation of Minnesota law, and requested an order restraining the county from using the modem functions during the election. The complaint named the Director of Rice County Property Tax and Elections as a defendant, and the Minnesota Secretary of State intervened as a party.The Rice County District Court dismissed the section 204B.44 claim in January 2023, citing several jurisdictional defects, including mootness because the 2022 election had already occurred, and insufficient service of process on all candidates as required by statute. The Minnesota Court of Appeals affirmed the dismissal, focusing on the lack of service to all candidates as the basis for its decision and did not address the other grounds identified by the district court.The Minnesota Supreme Court reviewed the case and held that the appellants’ claim under Minnesota Statutes section 204B.44 was moot because the relief sought pertained solely to the 2022 general election, which had already taken place. The court rejected the argument that the claim could be redirected to future elections and clarified that section 204B.44 challenges must be specific to a single election. The Supreme Court affirmed the decision of the Court of Appeals, but did so on the alternative ground of mootness, without reaching the issue of service of process on all candidates. View "Benda for Common-sense vs. Anderson" on Justia Law

An employee began working at a foundry in Minnesota and, after developing back problems, was placed on a lifting restriction by her doctor. She informed her employer of this restriction, but the employer terminated her employment without attempting to provide accommodations. The employee then applied for unemployment benefits, prompting the employer to complete a questionnaire for the Department of Employment and Economic Development (DEED) regarding her termination and disability. In the questionnaire, the employer indicated it had not tried to accommodate her condition.The employee subsequently filed a lawsuit under the Minnesota Human Rights Act, alleging disability discrimination and failure to accommodate. During discovery, the employer sought to exclude the DEED questionnaire from evidence at trial, arguing it was absolutely privileged under Minnesota Statutes section 268.19, subdivision 2(c). The District Court agreed and excluded the document, reasoning that information created solely for unemployment insurance purposes was inadmissible in other civil proceedings. After a bench trial, the District Court ruled in favor of the employer and dismissed the employee’s claims. The Minnesota Court of Appeals affirmed, holding that the questionnaire was absolutely privileged and inadmissible.The Supreme Court of Minnesota reviewed the case to determine whether section 268.19, subdivision 2(c), bars admission of such documents in civil cases. The court held that the phrase “absolutely privileged” in the statute provides immunity from liability for information submitted to DEED, but does not create a general rule of inadmissibility for such evidence in unrelated civil proceedings. Because the employee’s discrimination claim was not based on the content of the DEED questionnaire, its exclusion was erroneous. However, the court found the error was not prejudicial, as the excluded evidence was cumulative of other admitted evidence. The Supreme Court affirmed the decision of the Court of Appeals, but on different grounds. View "McBee vs. Team Industries, Inc." on Justia Law

After a car accident in January 2017, Lee Scheurer was injured and Ann Maland was found to be at fault. Scheurer submitted a written notice of claim to Maland’s insurer in September 2017 and later made a settlement offer in July 2020. The parties could not agree on damages, and Scheurer filed a negligence lawsuit against Maland in November 2020. After Maland’s death, her estate was represented by a special administrator. The case proceeded to a jury trial, which awarded Scheurer $292,340 in damages. The district court subsequently reduced the award to $194,631 to account for collateral source payments, such as insurance, and awarded Scheurer $53,320 in preverdict interest.The Minnesota District Court determined that preverdict interest began accruing when Scheurer commenced the action, not when he served his notice of claim, because he did not file the lawsuit within two years of the notice. The court also held that preverdict interest should be calculated on the reduced judgment amount after deducting collateral sources. Scheurer appealed, arguing that interest should accrue from the notice of claim and be calculated on the full jury verdict. The Minnesota Court of Appeals affirmed the district court on the accrual issue but reversed on the calculation issue, holding that interest should be calculated on the jury verdict before collateral source reductions.The Minnesota Supreme Court reviewed both issues. It held that, under Minnesota Statutes section 549.09, subdivision 1(b), the requirement that an action be commenced within two years of a written notice of claim for interest to accrue from the notice applies even if a written settlement offer is made. The court also held that preverdict interest is to be calculated on the judgment after collateral source deductions, not on the full jury verdict. The decision of the court of appeals was affirmed in part and reversed in part, reinstating the district court’s calculation of interest. View "Scheurer vs. Shrewsbury" on Justia Law

Wells Fargo Bank filed a complaint against Astra Genstar Partnership, LLP, seeking a declaratory judgment related to a property purchased at a foreclosure sale. Wells Fargo requested a declaration that all previously held interests in the property, including Astra's interest, were terminated. Astra filed an answer opposing Wells Fargo's request. The district court granted Wells Fargo's motion for judgment on the pleadings, ruling that any interest Astra had in the property was terminated by the foreclosure sale and the redemption period's expiration. The court administrator failed to notify the parties of the judgment immediately.The district court entered judgment on December 28, 2023, but the parties did not receive notice until March 15, 2024, after the appeal deadline had passed. Astra appealed to the Minnesota Court of Appeals on May 13, 2024. The court of appeals dismissed the appeal, stating it was late under Minnesota Rule of Civil Appellate Procedure 104 and that Rule 14.01(c)(2) of the Minnesota General Rules of Practice for the District Courts did not apply to appellate courts.The Minnesota Supreme Court reviewed the case and concluded that Rule 14.01(c)(2) does not authorize appellate courts to reinstate a late appeal. However, the court determined that the interests of justice warranted reinstating the appeal because the court administrator failed to transmit notice of the judgment as required by Minnesota Rule of Civil Procedure 77.04. The Supreme Court reversed the court of appeals' decision and reinstated Astra's appeal, emphasizing the need to avoid setting a trap for the unwary and to preserve the right to appeal. View "Wells Fargo Bank v. True Gravity Ventures, LLC" on Justia Law

Energy Transfer LP, involved in the Dakota Access Pipeline (DAPL) project, filed a lawsuit in North Dakota against Greenpeace International and others, alleging various tort claims related to the 2016 Standing Rock Protests. Unicorn Riot, a Minnesota-based news organization, and its journalist Niko Georgiades, who reported on the protests, were subpoenaed by Energy Transfer for documents and communications related to the protests. Unicorn Riot objected, citing the Minnesota Free Flow of Information Act (MFFIA), which protects newsgatherers from disclosing unpublished information.The Hennepin County District Court denied Energy Transfer's motion to compel Unicorn Riot to produce the requested documents but ordered Unicorn Riot to produce a privilege log. Both parties appealed. The Minnesota Court of Appeals affirmed the denial of the motion to compel but reversed the order requiring a privilege log, concluding that the MFFIA prohibits such an order.The Minnesota Supreme Court reviewed the case. It held that the MFFIA applies to newsgatherers even if they engage in unlawful or tortious conduct, as long as the conduct does not fall within the statutory exceptions of Minn. Stat. §§ 595.024–.025. The court also held that the MFFIA does not prevent district courts from ordering the production of a privilege log, but district courts should consider whether producing such a log would impose an undue burden on the responding party.The Minnesota Supreme Court affirmed the Court of Appeals' decision in part, reversed in part, and remanded the case to the district court to determine the appropriate scope of the privilege log, considering potential undue burdens. View "Energy Transfer LP v. Greenpeace International" on Justia Law

James Jurgensen sustained a work injury on July 29, 2021, while employed by Dave Perkins Contracting, Inc. He hired attorney Joshua E. Borken, who agreed to a contingent fee of 20% of the first $130,000 of compensation and 20% of any excess amount, subject to approval. Minnesota Statutes § 176.081, subd. 1(a) (2022), caps attorney fees in workers’ compensation cases at $26,000. The parties settled for $150,000, and Borken sought $30,000 in fees, including $4,000 in excess fees. The compensation judge approved $26,000 but denied the excess fees after applying the Irwin factors.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge’s decision, finding no abuse of discretion in denying the excess fees. The WCCA also concluded that automatic approval of unobjected-to excess fees is inconsistent with section 176.081, which provides a presumptive cap on attorney fees. The WCCA did not address the constitutional issue due to a lack of jurisdiction.The Minnesota Supreme Court reviewed the case. The court held that the 2024 amendment to Minn. Stat. § 176.081, which increases the cap on attorney fees, does not apply retroactively. The court also held that the WCCA did not err by declining to automatically approve the requested excess fee. Additionally, the court found that Minn. Stat. § 176.081, subd. 1(a) (2022), does not violate the Contracts Clause of the Minnesota Constitution. Finally, the court concluded that the WCCA did not err by affirming the compensation judge’s denial of excess attorney fees under the Irwin factors.The Minnesota Supreme Court affirmed the decision of the WCCA, upholding the denial of the $4,000 in excess attorney fees. View "Jurgensen vs. Dave Perkins Contracting, Inc." on Justia Law

Alex Lancaster, who operates an adult foster care program in his home, received a correction order from Olmsted County on behalf of the Minnesota Department of Human Services (DHS) after a home inspection. The correction order cited two violations: failure to provide resident access to the upstairs living room and dining area. Lancaster did not request reconsideration of the correction order within the 20-day deadline.Lancaster appealed the correction order to the Minnesota Court of Appeals by petitioning for a writ of certiorari. The court of appeals dismissed the appeal, determining that the correction order was not a quasi-judicial decision and therefore not appealable by writ of certiorari. Lancaster then petitioned for further review.The Minnesota Supreme Court reviewed the case to determine whether a DHS correction order is appealable by writ of certiorari. The court held that a correction order is not a judicial or quasi-judicial decision because it does not bind and irrevocably fix the legal rights of the license holder. Instead, it merely notifies the license holder of alleged violations and the possibility of future sanctions if the violations are not corrected. As a result, the correction order does not meet the criteria for a quasi-judicial decision, which includes a binding decision regarding a disputed claim.The Minnesota Supreme Court affirmed the court of appeals' dismissal of Lancaster’s appeal, concluding that the correction order was not appealable by writ of certiorari. View "Lancaster vs. Department of Human Services" on Justia Law

Hollydale Land LLC (Hollydale) owned a golf course in Hennepin County, Minnesota, which was taxed under the Minnesota Open Space Property Tax Law. This law allows for reduced tax assessments on properties used for recreational purposes, with deferred taxes calculated based on the difference between the market value and the reduced value. When Hollydale sold the golf course, Hennepin County assessed seven years of deferred taxes totaling $2,622,720.41. Hollydale paid the amount but contested the calculation, arguing that the County failed to cap the market value at the bona fide sale price.Hollydale filed a petition in district court, later transferred to the tax court, challenging the County's assessment. Hennepin County moved to dismiss the petition, arguing it was untimely because Hollydale should have challenged the valuations annually. The tax court denied the motion, holding that the petition was timely as it was filed within 60 days of the notice of deferred taxes, thus the tax court had jurisdiction.Hennepin County sought certiorari review of the tax court's order. The Minnesota Supreme Court reviewed whether the tax court's order denying the motion to dismiss was a "final order" under Minn. Stat. § 271.10, subd. 1, which would allow for immediate appeal. The court reaffirmed its decision in Beuning Family LP v. County of Stearns, which held that such orders are not final and thus not immediately appealable. The court also declined to exercise discretionary review under Minn. R. Civ. App. P. 105.1, finding no compelling reason for immediate appeal and determining that judicial economy would be better served by allowing the tax court to resolve the merits of the case.The Minnesota Supreme Court dismissed the writ of certiorari, concluding that the tax court's order was not a final order and that the interests of justice did not warrant discretionary review. View "County of Hennepin v. Hollydale Land LLC" on Justia Law

Deborah Jane Clapp, a Minneapolis homeowner and taxpayer, filed a declaratory judgment action against the Minneapolis Public Schools and its officials. Clapp challenged the constitutionality of racial and ethnic preference provisions in a collective bargaining agreement between the school district and its teachers' union. She sought to stop the school district from implementing and spending public money on these provisions, alleging they violated the Minnesota Constitution's Equal Protection Guarantee.The district court dismissed Clapp's complaint, ruling that she lacked standing and that her claims were not ripe. Clapp appealed, and the Minnesota Court of Appeals reversed the district court's decision, concluding that Clapp had taxpayer standing and that her claims were ripe for judicial review. The school district then petitioned for review by the Minnesota Supreme Court.The Minnesota Supreme Court reviewed the case and focused on the issue of taxpayer standing. The court held that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. In this case, the court found that the alleged unlawful disbursements were merely incidental to the central dispute, which was the constitutionality of the racial and ethnic preference provisions in the collective bargaining agreement. Therefore, Clapp lacked taxpayer standing to bring her claims. The court reversed the decision of the court of appeals, upholding the district court's dismissal of Clapp's complaint. View "Clapp vs. Sayles-Adams" on Justia Law

Michael Benson was civilly committed to the Minnesota Sex Offender Program in 1993. In 2020, he petitioned for a reduction in custody, which the Special Review Board recommended denying. Benson then sought a rehearing and reconsideration from the Commitment Appeal Panel (CAP). He filed a motion to cross-examine witnesses and participate in his defense, expressing a preference to proceed pro se. The CAP allowed limited cross-examination by Benson but required his appointed counsel to be present and conduct initial questioning. Benson refused to participate under these conditions, leading the CAP to dismiss his petition.Benson appealed to the Minnesota Court of Appeals, arguing that the right to counsel under Minnesota Statutes section 253D.20 is waivable. The court of appeals affirmed the CAP's decision, holding that the right to counsel in section 253D.20 is not waivable, based on its precedent. The court also noted that Benson forfeited his constitutional arguments by not raising them at the CAP hearing.The Minnesota Supreme Court reviewed the case to determine whether a civilly committed person can waive the right to counsel under section 253D.20. The court concluded that the right to counsel is waivable, provided the waiver is knowing and intelligent. The court found the statutory language ambiguous but interpreted it in light of legislative intent, common law, and constitutional considerations. The court reversed the court of appeals' decision and remanded the case to the CAP to determine if Benson's waiver of counsel was knowing and intelligent. If so, the CAP must allow him to represent himself. View "In re Matter of the Civil Commitment of Benson" on Justia Law