Justia Minnesota Supreme Court Opinion Summaries

After Employee ended his employment with Employer he applied for and received state unemployment benefits from the Department of Employment and Economic Development (DEED) and supplemental unemployment benefits (SUB) through a plan offered by Employer. DEED determined that the SUB plan payments counted as “wages” under Minn. Stat. 268.035(29)(A) and determined that Employee had been overpaid state unemployment benefits. An unemployment law judge affirmed. The court of appeals reversed, concluding that Employee was entitled to keep the state unemployment benefits. The Supreme Court affirmed, holding the SUB plan payments Employee received were not “wages” for purposes of his eligibility for state unemployment benefits, and therefore, Employee was not overpaid state unemployment benefits. View "Engfer v. Gen. Dynamics Advanced Info. Sys., Inc." on Justia Law

Relators were sixteen electric cooperatives located in Minnesota. The cooperatives filed amended sales-tax returns for tax periods spanning the years 2004-06 to recover sales taxes they had paid for the portion of the revenues that they later converted into equity. The Commissioner of Revenue initially granted the refunds claimed on the cooperatives’ amended returns. However, the Commissioner later determined that the refund was made in error and assessed the cooperatives to recover the amounts refunded to them. The cooperatives appealed. The tax court concluded that the cooperatives were not legally entitled to sales-tax refunds for any earnings that they later converted into equity and that the challenged assessments were timely. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) electric cooperatives may not reclassify portions of monthly payments by their customers as equity contributions and receive sales-tax refunds based on the reclassification; and (2) when the Commissioner assesses a taxpayer based on a deficiency created by an erroneous refund, the two-year statute of limitations for erroneous refunds generally applies. View "Connexus Energy v. Comm’r of Revenue" on Justia Law

Based on an indirect audit that the Commissioner of the Minnesota Department of Revenue conducted of the sales and use tax returns for Conga Corporation for the tax periods from January 1, 2007 through March 31, 2010, the Commissioner determined that Conga had unreported revenues for the relevant tax periods and issued an order assessing additional sales, use, and entertainment taxes, plus penalties and interest. The tax court affirmed the Commissioner’s order with respect to the assessment of 2007 taxes but reversed with the penalty assessment for tax years 2008-2010, concluding that the Commissioner’s decision to use an indirect audit was not supported by the record. The Supreme Court reversed, holding that the Commissioner’s decision to use an indirect audit to assess taxes was supported by the record. Remanded. View "Conga Corp. v. Comm’r of Revenue" on Justia Law

Reichmann Land and Cattle, LLP managed a winter feeding facility. In 2011, the Minnesota Pollution Control Agency (MPCA) issued an administrative order requiring Reichmann to obtain national-pollutant-discharge-elimination-system (NPDES) and state-disposal-system (SDS) permits or discontinue the winter feeding operation. Reichmann requested a contested case hearing. An administrative law judge (ALJ) concluded that Reichmann’s winter feeding fields constituted a “concentrated animal feeding operation” and were not “pastures.” Therefore, Reichmann was required to apply for an NPDES/SDS permit. The Commissioner of the MPCA adopted the findings and conclusions of the ALJ. The court of appeals affirmed the Commissioner’s conclusion that Reichmann must apply for an SDS permit but reversed the Commission’s requirement that Reichmann must apply for an NPDES permit. The Supreme Court affirmed, holding (1) Reichmann need not obtain an NPDES permit because its winter feeding facility is not an animal feeding operation as required by 40 C.F.R. 122.23(b)(1); and (2) Reichmann is required to obtain an SDS permit because it does not qualify for the pasture exemption. View "In re Reichmann Land & Cattle, LLP" on Justia Law

Respondent sustained injuries while employed by Employer. In 2010, Respondent sought workers’ compensation benefits, claiming that as a result of his injury he developed complex regional pain syndrome (CRPS) and that he was entitled to compensation for certain medical expenses, including expenses incurred for the implantation of a spinal cord neurostimulator. The compensation judge concluded that Respondent had failed to show that the effects of his work-related injury included CRPS and therefore necessitated a neurostimulator. The Workers’ Compensation Court of Appeals (WCCA) affirmed. In 2013, Respondent filed a second request for medical benefits seeking compensation for the expenses related to the replacement of his neurostimulator. The compensation judge dismissed the claim, concluding that Respondent’s 2013 claim was barred by res judicata and collateral estoppel. The WCCA reversed. The Supreme Court vacated the decision of the WCCA, holding (1) res judicata did not preclude Respondent’s 2013 claim; but (2) in resolving the 2013 claim, the compensation judge did not determine whether Respondent’s medical condition had changed or new material facts had emerged, a determination that was necessary in order to resolve whether collateral estoppel precluded the 2013 claim. Remanded. View "Mach v. Wells Concrete Prods. Co." on Justia Law

Yer Sumner was injured when she fell while working for Jim Lupient Infiniti. Sumner filed a claim petition for workers’ compensation benefits. Lupient denied primary liability. After Sumner filed her claim petition, eleven entities (collectively, Intervenors), including two health-care providers that provided treatment to Sumner (collectively, Relators), moved to intervene as of right. Lupient objected to the compensability of the services for which several Intervenors, including Relators, sought reimbursement. Intervenors had their claims for reimbursement denied when they failed to attend a hearing before a compensation judge. Relators and Sumner appealed. The Workers’ Compensation Court of Appeals affirmed the denial of Relators’ reimbursement claims. The Supreme Court affirmed, holding that, because Relators were absent from the hearing, and none of the exceptions to the attendance requirement was met, the compensation judge did not err when he denied Relators’ claims for reimbursement. View "Sumner v. Jim Lupient Infiniti" on Justia Law

Appellant was denied a promotion after based on the results of a civil service test conducted by the Richfield Police and Fire Civil Service Commission. Appellant filed a petition for writ of certiorari with the Court of Appeals, arguing that the Commission’s promotional process failed to meet the requirements of Minn. Stat. 419.06(9). The Supreme Court reversed, holding (1) the Court of Appeals erred by determining that the term “records” under section 419.06(9) includes a candidate’s interview responses at the time the candidate is applying for a promotion; and (2) the Commission violated section 419.06(9) when it failed to consider records “kept in the regular course of the administration of civil service” as required by statute. View "Peterson v. Richfield Civil Serv. Comm’n" on Justia Law

RDNT, LLC, which provided assisted living and skilled nursing services, owned a campus consisting of two buildings. RDNT submitted an application to the City of Bloomington for a conditional use permit, seeking to expand its services by adding a third building to the campus. The City Council denied RDNT’s application, giving four reasons for its decision. The district court reversed the denial of RDNT’s application, holding that the City misapplied certain standards, misrepresented the impact of certain studies, and ignored certain evidence. The court of appeals reversed, concluding that the City appropriately exercised its discretion. The Supreme Court affirmed, holding that the City’s decision was not unreasonable arbitrary or capricious, as the City based its decision on a legally and factually sufficient ground, and the City properly considered RDNT’s proposed traffic-mitigating conditions. View "RDNT, LLC v. City of Bloomington" on Justia Law

Employee fractured her ankle on a staircase at her workplace. A workers’ compensation judge awarded benefits to Employee, concluding that the injuries “arose out of” her employment. The Workers’ Compensation Court of Appeals (WCCA) affirmed, relying on its previous decision in Dykhoff v. Xcel Energy. The Supreme Court stayed Employer’s appeal while it considered Dykhoff. The Supreme Court then reversed the WCCA’s decision in Dykhoff and remanded. On remand, the WCCA again affirmed, this time applying the “increased risk” test, which requires an employee to to show that her workplace exposed her to a risk of injury that was increased over what she would face in her everyday life. The WCCA relied on two factual findings to conclude that Employee’s injury was compensable under the increased risk test. The Supreme Court reversed, holding that the WCCA’s decision was manifestly contrary to the evidence. Remanded. View "Arrowhead Senior Living Cmty. v. Kainz" on Justia Law

Plaintiff filed a putative class action against Defendant, a former employee of the Minnesota Department of Human Services (DHS), alleging that Defendant accessed Driver and Vehicle Services records without authorization in violation of the federal Driver’s Privacy Protection Act (DPPA). DHS denied Defendant’s request for defense and indemnification, concluding that Defendant’s actions were outside the scope of his employment. Defendant filed a petition for a writ of certiorari with the court of appeals seeking judicial review of DHS’s decision. The court of appeals remanded the matter to DHS with instructions to grant Defendant’s request, concluding that DHS’s decision was not supported by substantial evidence. The Supreme Court vacated the decision of the court of appeals, holding that the court of appeals did not have jurisdiction over Defendant’s petition for a writ of certiorari and therefore did not have authority to hear this appeal. View "Nelson v. Schlener" on Justia Law