Articles Posted in Minnesota Supreme Court

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After a jury trial, Defendant was convicted of nine counts, including one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder, stemming from an incident in which Defendant fired a semiautomatic rifle at Joseph Rivera and two of Rivera's friends. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant's pretrial motion to dismiss the indictment, as any alleged misconduct by the State did not substantially influence the grand jury's decision to indict; (2) admitted Defendant's taped statement to police, as the statement was voluntary made; (3) admitted a photograph of Rivera as a child, as the photograph was admissible as spark of life evidence; (4) denied Defendant's motion for a mistrial based on a law enforcement officer's testimony that Defendant was truant and once swore at a teacher in high school; and (5) denied Defendant's request for surrebuttal closing argument, because even if the district court erred in denying the request, the error was harmless beyond a reasonable doubt. View "State v. Morrow" on Justia Law

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After a jury trial, Defendant was convicted of first-degree murder by drive-by shooting and first-degree premeditated murder. Defendant appealed, arguing that the trial court erred in admitting out-of-court statements made by his wife and cell phone records obtained without a warrant. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting Defendant's wife's statement under Minn. R. Evid. 807; and (2) the district court did not err in finding Defendant had no subjective expectation of privacy in the cell phone records at issue under the Supreme Court's decision in State v. Gail, and therefore, the admission of the cell phone records did not violate Defendant's constitutional rights. View "State v. Griffin" on Justia Law

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After a jury trial, Defendant was convicted of third-degree criminal sexual conduct and sentenced to forty-eight months in prison. As part of the sentencing order, the trial court ordered Defendant to pay restitution. More than ninety days after entry of the order imposing Defendant's initial sentence, the court amended the restitution portion of Defendant's initial sentence. The State appealed the amended sentencing order, but the court of appeals dismissed the appeal because it was not filed within ninety days after the initial imposition of Defendant's sentence. The Supreme Court reversed, holding (1) the issuance of an order amending the restitution portion of a sentence constitutes a "sentence imposed" within the plain language of the relevant statute, such that the State had ninety days to appeal the amended sentencing order from the date it was entered; and (2) because the State appealed the amended sentencing order within ninety days, the appeal was timely. Remanded. View "State v. Borg" on Justia Law

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The Commissioner of Revenue ordered Sharon Soyka to pay income taxes, penalties, and interest for the 2007 tax year. Soyka had sixty days to appeal the Commissioner's order to the tax court. Instead, Soyka filed her notice of appeal to the Commissioner, who forwarded the documents to the tax court. The tax court dismissed Soyka's appeal as untimely filed because Soyka did not file her notice of appeal until more than a month after it was due and because Soyka did not file a request seeking an extension of time. The Supreme Court affirmed the tax court's dismissal of Soyka's appeal, holding (1) Soyka's failure to file her notice of appeal before the expiration of the statutory deadline deprived the tax court of subject matter jurisdiction over the appeal; and (2) because the tax court did not receive a copy of Soyka's extension request until the statutory period had expired, Soyka was not entitled to an extension of time to file her appeal. View "Soyka v. Comm'r of Revenue" on Justia Law

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Appellant was discharged after testing positive to a drug test. Nearly three years after being discharged, Appellant filed an action against Respondents, his former employers, alleging that Respondents violated various provisions of the Drug and Alcohol Testing in the Workplace Act, namely Minn. Stat. 181.953. Respondents filed a motion to dismiss, asserting that Appellant's claim was barred by the two-year statute of limitations in Minn. Stat. 451.07(1) for, inter alia, libel, slander, "or other tort resulting in personal injury." The district court granted the motion, concluding that a claim under section 181.953(10) was a "tort resulting in personal injury." The court of appeals affirmed. The Supreme Court reversed, holding (1) Appellant's claim was subject to the six-year statute of limitations under Minn. Stat. 541.05(1)(2) as a cause of action "upon liability created by statute"; and (2) therefore, Appellant's complaint was not time-barred. Remanded. View "Sipe v. STS Mfg., Inc." on Justia Law

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After a jury trial, Appellant was convicted of first-degree premeditated murder and second-degree murder. Appellant appealed, asserting, among other issues, that the trial court erred in denying his motion to suppress statements he made to police because he was in custody when he made the statements and had not received a Miranda warning. The Supreme Court affirmed Defendant's convictions, holding (1) any error the trial court may have made in denying Appellant's motion to suppress statements he made to police was harmless beyond a reasonable doubt; and (2) the evidence was sufficient to support Appellant's conviction. View "State v. Sterling" on Justia Law

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The district court issued domestic abuse no contact orders pursuant to Minn. Stat. 629.75(1) prohibiting Appellant from contacting his wife. After Appellant allegedly contacted his wife, he was charged with two felony violations. Appellant moved to dismiss the charges, contending that section 629.75(1) violates due process because it fails to provide adequate notice and an opportunity to be heard and encourages arbitrary and discriminatory enforcement. The district court granted Appellant's motions, concluding that the statute provides defendants with no procedural due process and grants judges unfettered discretion in determining whether to issue a domestic abuse no contact order. The court of appeals reversed. The Supreme Court affirmed, holding that, on its face, the statute (1) ensures that a defendant will receive notice of the conditions to be imposed and an opportunity to challenge those conditions in a constitutionally sufficient proceeding before the court imposes a domestic abuse no contact order; and (2) is not unconstitutionally vague because it does not encourage arbitrary and discriminatory enforcement. View "State v. Ness" on Justia Law

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Taxpayer was a trust fund that purchased property in Ramsey County. Taxpayer sought an exemption from taxation for the property on the basis that it was a "seminary of learning" and therefore exempt under Minn. Stat. 272.02(5). The County allowed an exemption for several years but later determined that the property was no longer exempt and assessed the property. Taxpayer subsequently filed a petition challenging the assessment. After the tax court denied Taxpayer's motion to amend or supplement its petition, Taxpayer sought certiorari review. The Supreme Court dismissed the writ of certiorari, holding that it lacked jurisdiction because the tax court's order was not reviewable either as a final order under Minn. Stat 271.10 or in the interests of justice under Minn. R. App. P. 105.01. View "Metro. Sheet Metal Journeyman & Apprentice Training Trust Fund v. County of Ramsey" on Justia Law

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The State charged Defendant with two counts of second-degree murder for the stabbing death of Tina San Roman and second-degree assault and attempted second-degree murder for the stabbing of a second victim, O.A.R. A jury acquitted Defendant on the murder counts but deadlocked on the two other counts relating to the attack on O.A.R. In preparation for a retrial on the unresolved counts, the district court (1) excluded the State's evidence related to San Roman's death, concluding that the evidence would mislead the jury and substantially prejudice Defendant; then (2) granted Defendant's motion to dismiss the remaining counts, concluding (i) Defendant could not present his alternative-perpetrator defense without using evidence relating to San Roman's death, and (ii) the exclusion of Defendant's alternative-perpetrator evidence would violate Defendant's right to present a complete defense. The Supreme Court reversed and remanded, holding that the exclusion of the alternative-perpetrator evidence did not violate Defendant's due process right to present a complete defense. View "State v. Pass " on Justia Law

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Appellant was convicted of murder and sentenced to life in prison. The Supreme Court affirmed the conviction. After unsuccessfully filing four petitions for postconviction relief, Appellant filed a "Motion for DNA Analysis" under Minn. Stat. 590.01(1)(a) requesting DNA testing of the victim's underwear. The postconviction court construed Appellant's motion as his fifth petition for postconviction relief and found the petition was procedurally barred. The Supreme Court affirmed without addressing the issue of whether the postconviction court erred when it treated Appellant's motion as a petition for postconviction relief, holding (1) Appellant's motion for DNA testing failed to satisfy the requirements of Minn. Stat. 590.01(1)(a) as a matter of law; and (2) even if it was proper to treat Appellant's motion as a petition for postconviction relief, Appellant's claim was time-barred. View "Wayne v. State" on Justia Law