Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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In Minnesota, a group of voters sought to prevent former President Donald Trump from appearing on the 2024 presidential primary and general election ballots, arguing that Section 3 of the Fourteenth Amendment of the U.S. Constitution, which disqualifies anyone from holding office who has engaged in insurrection or rebellion against the U.S., rendered him ineligible. The Minnesota Supreme Court held that it would not be an error to place Trump's name on the 2024 Republican Party presidential nomination primary ballot. The court reasoned that the nomination primary is an internal party election, and the state law does not prohibit a major political party from placing an ineligible candidate on the primary ballot. However, the court did not decide on the issue of Trump's name on the general election ballot, stating that the matter was not yet ripe for adjudication as it was not "about to occur" under the relevant state law. The court did not foreclose the possibility of petitioners bringing such a claim at a later date. View "Growe v. Simon" on Justia Law

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The Minnesota Supreme Court affirmed the decision of the lower courts to terminate a mother's parental rights due to her failure to appear for the final day of a multiple-day termination of parental rights trial. The mother, identified as S.T., had argued that the district court violated her procedural due process rights by refusing to reschedule the trial to allow her to testify, offer additional witnesses, and cross-examine witnesses. However, the Supreme Court found that S.T. failed to demonstrate that the outcome of the trial was materially affected by her absence. The Supreme Court noted that although S.T.'s absence was troubling, the district court's refusal to continue or reschedule the hearing did not automatically violate due process. The court concluded that S.T. did not make a sufficient case that her testimony or that of her proposed witnesses would have materially affected the outcome of the trial. Therefore, the court upheld the termination of S.T.'s parental rights. View "In the Matter of the Welfare of the Children of: G.A.H. and S.T., Parents" on Justia Law

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The Supreme Court affirmed the decision of the Minnesota Tax Court affirming the assessment of the Commissioner of Revenue assessing tax on an apportioned share of Cities Management, Inc.'s (CMI) income from the sale of the S corporation, holding that the income from the corporation's sale was apportionable business income.CMI, which did business in Minnesota and Wisconsin, and its nonresidential partial owner filed Minnesota tax returns characterizing the sale of CMI's goodwill as income that was not subject to apportionment by the State under Minn. Stat. Ann. 290.17. The Commissioner disagreed and assessed tax on an apportioned share of the corporation's income from the sale. The tax court affirmed. The Supreme Court affirmed, holding that CMI's income did not constitute "nonbusiness" income under section 290.17, subd. 6 and may be constitutionally apportioned as business income. View "Cities Management, Inc. v. Commissioner of Revenue" on Justia Law

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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

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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

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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

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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

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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

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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

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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