Justia Minnesota Supreme Court Opinion Summaries

James Bergstrom and Vanessa Rew dissolved their marriage in 2008. In 2002, 2007, and 2008, Rew obtained a series of one-year orders for protection (OFPs) against Bergstrom. In 2010, before the extended expiration date of the 2008 OFP, Rew filed an application under Minn. Stat. 518B.01(6)(a) to extend the terms of the 2008 OFP. After an evidentiary hearing, the district court extended the OFP for up to fifty years in favor of Rew and the couple’s minor children. The Supreme Court affirmed in part and reversed in part, holding (1) section 518B.01(6)(a) does not require a finding of domestic abuse before a district court may extend the duration of an OFP; (2) the extension of an OFP under section 518B.01(6)(a) does not facially violate the First Amendment to the United States Constitution or Minn. Const. art. I, 3; (3) the record was insufficient to conclude that the extended OFP was constitutional with respect to Bergstrom’s children; and (4) the extension of an OFP for up to fifty years does not implicate the prohibition against double jeopardy or the Ex Post Facto Clause of either the United States of Minnesota Constitutions. Remanded. View "In re Rew" on Justia Law

In 2001, Respondent was found guilty of first-degree murder while committing or attempting to commit criminal sexual conduct and first-degree premeditated murder. Respondent was a juvenile when he committed the crime. The district court sentenced Respondent to life without the possibility of release (LWOR) under the mandatory sentencing scheme in Minn. Stat. 609.106(2)(1). After the U.S. Supreme Court decided Miller v. Alabama in 2012, Respondent filed a petition for postconviction relief, arguing that his sentence violated the Eighth Amendment. The postconviction court granted Respondent’s petition and resentenced him to life in prison with the possibility of release after thirty years. The Minnesota Supreme Court subsequently issued its decision in Chambers v. State, which held that the Miller rule does not apply retroactively to a juvenile whose sentence of LWOR under section 609.106(2)(1) became final before the Miller rule was announced. Thereafter, in the instant case, the Supreme Court reversed the postconviction court’s order and reinstated the original sentence of LWOR, holding that the postconviction court’s legal conclusion was in direct conflict with Chambers, and the circumstances of this case did not warrant granting relief to Respondent under the Court’s supervisory powers to ensure the fair administration of justice. View "Roman Nose v. State" on Justia Law

Appellant entered into a mortgage with Aegis Lending Corporation. The mortgage was later assigned to Pacifica L. Ninteen, and the servicing rights were eventually transferred to Vantium Capital, Inc. (“Acqura”). After foreclosure proceedings were commenced against Appellant, Appellant filed suit against Acqura, alleging numerous state law claims. Specifically, Appellant claimed that Acqura’s violated its Servicer Participation Agreement with Fannie Mae by failing to follow guidelines applicable under the federal Home Affordable Modification Program. The district court dismissed the lawsuit, holding that Minn. Stat. 58.18(1) did not provide a private cause of action for Appellant to pursue damages for Acqura’s alleged violation of its agreement with Fannie Mae and that Appellant therefore lacked standing. The court of appeals affirmed. The Supreme Court reversed, holding that section 58.18(1) provides for a private right of action and therefore gave Appellant standing to pursue her claim. View "Gretsch v. Vantium Capital, Inc." on Justia Law

Appellant Ronald Greer sought post-conviction relief from his murder conviction. The trial court denied relief, and he appealed that denial to the Supreme Court. Finding that the trial court did not abuse its discretion in denying Greer's petitions for relief, the Supreme Court affirmed. View "Greer v. Minnesota" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree premeditated murder, two counts of first-degree felony murder, and three counts of first-degree aggravated robbery. The Supreme Court affirmed Appellant's convictions, holding that the district court did not err by (1) overruling Defendant's Batson objection to the State's peremptory challenge of an African-American prospective juror, as Defendant failed to prove that the challenge constituted purposeful racial discrimination; and (2) admitting evidence that Defendant assaulted and threatened a witness two days before trial to prove consciousness of guilt, as the district court correctly weighed the probative value of the evidence against the danger of unfair prejudice and provided safeguards to ensure the evidence would not unduly influence the jury's verdict.View "State v. Diggins" on Justia Law

Defendant was convicted of two counts of aiding suicide in violation of Minn. Stat. 609.215(1), which makes it illegal to intentionally “advise, encourage, or assist another in taking the other’s own life.” Defendant had responded to posts on suicide websites by encouraging the victims to hang themselves, falsely claiming that he would also commit suicide. Defendant appealed, arguing that section 609.215(1) violated the First Amendment. The court of appeals affirmed, holding that the statute prohibited speech that was unprotected by the First Amendment. The Supreme Court reversed, holding (1) the State may prosecute Defendant for assisting another in committing suicide but not for encouraging or advising another to commit suicide, and thus the words “advises” and “encourages” must be severed from the statute as unconstitutional; and (2) because the district court did not make a specific finding on whether Defendant assisted the victims’ suicides, the case must be remanded. View "State v. Melchert-Dinkel" on Justia Law

Defendant, who was HIV positive, engaged in consensual anal intercourse. Defendant was subsequently charged with attempted first-degree assault by transferring a communicable disease for violating Minn. Stat. 609.2241(2). A jury found Defendant violated section 609.2241(2)(2), which applies to the "transfer of blood, sperm, organs, or tissue." The court of appeals reversed the conviction, concluding that section subdivision 2(2) applies only to medical procedures instead of applying to acts of sexual conduct. The Supreme Court affirmed, holding (1) subdivision 2(2) applies only to the donation or exchange for value of blood, sperm, organs, or tissue; and (2) because Defendant's conduct indisputably did not involve the donation or exchange for value of his sperm, subdivision 2(2) was inapplicable to Defendant's conduct.View "State v. Rick" on Justia Law

After a jury trial, Defendant was convicted of criminal vehicular homicide for causing the death of ninety-three-year-old Edith Schouveller in a motor vehicle accident. The accident occurred on March 28, 2010. Schouveller was transported to the hospital with several life-threatening injuries. For the next twenty-two days, Schouveller was either hospitalized or in a nursing home. Schouveller developed lung problems while in the hospital, which led to pneumonia. On April 19, 2010, Schouveller experienced acute respiratory failure. Doctors determined that she needed to be placed on a respirator in order to continue to live, but relying on Schouveller's living will, the doctors declined to place her on respiratory support. Schouveller died that evening. The Supreme Court affirmed Defendant's conviction, holding (1) the district court properly instructed the jury on causation; (2) the State presented sufficient evidence to demonstrate a causal chain between the injuries Shouveller sustained in the accident and the pneumonia and aspiration that ultimately led to her death; and (3) the evidence was sufficient for the jury to conclude that the do-not-resuscitate order in Souveller's living will was not a superseding cause of her death. View "State v. Smith" on Justia Law

A snowplow driver for the City of Alexandria collided with Donald Fernow's vehicle. Fernow brought a personal injury action against the City. At the same time, Fernow's insurance company (Insurer) sought arbitration against the City, seeking repayment in basic economic loss benefits paid to Fernow. In the personal injury action, the district court denied the City's motion for summary judgment on the basis that Fernow's claim was barred by statutory discretionary immunity, common law official immunity, and statutory snow and ice immunity. The court of appeals affirmed. Meanwhile, the arbitrator awarded Insurer basic economic loss benefits, concluding that the defense of governmental statutory immunity did not apply to the matter because of the denial of the City's motion for summary judgment. The district court confirmed the award. The court of appeals reversed, concluding that the arbitrator exceeded her authority when she determined that the defense of governmental statutory immunity did not apply to the matter. The Supreme Court affirmed on different grounds, holding that claims of immunity, including necessary questions of fact, should be determined by the district court prior to arbitration on the merits under the Minnesota No-Fault Automobile Insurance Act. Remanded.View "Fernow v. Gould" on Justia Law

After Scott Schuette, who was working as a police officer at the time, responded to an accident at the local high school he began experiencing mental health problems. Schuette was later diagnosed with post-traumatic stress disorder (PTSD). Schuette filed a claim petition seeking workers’ compensation benefits for PTSD. A compensation judge denied Schuette’s claim, finding that Schuette’s PTSD lacked a physical component and was thus not a compensable injury under Minnesota law. The Workers’ Compensation Court of Appeals (WCCA) affirmed, determining (1) to be compensable under Lockwood v. Independent School District No. 877, an injury must include a physical component; and (2) the compensation judge’s findings that Schuette’s PTSD did not result in a physical brain injury had substantial evidentiary support. The Supreme Court affirmed, holding (1) the compensation judge’s findings were not manifestly contrary to the evidence; and (2) applying the doctrine of stare decisis, Schuette’s request to overrule Lockwood was declined. View "Schuette v. City of Hutchinson" on Justia Law