Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Minnesota Supreme Court
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In this subrogation action, appellant Insurer sought to recover payments it made to its Insured for the repair of water damage allegedly caused by the negligence of respondent, the commercial tenant of Insured. The district court dismissed Insurer's subrogation claim as a matter of law, relying on the court of appeals decision in United Fire & Casualty Co. v. Bruggeman. The court of appeals affirmed. The Supreme Court reversed after rejecting the rule from Bruggeman, holding that the question of whether an insurer may pursue a subrogation action against the tenant of an insured, when the tenant's negligence caused damage to the insured's property, must be answered by examining the unique facts and circumstances of each case. Remanded. View "RAM Mut. Ins. Co. v. Rusty Rohde" on Justia Law

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At issue in this case was whether the workers' compensation courts had the authority to hear a petition filed by Insured to determine whether Insurer had a duty to defend and indemnify Insured under a policy for workers' compensation insurance. Insurer moved to dismiss Insured's petition, arguing that the compensation judge did not have subject matter jurisdiction to hear the petition because it asserted a breach of contract claim rather than one arising under the workers' compensation laws. The compensation judge disagreed and denied Insurer's motion to dismiss. The workers' compensation court of appeals (WCCA) affirmed, concluding that Insured was seeking a declaration that its insurance coverage with Insurer was still "in effect," a question within the compensation judge's authority to decide. The Supreme Court affirmed, holding that the workers' compensation courts had jurisdiction to decide the issues presented in Insured's petition for declaration of insurance coverage, as the real nature of the claim was whether Insured's insurance coverage was in effect, a question that was within the authority of the compensation judge to answer. View "Giersdorf v. A & M Constr., Inc." on Justia Law

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In these two cases, Petitioners, members of the Minnesota Legislature and others, filed petitions pursuant to Minn. Stat. 204B.44 seeking an order requiring Mark Ritchie, the Minnesota Secretary of State, to use the titles designated by the Minnesota Legislature for two proposed constitutional amendment ballot questions that were scheduled to appear on the November 2012 general election ballot. Petitioners contended that by failing to use the title designated by the Legislature for each ballot question, Respondents failed to comply with the statutory requirement to "provide an appropriate title" for the ballot question. The Supreme Court granted the petitions, holding that when the Legislature has included a title for a ballot question in the bill proposing a constitutional amendment, the "appropriate title" the Secretary of State must provide for that ballot question is the title designated by the Legislature. View "Limmer v. Ritchie" on Justia Law

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This action was brought under Minn. Stat. 204B.44 seeking to correct an alleged error in the preparation of the ballot for the general election. Specifically, Petitioners sought to prevent the people of Minnesota from voting on the question of whether photographic identification should be required to vote in Minnesota. Without expressing an opinion as to the merits of changing Minnesota law to require photographic identification to vote, the Supreme Court concluded that Petitioners were not entitled to relief, holding that Petitioners did not meet their burden of demonstrating that there was an error that required the judiciary to intercede. View "League of Women Voters Minn. v. Ritchie" on Justia Law

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A compensation judge found Respondent was barred from receiving workers' compensation benefits because his written notice of injury, given nearly two years after his last day of work, was not timely and because Respondent's employer did not have actual knowledge that Respondent's back problems were work-related. The workers' compensation court of appeals (WCCA) reversed, concluding that a reasonable person in Respondent's position would not have known his injury was compensable until Respondent's doctors provided written reports to Respondent's attorney establishing a relationship between Respondent's back problems and his job duties. The Supreme Court reversed the WCCA and affirmed the denial of benefits, holding (1) the WCCA erred in overturning the compensation judge's finding that Respondent failed to give timely notice to his employer of his work-related injury; and (2) the compensation judge did not err in finding that the employer did not have actual knowledge of such an injury. View "Anderson v. Frontier Commc'ns" on Justia Law

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At issue in this case was whether a school district is subject to the campaign-finance reporting requirements found in Minn. Stat. 211A and whether the complaint in this matter stated a claim under Minn. Stat. 211B.06, which prohibits the dissemination of false campaign material. The Supreme Court held (1) a school district is a "corporation" under section 211A.01 and therefore can qualify as a "committee" subject to chapter 211A's campaign-finance reporting requirements if it acts "to promote or defeat a ballot question"; (2) because Appellants' complaint, filed with the Office of Administrative Hearings, stated a prima facie claim that the school district here was a "committee" under section 211A.01 that promoted a ballot question, the ALJ assigned to the matter erred in dismissing the complaint without an evidentiary hearing; and (3) the complaint failed to state a prima facie violation of section 211B.06 with respect to two allegedly false statements. Remanded. View "Abrahamson v. St. Louis County Sch. Dist." on Justia Law

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A home remodeling contractor (Contractor) received a demand for arbitration regarding allegedly defective work it performed on a remodeling project. Contractor's insurer (Insurer) accepted defense of the claim under a reservation of rights. The arbitrator issued an arbitration award in favor of the homeowners. When Insurer refused to pay the award, Contractor paid the homeowners and sued Insurer for indemnification under the policy. The district court granted Contractor's motion for summary judgment, concluding that a vague arbitration award made it impossible to determine whether the insurance policy covered any of the homeonwers' successful claims and was directly attributable to the inaction of the attorney appointed by Insurer to represent Contractor. The court of appeals reversed. The Supreme Court reversed, holding (1) a portion of the homeowners' claim may be covered under the policy; (2) Insurer was not vicariously liable of the absence of an explanation of the arbitration award; and (3) Insurer was directly liable to Contractor for the failure of the attorney to request an explanation of the arbitration award to determine what portion of the award, if any, was for the covered claim. Remanded. View "Remodeling Dimensions, Inc., v. Integrity Mut. Ins. Co." on Justia Law

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Petitioner filed with the Secretary of State's (Secretary) office an affidavit of candidacy as the Republican candidate for Minnesota State Senate, District 61. Petitioner's affidavit did not include a telephone number as required by statute, and therefore, Petitioner's affidavit was rejected. Petitioner subsequently filed a petition with the Supreme Court seeking an order requiring the Secretary to place his name on the 2012 general election ballot as a candidate for state senate. The Supreme Court denied the petition, holding that the Secretary properly rejected Petitioner's affidavit of candidacy because Petitioner failed to comply with the statutory requirements for filing to run for elective office. View "In re Petition of Pfliger" on Justia Law

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Appellant was convicted of first-degree murder while committing a drive-by shooting and drive-by shooting. The Supreme Court affirmed Defendant's conviction. In this case, Defendant appealed the summary denial of his second petition for postconviction relief, which alleged a claim of ineffective assistance of appellate counsel, and his third petition for postconviction relief, which alleged a claim of newly discovered evidence. The Supreme Court (1) affirmed the postconviction court's summary denial of the second postconviction petition because the record conclusively showed appellate counsel was not ineffective; but (2) reversed the court's summary denial of the third postconviction petition and remanded for an evidentiary hearing because the record failed to conclusively show that Appellant was not entitled to relief based on his claim of newly discovered evidence. View "Bobo v. State" on Justia Law

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In June 2012, Petitioner filed an affidavit of candidacy and nominating petition with the Secretary of State's (Secretary) office, seeking to run as an independent candidate for Minnesota state representative. The Secretary rejected Petitioner's nominating petition because it did not bear her residence as required by statute and because Petitioner's statement of political party or political principle exceeded the three-word limit required by statute. Petitioner petitioned the Supreme Court to require the Secretary to list her on the 2012 general election ballot as a candidate for state representative. The Supreme Court denied the petition, holding that the Secretary properly denied Petitioner's nominating petition, as (1) candidates for public office must strictly comply with the statutory requirements for filing for office, and (2) the statement of political party or political principle on the pages of Petitioner's nominating petition exceeded the three-word limit required by statute. View "Anderson v. Ritchie" on Justia Law