Justia Minnesota Supreme Court Opinion Summaries

In 2015, a group of parents brought a class action lawsuit on behalf of their children, who were enrolled in Minneapolis and Saint Paul public schools. The parents claimed that the state of Minnesota violated their children's right to an adequate education under the Education Clause of the Minnesota Constitution due to the racial and socioeconomic segregation present in the schools. The case went through several years of litigation, and the district court certified a question for immediate appeal: whether racial imbalances in Minneapolis and Saint Paul public schools are sufficient, standing alone, to establish a violation of the Education Clause. The Minnesota Supreme Court reformulated the certified question and held that racial imbalances in Minneapolis and Saint Paul public schools, standing alone, are not sufficient to establish a violation of the Education Clause. The court ruled that while the parents do not have to establish that state action caused the racial imbalances, they must show that the racial imbalances are a substantial factor in causing their children to receive an inadequate education. The case was remanded back to the district court for further proceedings. View "Cruz-Guzman, as guardian and next friend of his minor children vs. State of Minnesota" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree intentional felony murder while committing burglary, holding that the State presented sufficient evidence to sustain Defendant's conviction.After a jury trial, Defendant was found guilty of three counts, including first-degree intentional felony murder while committing burglary. The trial court imposed a life sentence with eligibility for release after thirty years. Defendant appealed, arguing that the State presented insufficient evidence to prove his intent to kill. The Supreme Court affirmed, holding that the circumstantial evidence presented by the State was sufficient to support Defendant's conviction for first-degree intentional felony murder. View "State v. Colgrove" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress evidence found during a search of his vehicle, holding that the odor of marijuana emanating from a vehicle, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement.After a traffic stop and subsequent search of his vehicle Defendant was convicting of possession of methamphetamine paraphernalia in the presence of a minor and fifth-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the odor of marijuana, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement. The district court granted the motion and dismissed the complaint. The court of appeals affirmed. The Supreme Court affirmed, holding that evidence of medium-strength odor of marijuana, on its own, is insufficient to establish a fair probability that the search would yield evidence of criminally-illegal conduct or drug-related contraband. View "State v. Torgerson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the determination of the district court that the underlying First Amendment retaliation claim brought under 42 U.S.C. 1983 was time-barred, holding that the continuing violation doctrine did not apply to toll the statute of limitations.Plaintiff brought this action alleging that Defendant, the City of Duluth, retaliated against him in violation of his rights under the First Amendment by making false statements and engaging in other negative conduct toward him. In dismissing the claim, the trial court rejected Plaintiff's reliance on the continuing violation doctrine. The court of appeals reversed and reinstated Plaintiff's section 1983 retaliation claim against the City, concluding that the continuing violation doctrine did not apply because the acts Plaintiff alleged as retaliation were discrete acts that were actionable when committed and therefore did not constitute a continuing violation that tolled the statute of limitations. The Supreme Court affirmed, holding that the continuing violation doctrine did not apply in this case. View "Ringsred v. City of Duluth" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress evidence discovered in the vehicle that Defendant was driving, holding that the totality of the circumstances supported probable cause to search the vehicle.Law enforcement initiated a traffic stop after receiving a tip from an informant that a male in possession of a firearm was in the vehicle Defendant was driving. The district court granted Defendant's motion to suppress the firearm on the grounds that the officers lacked probable cause to search the vehicle. The court of appeals affirmed. The Supreme Court reversed, holding that the State met its burden and established probable cause to search the vehicle that Defendant was driving. View "State v. Mosley" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant postconviction relief by ordering a substantive sentencing hearing, holding that, under the circumstances of this case, it would be manifestly unfair for the district court not to hold a substantive sentencing hearing in accordance with State v. Warren, 592 N.W.2d 440 (Minn. 1999).After a jury trial, Defendant was convicted of two counts of first-degree murder. Defendant was seventeen years old when he committed the offenses. The district court sentenced Defendant to two consecutive sentences of life in prison without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, the district court resentenced Defendant to two consecutive sentences of life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant subsequently filed his postconviction petition requesting a substantive hearing to consider whether, pursuant to the test articulated in Warren, his modified sentences should be served concurrently rather than consecutively. The district court granted the petition. The Supreme Court affirmed, holding that the unique circumstances of this case warranted the exercise of this Court's inherent supervisory powers to direct that the district court hold a substantive sentencing hearing in accordance with Warren. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of felony domestic assault-harm under Minn. Stat. 609.2242, subds. 1(2), 4, holding that there was no error in the proceedings below and that the evidence was sufficient to support the conviction.On appeal, the court of appeals concluded that the district court erred by instructing the jury that Defendant could use reasonable force to resist an "assault against the person" rather than to resist any "offense against the person" but that the error was not plain and that sufficient evidence supported the conviction. The Supreme Court affirmed, holding (1) use of nonlethal self-defense under section 609.06, subd. 1(3) requires a person to resist an offense carrying the threat of bodily harm; (2) the district court's use of the phrase "assault against the person" in the jury instruction at issue was not error; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Lampkin" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying Appellant's petition for postconviction relief without an evidentiary hearing, holding that Appellant was conclusively entitled to no relief on his claims even if the facts alleged were proven by a preponderance of the evidence.Appellant, who was imprisoned for first-degree premeditated murder, filed a petition seeking postconviction relief and an evidentiary hearing, arguing that he was deprived of his Sixth Amendment right to effective assistance of appellate counsel in his direct appeal. The district court summarily denied relief. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the postconviction petition without an evidentiary hearing. View "Woodard v. State" on Justia Law

The Supreme Court held that, under Minnesota statutes in a condemnation proceeding, Blue Earth County did not owe just compensation to Landowners for the loss of a right to access to a newly constructed controlled-access highway built across their property.The district court ruled that Landowners had not been deprived of any right of access for which they should be justly compensated, noting that the County continued to provide farm access to Landowners' property. The court of appeals affirmed. The Supreme Court affirmed, holding that a person who owns property abutting a newly constructed controlled-access highway has no right of access to the controlled-access highway. View "Wood v. County of Blue Earth" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and his sentence of life in prison without the possibility of release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confrontation when it admitted the victim's dying declarations into evidence during the jury trial, and this Court reaffirms that dying declarations are an exception to the Confrontation Clause; (2) the district court did not violate Defendant's Fifth Amendment right to counsel by denying Defendant's motion to suppress his statements to police officers because Defendant validly waived his invoked right to counsel; and (3) there was no reasonable possibility that the admission of Spreigl evidence related to a prior assault charge into evidence significantly affected the verdict. View "State v. Buchan" on Justia Law