Justia Minnesota Supreme Court Opinion Summaries

Defendant was found guilty of first-degree murder while committing domestic abuse with a past pattern of domestic abuse, and second-degree murder while committing a felony. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to prove that Defendant assaulted the victim and caused his death; (2) the State presented sufficient evidence to prove Defendant had engaged in a past pattern of domestic abuse; (3) the district court did not err in failing to instruct the jury that a past pattern of domestic abuse requires proof beyond a reasonable doubt of at least two prior acts of abuse; and (4) the district court did not err in failing to instruct the jury that it needed to agree unanimously on which two specific acts of past abuse were proven beyond a reasonable doubt. View "State v. Hayes" on Justia Law

This case involved a facial challenge to the constitutionality of the City of Red Wing's rental property inspection ordinance. Appellants were landlords and tenants who brought suit seeking a declaratory that the City's ordinance violated the Minnesota Constitution. The district court granted summary judgment in favor of the City, concluding that Appellants lacked standing and that the constitutional claim failed on the merits. The court of appeals affirmed, ruling that Appellants lacked standing. The Supreme Court reversed, holding that Appellants' facial challenge presented a justiciable controversy. On remand, the court of appeals again affirmed, this time concluding that the City's ordinance did not violate the state constitution. The Supreme Court affirmed, holding (1) the law can be applied constitutionally; and (2) because Appellants did not satisfy their burden in a facial challenge to show that the ordinance operated unconstitutionally in all of its applications, Appellants' facial challenge failed. View "McCaughtry v. City of Red Wing" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and related charges. The district court sentenced Appellant on the first-degree murder conviction to a mandatory sentence of life imprisonment without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence on direct appeal. Appellant subsequently filed a second petition for postconviction relief, alleging that his sentence was unconstitutional under the Eighth Amendment. The postconviction court denied Appellant's petition without an evidentiary hearing, concluding that the petition was time barred and that none of the exceptions to the time bar applied. Appellant appealed, contending that his sentence violated the Eighth Amendment and that recent decisions of the U.S. Supreme Court satisfied an exception to the time bar. The Supreme Court affirmed, holding that the cases upon which Appellant relied were either not applicable to Appellant or did not apply retroactively to him. View "Chambers v. State" on Justia Law

Appellants were landowners who elected to require a utility to condemn their property in fee after Respondents sought to acquire easements through their property by eminent domain in order to construct a high-voltage electric transmission line. After making this election, Appellants requested that Respondents provide them with minimum compensation and relocation assistance. Respondents moved the district court for an order clarifying whether such benefits are available to property owners making an election under Minn. Stat. 216E.12. The district court concluded that such benefits were available to Appellants, but the court of appeals reversed. The Supreme Court reversed, holding that Appellants satisfied the statutory criteria for receiving minimum compensation and relocation assistance and were therefore entitled to such benefits. Remanded. View "N. States Power Co. v. Aleckson" on Justia Law

After a jury trial, Appellant was convicted of fleeing a peace officer by means other than a motor vehicle pursuant to Minn. Stat. 609.487(6) after she ran from a police officer who was responding to a stabbing at a bar. Appellant argued in a pretrial motion that she was entitled to a voluntary intoxication jury instruction because section 609.487(6) contains a specific-intent requirement. The district court denied the motion, ruling that the offense is a general-intent crime. The court of appeals affirmed. The Supreme Court affirmed but on different grounds, holding (1) section 609.487(6) contains a specific-intent requirement, and the district court erred in failing to instruct the jury on voluntary intoxication in this case; but (2) the error was harmless beyond a reasonable doubt because the omission of the voluntary intoxication jury instruction did not significantly affect the verdict. View "State v. Wilson" on Justia Law

Pursuant to a plea agreement, the district court convicted Respondent of aggravated forgery. After Respondent was discharged from probation, she filed a second petition for expungement of her criminal record. The district court granted Respondent's motion to expunge her criminal records, finding that sealing Respondent's record would yield a benefit commensurate with the disadvantages to the public. The court of appeals affirmed, holding that the district court had the inherent authority to expunge Respondent's criminal records held in the executive branch. The Supreme Court reversed in part, holding that because expungement of Respondent's criminal records held in the executive branch is not necessary to the performance of a unique judicial function, the district court did not have the authority to expunge Respondent's records held in the executive branch. View "State v. M.D.T." on Justia Law

Employees filed a complaint against two employers (Employers), alleging that Employers violated the Minnesota Human Rights Act (MHRA) based on sexual harassment perpetrated by the sole owner of both entities (Owner). Employees also alleged that Owner was individually liable under MHRA's aiding and abetting provision. The district court dismissed Employees' claims. The court of appeals reversed, holding (1) the district court's determination that the harassment was not actionable was clearly erroneous, (2) Employees were entitled to judgment on their claims as a matter of law, and (3) Owner could not be individually liable for aiding and abetting Employers' MHRA violations. The Supreme Court reversed, holding (1) the court of appeals did not err in concluding that Owner could not be liable on an aiding and abetting theory; but (2) two separate errors of law infected the district court's determination that Employees did not prove their sexual harassment claims, and therefore, the Court was unable to ascertain exactly how the errors impacted the court's decision to dismiss Employees' claims. Remanded to the district court to reevaluate the evidence using the correct legal standard. View "Rasmussen v. Two Harbors Fish Co." on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief requesting a new trial or an evidentiary hearing based on recanted testimony from a witness and newly discovered evidence. The postconviction court denied Appellant's motion on the grounds that it was untimely because it was filed after the two-year statutory limit, and no exception to the limitations applied. The court further concluded that the jury would not have reached a different outcome without the witness's testimony. The Supreme Court affirmed, holding that Appellant's petition was untimely, and Appellant failed to demonstrate he was entitled to relief under the newly discovered evidence exception to the time bar. View "Clifton v. State" on Justia Law

After a trial, Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct and was sentenced to life in prison. On appeal, Appellant challenged his conviction on several grounds but did not raise an ineffective assistance of counsel claim. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, asserting a claim of ineffective assistance of trial counsel. The district court summarily denied Appellant's petition. The Supreme Court affirmed, holding that Appellant's postconviction claim was barred by application of State v. Knaffla, which provides that claims that were not raised on direct appeal or were known or should have been known but were not raised on direct appeal, are procedurally barred. View "Sontoya v. State" on Justia Law

After the City of Moorhead annexed Americana Estates (Americana), a residential subdivision with sixty-five metered electric service accounts, the City filed a condemnation petition to begin municipal electric service to residents of Americana. After a hearing, a three-member commission of the district court awarded the Red River Valley Cooperative Power Association (RRVC), which previously served Americana, $307,214. Both parties appealed the commission's award of damages. After a jury trial, the district court awarded a total compensation award to RRVC of $385,311. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the City's valuation was inconsistent with the plain language of Minn. Stat. 216B.47 by failing to give meaningful consideration to four statutory factors and thus was properly excluded from consideration by the district court; and (2) the district court did not abuse its discretion in excluding portions of an untimely revised report submitted by the City dealing with facility replacement costs. View "City of Moorhead v. Red River Valley Coop. Power Ass'n" on Justia Law