Justia Minnesota Supreme Court Opinion Summaries

After being arrested and jailed following an alleged assault on hospital staff, an individual was found incompetent to proceed in a criminal case and was civilly committed as mentally ill. The district court appointed counsel to represent him in the civil commitment proceedings. Under Minnesota law at the time, civilly committed patients in jail were entitled to priority admission to a state-operated treatment program within 48 hours of the commitment order. Despite this, the individual remained in jail for over a month. His court-appointed counsel then petitioned for writs of mandamus and habeas corpus to enforce his statutory right to timely admission to a treatment facility.The district court granted the writ of mandamus, ordering the Commissioner of Human Services to admit the patient to a treatment facility, and directed the county sheriff to transport him accordingly. When the county refused to pay the appointed counsel for work performed in the extraordinary writ proceedings, the district court ordered the county to pay, finding that the counsel’s work was directly related to the civil commitment and that representation extended to all proceedings under the relevant statute.The Minnesota Court of Appeals reversed the district court’s order regarding payment for the extraordinary writ proceedings, holding that such proceedings were not “under” the civil commitment statute and thus did not entitle the patient to court-appointed counsel or require payment by the county. However, the appellate court affirmed the order for payment for representation in the initial commitment proceedings.The Minnesota Supreme Court reversed the appellate court’s decision, holding that a petition for an extraordinary writ to enforce a civilly committed patient’s right to timely admission to a state-operated treatment program is a proceeding under the civil commitment statute. Therefore, the patient is entitled to the assistance of court-appointed counsel in such proceedings, and the county must pay a reasonable sum for that representation. View "In the Matter of the Civil Commitment of: Swope" on Justia Law

A county agency filed a petition to terminate a father’s parental rights to his child. The father consented to the voluntary termination and submitted a written affidavit to that effect. At a subsequent hearing, he confirmed his consent and understanding of the consequences. The district court relied on his admission and other evidence to terminate his parental rights, finding the termination was in the child’s best interests. The father did not file any post-trial motions but initially appealed on jurisdictional grounds, later voluntarily dismissing and then seeking to reinstate his appeal. The Minnesota Court of Appeals ultimately affirmed the termination, limiting its review to the jurisdictional issue.Over a year after the termination order became final, the father filed a motion in the district court to withdraw his admission, alleging it was obtained through fraud, undue influence, and duress. The district court struck the motion, reasoning that the father lacked standing because his parental rights had already been terminated and the time to challenge the order had expired. The Minnesota Court of Appeals dismissed his appeal, agreeing that he lacked standing to file the motion after finality.The Minnesota Supreme Court reviewed the case to clarify the timeframe for withdrawing an admission to a petition for termination of parental rights under Minnesota Rule of Juvenile Protection Procedure 56.03, subdivision 5(b). The court held that a person may file a motion to withdraw such an admission at any time if withdrawal is necessary to correct a manifest injustice, regardless of other time limits in the rules. The court further held that the district court must determine whether the motion makes a prima facie showing of manifest injustice and, if so, must hold an evidentiary hearing. The Supreme Court reversed the court of appeals and remanded for further proceedings. View "In the Matter of the Welfare of the Child of: B.D.D. and D.A.A." on Justia Law

A father, Travis W. Kalis, was ordered by a district court in 2013 to pay $1,145 per month in child support to the mother of his children, Leslie E. Sheehy Lee. In 2015, the parties discussed modifying this amount through a private agreement, but no written agreement was executed. Despite this, Kalis began making reduced payments of $1,000 per month via Venmo, which later decreased to $500 per month. In 2022, after Kalis stopped making prompt payments, Sheehy Lee sought enforcement of the original court order through the county child support agency, which notified Kalis that he owed over $30,000 in arrearages.A child support magistrate (CSM) concluded that the parties had reached an extrajudicial agreement to modify Kalis’s child support obligation and determined that Kalis did not owe any arrearages. Sheehy Lee sought review in the district court, arguing that the forgiveness of arrearages was an impermissible retroactive modification of the child support order. The district court declined to grant relief, and the court of appeals affirmed, concluding that the parties had reached a fair and reasonable agreement.The Minnesota Supreme Court reviewed the case and held that extrajudicial agreements to modify child support orders are invalid as a matter of law. The court emphasized that child support orders can only be modified by a court and within the limits set by Minnesota Statutes section 518A.39, subdivision 2(f), which prohibits retroactive modifications of child support orders except from the date of service of notice of the motion to modify. The court also clarified that the statutory exception allowing for an alternative effective date applies only to subsequent court-issued child support orders, not to extrajudicial modifications. The decision of the court of appeals was reversed, and the case was remanded for further proceedings. View "Lee v. Kalis" on Justia Law

The Supreme Court of Minnesota affirmed the conviction of John Ishmael Bradley, III, who was charged with second-degree assault and felony domestic assault for striking his girlfriend over the head with a broom handle. Bradley challenged his convictions, claiming the broom handle was not a dangerous weapon and that his two convictions for one assaultive act was improper.The court ruled that there was sufficient evidence for the jury to conclude that the broom handle was a dangerous weapon. The court determined that an object is "likely to produce death or great bodily harm" if it is used in a manner where death or great bodily harm is a probable or reasonably expected result. Given the manner in which Bradley used the broom handle, the court found there was enough evidence to sustain this claim.The court also examined whether Bradley could be convicted of both second-degree assault and domestic assault for the same criminal act. The court rejected Bradley's argument that domestic assault is a "lesser degree" of second-degree assault. The court concluded that the term "degree" in the phrase "lesser degree of the same crime" in Minnesota Statutes section 609.04, subdivision 1(1), is an unambiguous technical term referring to offenses within an ordinal statutory scheme. Therefore, domestic assault is not a lesser degree of second-degree assault, and the court affirmed both convictions. View "State of Minnesota vs. Bradley" on Justia Law

The case revolves around the interpretation of the term "resources" as used in the criminal restitution statute, Minnesota Statutes section 611A.045, subdivision 1(a)(2). Specifically, the case examines whether the equity in a defendant's home, which he co-owns with his spouse, can be considered as a "resource" when awarding restitution. The appellant, Joshua Henry Baion Cummings (Baion), was convicted of one count of theft by false representation and was ordered to pay restitution. The district court considered the equity in Baion’s home as one of his resources when determining the amount of restitution. Baion appealed, arguing that the equity in a home owned with a non-defendant spouse cannot be considered a resource under the restitution statute. The Court of Appeals affirmed the district court's decision. The Minnesota Supreme Court also affirmed, holding that the term “resources” in the restitution statute unambiguously means useful and valuable possessions, and that home equity, even when the home is co-owned with a non-defendant spouse, may be such a possession. View "State v. Cummings" on Justia Law

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

The Supreme Court reversed the judgment of the court of appeals dismissing Appellants' appeal of the dismissal of their petition for permanent third-party custody of their great niece, K.J., holding that the court of appeals erred in dismissing the appeal for failure to timely serve the guardian ad litem with a notice of appeal under Minn. R. Civ. App. P. 103.01, subdivision 1.After Appellants filed their petition the district court appointed a guardian ad litem. A referee approved a stipulation of shared joint legal and physical custody of K.J. by Respondent, K.J.'s mother, and K.J.'s father. After a hearing, the court dismissed Appellants' petition for third-party custody. The court subsequently discharged the guardian ad litem, after which Appellants appealed. The court of appeals dismissed the appeal for failure to timely serve the guardian ad litem under Rule 103.01, subdivision 1. The Supreme Court reversed, holding (1) the guardian ad litem was no longer a party to the action once she was discharged by the district court; and (2) Rule 103.01, subdivision 1 does not require service of a notice of appeal on a former party whose dismissal is not itself the subject of the appeal. View "Blakey v. Jones" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding the district court's award of attorney fees based on conduct that occurred outside the context of litigation, holding that the district court exceeded the scope of its inherent authority when it awarded attorney fees.In this case arising from a post-dissolution, mediated settlement agreement between Appellant and Respondent regarding the treatment of a college savings account. The agreement required that the account be awarded to the parties' daughter when she turned twenty-one years old, but when their daughter reached that age Appellant took no action to transfer the account. Ultimately, after intervention on the part of the district court, the transfer became effective. Respondent moved for conduct-based attorney fees under Minn. Stat. 518.14. The district court granted the motion.. The court of appeals affirmed. The Supreme Court reversed, holding that the district court exceeded the scope of its inherent authority in awarding attorney fees because the award was not necessary to the performance of a judicial function. View "Buckner v. Robichaud" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals determining that the juvenile court had subject-matter jurisdiction over this case, rejecting Father's statutory interpretation argument about the interplay between the child protection and predatory offender registration statutes, and affirming the termination of Father's parental rights by the juvenile court, holding that Father was not entitled to relief on his claims of error.While Father was incarcerated for an offense that arose out of the same circumstances as an offense enumerated in the predatory offender registration statute Mother gave birth to H.Q., who was adjudicated as a child in need of protection or services. The juvenile court terminated Father's parental rights to H.Q. because of his conviction. The court of appeals affirmed the juvenile court's termination of Father's parental rights. The Supreme Court affirmed, holding that the juvenile court did not err in determining that clear and convincing evidence supported the statutory ground for termination in Father's case. View "In re Welfare of Child of S.B.G." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the district court rejecting Wife's action against Husband seeking half of his retirement account or, alternatively, an equitable portion of the account, holding that the parties' omission of their largest asset from the dissolution decree made it impossible for the district court to determine whether the settlement was equitable.After the parties' marriage was dissolved through a joint petition for marriage dissolution Wife filed this action seeking half of Husband's retirement account. In objecting, Husband argued that he and Wife had intentionally omitted his retirement account from their joint petition pursuant to an unwritten side agreement. The district court concluded that the relief Wife sought was beyond the scope of a ** proper enforcement of clarification order and was time-barred to the extent it sought to reopen the decree. The court of appeals affirmed. The Supreme Court reversed, holding (1) district courts have the power to address omitted assets that fall outside the scope of the grounds set forth in Minn. Stat. 518.145, subd. 2 for reopening a dissolution decree; and (2) the parties' omission from the decree of their largest asset rendered it impossible for the district court to determine whether the settlement was equitable. View "In re Marriage of Pooley" on Justia Law