Justia Minnesota Supreme Court Opinion SummariesArticles Posted in Education Law
Halva v. Minnesota State Colleges & Universities
In this case alleging that Minnesota State Colleges and Universities (MnSCU) failed to maintain and produce certain government data the Supreme Court reversed the decision of the court of appeals holding that Plaintiff's complaint under the Minnesota Government Data Practices Act was insufficiently pleaded and affirmed the court's holding that the Minnesota Official Records Act did not authorize a private cause of action, holding that the allegations of Plaintiff's complaint were sufficient.In his complaint, Appellant alleged that the actions of MnSCU violated both the Data Practices Act and the Official Records Act. The district court dismissed both claims, concluding that Appellant could not pursue judicial remedies under the Data Practices Act after obtaining an administrative remedy under the that and that the Official Records Act does not authorize a private cause of action. The court of appeals affirmed but decided the Data Practices Act issue on the alternate ground that the complaint was insufficiently pleaded. The Supreme Court reversed in part, holding (1) Appellant's complaint was sufficiently pleaded; and (2) the Official Records Act does not authorize a private cause of action. View "Halva v. Minnesota State Colleges & Universities" on Justia Law
State v. Boettcher
The Supreme Court reversed the judgment of the court of appeals affirming the decision of the district court ordering Defendant to pay restitution for destruction of a cabin after a jury found him guilty of burglary but did not reach a verdict on an arson charge, holding that the court of appeals erred by applying an incorrect standard.Defendant was charged with second-degree burglary and first-degree arson for the destruction of a cabin in Minnesota that was burglarized and then set on fire. The jury found Defendant guilty of burglary but could not reach a verdict on the arson charge. The State declined to retry Defendant for arson, but, after determining that the arson was factually related to the burglary, ordered Defendant to pay restitution for the fire-damaged cabin. The court of appeals affirmed, concluding that the burglary and the fire were sufficiently "factually intertwined" to allow restitution. The Supreme Court reversed, holding that the court of appeals erred by applying a factual-relationship standard rather than a direct-causation standard when considering whether fire damage to the cabin was a result of Defendant's offense. View "State v. Boettcher" on Justia Law
Posted in: Education Law
Cruz-Guzman v. State
The Supreme Court held that separation-of-powers principles do not prevent the judiciary from ruling on whether the Legislature has violated its duty under the Education Clause of the Minnesota Constitution or violated the Equal Protection or Due Process Clauses of the Minnesota Constitution.Appellants brought a putative class-action complaint on behalf of their children, public school students, claiming that the State had violated the Education, Equal Protection, and Due Process Clauses of the Minnesota Constitution. The court of appeals concluded that the claims presented nonjusticiable political questions. The Supreme Court reversed,holding that Appellants’ claims were justiciable.Specifically, the Court held (1) the courts are the appropriate domain for determinations as to whether the Legislature has violated its constitutional duty under the Education Clause; and (2) as to Appellants’ equal protection and due process claims, while the Legislature plays a critical role in education, “it is ultimately the judiciary’s responsibility to determine what our constitution requires and whether the Legislature has fulfilled its constitutional duty.” View "Cruz-Guzman v. State" on Justia Law
State v. Mikulak
The Supreme Court held that Defendant may withdraw his plea of guilty to “knowingly violat[ing]” a provision of the predatory offender registration statute, Minn. Stat. 243.166(5)(a), because Defendant alleged that he did not recall his responsibility under the law at the time of the offense. The court of appeals affirmed Defendant’s conviction, noting that “ignorance of the law is no excuse.” The Supreme Court reversed, holding (1) ignorance of the law is a defense when the charged offense prohibits a knowing violation of a statutory provision; and (2) Defendant’s factual basis failed to satisfy the accuracy requirement for a valid plea because he made statements, never withdrawn or corrected, that negated the mens rea element of the charged offense. View "State v. Mikulak" on Justia Law
Posted in: Education Law
State v. Minnesota School of Business, Inc.
The Supreme Court reversed the court of appeals affirming the district court’s dismissal of the State’s amended complaint against Minnesota School of Business and Globe University (the Schools). The State alleged that the Schools charged usurious interest rates and made loans without the required license for making private student loans at interest rates of up to eighteen percent. The State’s amended complaint sought permanent statutory injunctive relief to stop the Schools from engaging in unlicensed and usurious lending. The district court granted summary judgment for the Schools. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Schools charged usurious interest rates in violation of Minn. Stat. 334.01(1); and (2) the Schools were required to obtain a lending license under Minn. Stat. 56.01(a), and their failure to do so meant that they engaged in unlicensed lending. View "State v. Minnesota School of Business, Inc." on Justia Law
In re Expulsion of A.D. from United S. Central Pub. Schs.
A School District expelled Student for six weeks after finding a pocketknife in a purse in her locker. The Commissioner of the Department of Education affirmed. The court of appeals reversed, concluding (1) Student did not willfully violate the District’s weapons policy when she unintentionally carried the pocketknife to school, and (2) the pocketknife’s presence in Student’s locker did not bring Student or others into danger. The Supreme Court affirmed, holding (1) the record did not support the conclusion that Student deliberately and intentionally violated the District’s weapons policy; and (2) the record did not contain substantial evidence that Student exposed anyone to actual or even probable harm. View "In re Expulsion of A.D. from United S. Central Pub. Schs." on Justia Law
Tatro v. Univ. of Minn.
When Appellant Amanda Tatro was a junior in the mortuary science program at the University of Minnesota, she posted statements on Facebook which she described as "satirical commentary and violent fantasy about her school experience." Following a hearing, the Campus Committee on Student Behavior (CCSB) found Tatro had violated the student conduct code and academic program rules governing the privilege of access to human cadavers, which prohibited "blogging" about cadaver dissection. CCSB imposed sanctions, including a failing grade for an anatomy laboratory course. The University Provost affirmed the sanctions. Tatro appealed, arguing that the University violated her constitutional rights to free speech. The court of appeals upheld the disciplinary sanctions. The Supreme Court affirmed, holding that the University did not violate the free speech rights of Tatro by imposing sanctions for her Facebook posts that violated academic program rules where the academic program rules were narrowly tailored and directly related to established professional conduct standards. View "Tatro v. Univ. of Minn." on Justia Law
Emerson v. Indep. Sch. Dist. 199
Appellant was employed by School District for three school years as the activities director and for one school year as interim middle school principal. Subsequently, School District terminated Appellant's employment. Appellant filed a grievance on the ground that he was a continuing-contract employee and entitled to continuing contract rights under Minn. Stat. 122A.40. School District denied the grievance. The court of appeals affirmed. At issue on appeal was whether Appellant's employment by the school district as an activities director fell within the definition of a "teacher" under section 122A.40, which would determine whether he was entitled to continuing-contract rights under the statute. The Supreme Court affirmed, holding that Appellant was not a professional employee required to hold a license from the state department and therefore was not a "teacher" within the meaning of the continuing-contract statute. View "Emerson v. Indep. Sch. Dist. 199" on Justia Law