Justia Minnesota Supreme Court Opinion Summaries

In this dispute over Governor Walz's declaration of a peacetime emergency under the Emergency Management Act, Minn. Stat. 12.01-.61, and the executive order the Governor issued requiring that Minnesotans wear face coverings, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals dismissing the appeal as moot, holding that one issue on appeal met a mootness exception.Plaintiffs brought the underlying petition for a writ of quo warranto challenging the face-covering mandate, arguing that the Governor overstepped his powers under the Emergency Management Act and that the mask mandate violated several of their constitutional rights. The district court granted Defendants' motion to dismiss. While Plaintiffs' appeal was pending, the peacetime emergency and mask mandate ended. Consequently, the court of appeals dismissed the appeal as moot. The Supreme Court reversed in part, holding (1) the legal question of whether the Act authorizes a peacetime emergency for a public health emergency is functionally justiciable and an important issue of statewide significance that should be decided immediately; and (2) Plaintiffs' remaining challenges to the mask mandate did not meet any of the mootness exceptions. View "Snell v. Walz" on Justia Law

The Supreme Court reversed the decision of the court of appeals and remanded this case, holding that, for property to be commandeered, the government must exercise exclusive control over or obtain exclusive possession of the property such that the government could physically use it for an emergency management purpose.Appellant brought this suit arguing that his hospitality businesses were commandeered when the Governor issued emergency executive orders in response to the COVID-19 pandemic that imposed capacity limits for dining beginning in March 2020. As the owner of the commandeered property, Appellant argued, he was entitled to just compensation for the government's use under Minn. Stat. 12.34. The district court dismissed the commandeering claim, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the government exercises exclusive physical control or exclusive possession of private property when only the government may exercise control or possession of the property and the owner is denied all control over or possession of the property; and (2) remand to the district court for further proceedings was required in this case. View "Buzzell v. Walz" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court that non-homestead life estates should not be included in Marvin Schmalz's assets, holding that the term "individual" in Minn. Stat. 256B.056, subd. 4a applies only to the applicant for medical assistance.Esther Schmalz was living at a long-term-care facility when she submitted an application for medical assistance for long-term-care benefits. As part of the assessment of her husband Marvin's assets, Renville County Human Services (RCHS) included Marvin's portion of several non-homestead life estate interests that he and Esther owned. Esther appealed, arguing that the life estates should not be included in the total amount of assets that Marvin may retain. The human services judge concluded that RCHS properly denied Esther's application for medical assistance based on the inclusion of the life estate assets owned by Marvin. The Commissioner of Minnesota Department of Human Services adopted the human services judge's recommendation. The district court concluded that the non-homestead life estates should not be included in Marvin's assets, ruling that the term "individual" in section 256B.056, subd. 4a included Marvin. The Supreme Court reversed, holding that an "individual" in the statute refers to the medical assistance applicant and not a community spouse. View "In re Schmalz" on Justia Law

The Supreme Court reversed the decision of the Commissioner of Human Services determining that RS Eden, a supervised living facility where J.W. received treatment before voluntarily leaving and dying of a drug overdose five days later, was responsible for maltreatment of J.W. by neglect, holding that the Commission's decision was not supported by substantial evidence.RS Eden appealed the maltreatment determination to the court of appeals, which affirmed. The Supreme Court reversed, holding that that Commissioner's finding of maltreatment for neglect for RS Eden's failure to obtain a waiver or to confer with a prescribing physicians was not supported by substantial evidence because RS Eden complied with the rules regarding the disposition of controlled substances and took reasonable steps to protect its client. View "In re Appeal by RS Eden" on Justia Law

Appellant BCBSM, Inc. (“Blue Cross”) denied respondent James Linn’s insurance claim because the requested treatment was not considered medically necessary under the parties’ health-plan contract. After Blue Cross denied the claim, an external-review entity determined that the treatment was, in fact, medically necessary for Linn’s condition. Blue Cross paid the claim, but Linn and his wife sued Blue Cross for breach of contract. The district court granted summary judgment for Blue Cross, concluding that the treatment was not medically necessary under the contract’s plain terms and that Blue Cross fulfilled its contractual obligations when it paid for the treatment following the external review. The court of appeals reversed. Because the Minnesota Supreme Court concluded: (1) external-review decisions were independent determinations of medical necessity that did not supersede contractual definitions of medical necessity; and (2) the health-plan contract plainly excluded coverage for Linn’s claim for treatment, the Court reversed. View "Linn v. BCBSM, Inc." 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

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

A court-appointed guardian had the power to consent to necessary medical treatment for a ward under Minn. Stat. 524.5-313(c)(4)(k). Although all parties agreed that it was in the ward’s best interests to remove him from life-sustaining treatment, the guardian argued that court approval was not required before he could consent to remove the ward from life support systems. The district court concluded that guardians do not have the power to direct the removal of life support without prior court approval. The court of appeals reversed, concluding that the medical-consent power granted to a guardian under section 524.5-313(c)(4) includes the power to authorize disconnection of a ward’s life-support systems without authorization from the district court. The Supreme Court affirmed, holding that the power of a guardian to consent to necessary medical treatment for a ward under the statute includes the power to consent to the removal of a ward from life support systems, without court approval, when all interested parties agree that removal is in the ward’s best interest. View "In re Guardianship of Tschumy" on Justia Law

Employee was injured in a work-related accident. Employee obtained approval for surgery from a union-sponsored benefit plan (the Fund) and proceeded with the surgery at a Hospital. After a hearing, a workers’ compensation judge concluded that the surgery was not reasonable and necessary and ordered Employer to reimburse the Fund for the medical bills but also concluded that Employer could seek reimbursement of the expenses from the medical providers. The Hospital was not given notice of that hearing. Before a second hearing on Employer’s request for reimbursement, the Hospital intervened. The compensation judge ordered the Hospital to reimburse Employer. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that the automatic-reimbursement rule announced in Brooks v. A.M.F., Inc. should be extended to the Hospital because it was not given notice of the first hearing. The Supreme Court reversed after declining to extend its decision in Brooks and require automatic payment of a medical provider’s treatment expenses when an employer fails to give the medical provider notice of its right to intervene in a workers’ compensation proceeding to determine responsibility for those expenses, holding that the Hospital was not entitled to automatic payment of its medical bills for Employee’s treatment. Remanded. View "Gamble v. Twin Cities Concrete Prods." on Justia Law