Justia Minnesota Supreme Court Opinion Summaries

Appellant, a Delaware limited liability company, made short-term, high-interest payday loans to Minnesota residents over the Internet. Integrity conceded that its payday loans did not comply with several provisions of Minnesota’s payday-lending law. In 2011, the Minnesota Attorney General sued Integrity, alleging that it had violated Minnesota’s payday-lending law. Integrity counterclaimed by requesting a declaratory judgment that Minnesota’s payday-lending law was unconstitutional under the extraterritoriality principle of the Commerce Clause, which prohibits a state from regulating commerce that occurs wholly outside the state. The district court granted summary judgment to the State. The court of appeals affirmed. The Supreme Court affirmed, holding that Minnesota’s payday-lending law does not violate the Commerce Clause. View "State v. Integrity Advance, LLC" on Justia Law

Defendant was the driver of a vehicle that was involved in a single-vehicle rollover crash. The accident resulted in one fatality. At the time of the accident, an officer obtained a blood draw from Defendant, and later testing of that blood revealed an alcohol concentration of 0.20. The State charged Defendant with three counts of criminal vehicular operation resulting in death, two counts of fourth-degree driving while impaired, reckless driving, and careless driving. Defendant filed a motion to suppress the alcohol concentration test results on the grounds that his blood was drawn without a warrant and without his consent. The district court suppressed the alcohol concentration test results, concluding that the State failed to satisfy the exigent circumstances exception as applied in Missouri v. McNeely. The court of appeals reversed, concluding that the State established that exigent circumstances justified the warrantless blood draw. The Supreme Court affirmed, holding that the State proved the existence of exigent circumstances justifying the warrantless blood draw. View "State v. Stavish" on Justia Law

Appellant was convicted of third-degree driving while impaired. At trial, the court admitted test results showing Appellant’s alcohol concentration at the time of the incident that were based on a warrantless blood draw. After the court of appeals affirmed the conviction, the Supreme Court decided Missouri v. McNeely, which held that the dissipation of alcohol in the blood does not create a single-factor exigency justifying a warrantless blood draw of suspected drunk drivers. Defendant petitioned for review to determine whether, in light of McNeely, her blood draw was an unconstitutional search. The Supreme Court vacated the court of appeals’ decision and remanded for further proceedings in light of McNeely. On remand, the court of appeals again affirmed. The Supreme Court affirmed, holding (1) McNeely applies to cases on direct review at the time of decision; but (2) the test results from Appellant’s blood draw, even if obtained in violation of Appellant’s constitutional rights, need not be suppressed because the officer who facilitated the blood draw acted in objectively reasonable reliance on binding appellate precedent. View "State v. Lindquist" on Justia Law

In 2005, the City of Winona enacted the thirty-percent rule, which limits the number of lots on a block in certain areas of the City that are eligible for certification as rental properties. Appellants brought this action challenging the rental ordinance, claiming that the thirty-percent rule is a zoning law that exceeds the City’s power authorized by Minn. Stat. 462.357 and violates their equal protection and substantive due process rights. The district court granted summary judgment in favor of the City, concluding that the ordinance is not unconstitutional and that the City had authority to enact it. The court of appeals affirmed. Appellants filed a petition for review. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that Appellants' claims had become moot because, under the facts and circumstances of this case, the alleged harm to Appellants’ interests had ceased. View "Dean v. City of Winona" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life in prison. The Supreme Court affirmed. Appellant then filed a pro se petition for postconviction relief alleging, inter alia, ineffective assistance of appellate counsel and newly discovered evidence. The postconviction court summarily denied relief on all claims with the exception of the newly discovered evidence claim. After an evidentiary hearing, the postconviction court denied the newly discovered evidence claim. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it (1) summarily denied Appellant’s ineffective assistance of counsel claim because the facts alleged in the petition failed to satisfy the Strickland test; (2) denied Appellant’s newly discovered evidence claim after an evidentiary hearing because the record supported the court’s finding that the testimony of the newly discovered witnesses was doubtful; and (3) summarily denied Appellant’s remaining claims because those claims were procedurally barred. View "Carridine v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court (1) did not err in admitting evidence from Appellant’s cell phone because the police lawfully seized the cell phone under the plain-view exception to the warrant requirement; (2) did not err in admitting evidence obtained from the execution of numerous search warrants because the search warrants were supported by probable cause; and (3) did not abuse its discretion in dismissing a juror for cause. View "State v. Holland" on Justia Law

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct for sexually penetrating a member of the parish where he served as a priest. The court of appeals reversed and ordered a new trial, holding that the district court erred in (1) failing to provide a specific-unanimity instruction; (2) failing to instruct the jury that State was required to prove that Defendant had subjective knowledge of the purpose of the meeting at which sexual penetration occurred; and (3) denying Defendant’s motion to admit evidence of the complainant’s sexual history after it admitted the State’s evidence of the victim’s sexual inexperience. The Supreme Court reversed, holding (1) the district court’s failure to provide a specific-unanimity jury instruction did not affect Defendant’s substantial rights; (2) the clergy sexual conduct statute does not require the clergy member to know that the complainant seeks or is receiving spiritual counsel; and (3) even assuming the district court abused its discretion in disallowing Defendant’s sexual-history evidence, any error was harmless beyond a reasonable doubt. View "State v. Wenthe" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder committed for the benefit of a gang and first-degree premeditated murder. Appellant was convicted of first-degree premeditated murder, and the district court imposed a sentence of life without the possibility of release. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, alleging, inter alia, newly discovered evidence of the recantations of two witnesses. The Supreme Court remanded the case to the postconviction court for an evidentiary hearing on the witness recantation claim. Thereafter, Appellant filed a second petition for postconviction relief, alleging that his sentence was unconstitutional and that he was entitled to retroactive application of Miller v. Alabama. The postconviction court consolidated both matters, conducted an evidentiary hearing, and (1) denied Appellant’s witness recantation claim from his first postconviction petition, and (2) denied Appellant’s second postconviction petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to a new trial on his witness recantation claim; and (2) Appellant’s second petition for postconviction relief was time-barred. View "Martin v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, one count of attempted first-degree murder, and one count of burglary. Appellant committed the offenses when he was sixteen years old. The district court imposed a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction. Defendant’s convictions were affirmed on direct appeal. Nineteen years later, Appellant moved to correct his sentence based on the rule announced in Miller v. Alabama. Specifically, Appellant argued that the rule announced in Miller should be extended to statutory provisions that mandate the imposition of life imprisonment with the possibility of release and should apply to a district court’s discretionary imposition of consecutive sentences that are the functional equivalent of life imprisonment without the possibility of release. The postconviction court denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court’s decision was consistent with the Court’s recent rulings, and its ruling was a sound exercise of its discretion. View "State v. Williams" on Justia Law

Defendant was convicted of three counts of murder in connection with the death of his two-year-old niece. While Defendant’s appeal was pending, new evidence was identified. The State then sought, and a grand jury returned, an amended indictment for five counts of murder. After a new trial, Defendant was convicted of five counts of murder. The Supreme Court reversed, holding that the district court (1) did not err when it seated jurors who knew about Defendant’s first conviction; but (2) abused its discretion when it allowed a juror who exhibited actual bias against Defendant and was not adequately rehabilitated to sit in judgment of Defendant. Remanded for a new trial. View "State v. Fraga" on Justia Law