Justia Minnesota Supreme Court Opinion Summaries

KSTP-TV (KSTP) requested videos that contained recordings of two incidents on Metro Transit buses. Metro Transit, a division of Metropolitan Council, had evaluated the conduct of the drivers of both buses but did not discipline either of them. Metro Transit refused KSTP’s requests, concluding that the videos contained private personnel data on the bus drivers, and therefore, the videos were exempt from disclosure. KSTP filed a complaint under the Minnesota Government Data Practices Act with the Office of Administrative Hearings. An administrative law judge concluded that the recordings were public data and, accordingly, that KSTP was entitled to the video data. The court of appeals affirmed. The Supreme Court reversed, holding (1) video data from public buses is personnel data under the Data Practices Act only if it is maintained exclusively because an individual subject of the data is a government employee; and (2) to determine whether particular data is personnel data under the Act, a government entity must classify the data at the time a request for access to the data is made. Remanded to the Office of Administrative Hearings for further proceedings. View "KSTP-TV v. Metropolitan Council" on Justia Law

The Minnesota Department of Human Services (DHS) assessed surcharges against seven hospitals and hospital systems (collectively, the Hospitals) on their net patient revenue under Minn. Stat. 256.957(2). The Hospitals appealed their surcharge assessments for various months, alleging that federal law preempted the surcharge to the extent it required them to pay a surcharge on revenues obtained from insurance carriers that participated in the Federal Employee Health Benefits Program and the TRICARE program. The Commissioner of DHS denied the claim. The court of appeals affirmed. The Supreme Court affirmed, holding that the surcharge was not preempted by federal law. View "In re Consolidated Hosp. Surcharge Appeals of Gillette Children’s Specialty Healthcare" on Justia Law

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

Respondent suffered a work-related back injury. Respondent and her employer entered into a “full, final, and complete” settlement of Respondent’s claims for workers’ compensation benefits related to that injury. Respondent later filed a claim petition seeking additional benefits for the back injury, alleging a lumbar spine injury with consequential depression and anxiety. The employer moved to dismiss the petition on the ground that Respondent was first required to bring a motion to vacate the existing settlement agreement before bringing a new claim. The workers’ compensation judge denied the motion, concluding that the settlement agreement did not foreclose a later claim for consequential psychological injury. The Workers’ Compensation Court of Appeals affirmed, concluding that the settlement agreement did not foreclose claims from the same incident that were not mentioned in the agreement without evidence that those claims were contemplated by the parties at the time they entered into the agreement. The Supreme Court reversed, holding that the language of the settlement agreement was sufficient settle conditions and complications that arise out of, and are a consequence of, Respondent’s workers’ compensation injury. View "Ryan v. Potlatch Corp." on Justia Law

When Daniel Berglund refused to file Minnesota income tax returns for tax years 2008, 2009, and 2010, the Minnesota Department of Revenue prepared and filed returns for Berglund and mailed him Notices of Commissioner Filed Returns for the relevant tax years. In total, the Commissioner of Revenue assessed $668,840 in unpaid taxes, penalties, and interest for the three-year period. Berglund appealed, arguing that because the returns did not contain the Commissioner’s signature they were invalid and unenforceable. The tax court granted the Commissioner’s motion for judgment on the pleadings, finding that the lack of a “manual signature” was of no consequence. The Supreme Court affirmed, holding that the relevant statutes do not require that the Commissioner sign commissioner-filed returns in order for those returns to be valid. View "Berglund v. Comm’r of Revenue" on Justia Law

Kelly Dennis was allegedly injured in the course of his employment with The Salvation Army. Dennis filed a claim for workers’ compensation benefits, but The Salvation Army and its insurer (collectively, Relators) denied liability. The compensation judge awarded Dennis benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed. Within thirty days, Relators filed a petition for a writ of certiorari with the clerk of the appellate courts. Relators, however, failed to serve a cost bond on the WCCA as required by Minn. Stat. 176.471. Relators subsequently served an untimely cost bond on the WCCA. At issue before the Supreme Court was whether timely service of the cost bond was mandatory to have the WCCA order reviewed by the Supreme Court on certiorari. The Supreme Court discharged the writ of certiorari and dismissed the appeal, holding that Relators’ failure to file the cost bond within the thirty-day period to appeal was fatal to their appeal. View "Dennis v. Salvation Army" on Justia Law

Employee was injured while participating in an annual employee-recognition event sponsored by Employer. Employee petitioned for workers’ compensation benefits, but Employer denied liability, arguing that Employee’s injury was excluded from coverage under Minn. Stat. 176.021(9), which exempts from workers’ compensation coverage injuries incurred during “voluntary recreational programs.” A compensation judge concluded that the employee-recognition event was not a “voluntary” program because it occurred during Employee’s shift, and he was required to attend in order to obtain his wage without sacrificing his vacation time. The Workers’ Compensation Court affirmed. The Supreme Court affirmed, holding (1) an employer-sponsored recreational program is not “voluntary” when it takes place during work hours and employees must either attend the event or risk forfeiting pay or benefits; and (2) the relevant inquiry when applying section 176.021(9) is whether the program is voluntary, not whether individual recreational activities within the program are voluntary. View "Shire v. Rosemount, Inc." on Justia Law

When Respondents filed their Minnesota tax return for tax year 2007, they claimed they were part-year residents of the state. After an audit, the Commissioner of Revenue determined that Respondents were full-year residents of Minnesota for that year and assessed additional income tax, penalties, and interest. On appeal, the tax court granted summary judgment in favor of Respondents, concluding that Respondents were not “residents” under Minn. Stat. 290.01. The Supreme Court reversed, holding (1) the statute is ambiguous; and (2) the tax court’s interpretation of the statute was erroneous. Remanded to the tax court for a recalculation of Respondents’ tax debt in accordance with this opinion. View "Curtis G. v. Comm’r of Revenue" on Justia Law

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