Justia Minnesota Supreme Court Opinion Summaries

Respondent Robert Half International (RHI) terminated Appellant Kim Hansen's employment shortly after she returned from maternity leave and failed to reinstate her to the same or similar position. Hansen filed an action against RHI, alleging that it violated the Minnesota Parenting Leave Act (MPLA) and the Minnesota Human Rights Act (MHRA) by failing to reinstate her to her position or a comparable position after maternity leave, for retaliating against her for taking maternity leave, and for terminating her because of her sex. The district court granted summary judgment in favor of RHI. The court of appeals affirmed. The Supreme Court affirmed, holding that there were no genuine issues of material fact and that judgment was appropriate as a matter of law. View "Hansen v. Robert Half Int'l, Inc." on Justia Law

Respondents brought this action on behalf of themselves and others similarly situated against Philip Morris, alleging that Philip Morris's marketing of its cigarettes violated Minnesota's consumer protection statutes. Respondents asserted claims under Minn. Stat. 8.31(3a) and for common law fraud and unjust enrichment. The district court granted Respondents' motion to certify the class. Subsequently, the court granted summary judgment to Philip Morris on the consumer protection claims asserted under section 8.31(3a) and then dismissed the case. The court of appeals affirmed the class certification but reversed the grant of summary judgment and reinstated Respondents' section 8.31(3a) consumer protection claims. The Supreme Court reversed, holding (1) Respondents' consumer protection claims asserted under section 8.31(3a) were previously released; and (2) because all of Respondents' claims had been dismissed, the issue of whether the plaintiff class was properly certified was moot. View "Curtis v. Altria Group, Inc." on Justia Law

Appellant Denon Rhoads was initially charged with a single count of second-degree burglary. At a pretrial hearing, Rhoads asserted his right to self-representation and signed a written waiver of counsel. The State later amended the complaint to include a count of first-degree burglary that roughly doubled the maximum possible punishment. On the day of trial, Rhoads renewed his waiver-of-counsel. The district court, however, did not conduct an on-the-record inquiry of Rhoads's understanding of the maximum punishment that might be imposed if he were convicted of first-degree burglary. Rhoads was later convicted of first- and second-degree burglary. The Supreme Court reversed Rhoads's first-degree burglary conviction and remanded, holding that because the record did not support an inference that when Rhoads renewed his waiver-of-counsel he understood the maximum possible punishment he faced had doubled, the renewed waiver-of-counsel was not knowing and intelligent. Remanded. View "State v. Rhoads" on Justia Law

Following a jury trial, Appellant Marlon Pratt was convicted of seventeen counts of theft by swindle and two counts of racketeering. On appeal, the court of appeals affirmed in part, reversed in part, and remanded for resentencing. This appeal followed. The Supreme Court reversed, holding (1) there was sufficient evidence to support Pratt's theft-by-swindle convictions; but (2) the judge who presided over Pratt's trial was disqualified from doing so under the Code of Judicial Conduct because the judge was retained by the county attorney's office to be an expert witness in an unrelated case, while at the same time presiding over Pratt's trial, which would cause a reasonable examiner to question the judge's impartiality. Remanded for a new trial. View "State v. Pratt" on Justia Law

Nicole Beecroft was found guilty of first-degree premeditated murder for the stabbing death of her newborn baby. The key factual issue at trial was whether Beecroft's baby was alive or dead when stabbed by Beecroft. Each party presented testimony on this issue from medical examiners and other forensic pathologists, but certain state officials interfered with Beecroft's forensic experts. Beecroft subsequently filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court reversed Beecroft's conviction, holding (1) the interference by the state officials undermined the integrity of the judicial system in this case; (2) the trial errors alleged by Beecroft did not in and of themselves warrant a reversal and the grant of a new trial; but (3) when the existence of alleged errors is combined with the improper conduct of state officials, a reversal is warranted in the interests of justice. Remanded for a new trial. View "State v. Beecroft" on Justia Law

At issue in this appeal was how to calculate an offender's criminal history score when the court permissively imposes a felony sentence consecutive to a gross misdemeanor sentence. Respondent Tito Campbell was convicted of six offenses, including gross misdemeanor criminal vehicular operation resulting in bodily harm and felony fleeing a police officer resulting in death. The district court imposed a twelve-month sentence for the gross misdemeanor and a consecutive 234-month sentence for the felony fleeing offense, using a criminal history score of three. The court of appeals reversed Campbell's sentence, concluding that zero criminal history points should have been used to calculate the duration of the felony sentence. The Supreme Court reversed the court of appeals and reinstated the district court's sentence, holding that the district court's calculation of Campbell's sentence was correct. View "State v. Campbell" on Justia Law

Appellant Carol LaMont filed suit against her employer, a school district, for violations of the Minnesota Human Rights Act (MHRA). Appellant claimed that she had been subjected to a hostile work environment based on her sex and that she had suffered sexual harassment. The district court granted summary judgment to the school district on both claims, concluding that a hostile work environment based on sex was not actionable, and even if it were, Appellant had not established that the conduct of the school district's employees was sufficiently severe or pervasive. The court of appeals affirmed. The Supreme Court affirmed but under different grounds, holding (1) a cause of action for a hostile work environment based on sex is actionable under the MHRA; but (2) Appellant's allegations were insufficient to state a claim of hostile work environment. View "LaMont v. Independent School District #728" on Justia Law

Relator 78th Street OwnerCo, LLC, the owner and landlord of a hotel, filed petitions contesting Hennepin County's assessments of its property for property taxes payable in 2008 and 2009, along with the taxes due in 2008 and 2009. The tax court dismissed both petitions for failure to comply with the statutory sixty-day rule, which states that failure to submit required documentation within sixty days results in automatic dismissal of the petition, because each petition did not include a copy of 78th Street's lease and a calculation of percentage rent paid, and the 2008 petition did not include a rent roll/tenant list. The Supreme Court affirmed, holding (1) 78th Street's argument that the information it did not submit was not relevant to the calculation of property tax for its hotel property was unavailing because a taxpayer is not permitted to evaluate relevancy under the sixty-day rule, and neither the relevancy standard nor the unavailability exception excuses a taxpayer from providing required information that is available to the taxpayer; and (2) neither version of the sixty-day rule was unconstitutionally vague as applied to 78th Street. View "78th St. OwnerCo, LLC v. County of Hennepin" on Justia Law

After a jury trial, Chaun Carridine was convicted of first-degree premeditated murder and sentenced to life in prison. The Supreme Court affirmed, holding (1) the district court did not err by rejecting Carridine's challenges to the State's exercise of two peremptory strikes; (2) any error by the district court in allowing the State to impeach Carridine through his prior statement did not substantially influence the jury's verdict, and therefore, the error, if any, was not prejudicial; (3) the district court did abuse its discretion in instructing the jury; (4) in the instances where there was or may have been prosecutorial misconduct, the misconduct was either harmless or did not affect Carridine's substantial rights, and therefore, the objected-to prosecutorial misconduct was harmless. View "State v. Carridine" on Justia Law

At issue in this case was how to calculate an offender's criminal history score when the court permissively imposes a felony sentence consecutive to a gross misdemeanor sentence. Respondent Tito Campbell was convicted of six offenses, including gross misdemeanor criminal vehicular operation resulting in bodily harm and felony fleeing a police officer resulting in death. The district court imposed a twelve-month sentence for the gross misdemeanor and a consecutive 234-month sentence for the felony fleeing offense, using a criminal history score of three. The court of appeals reversed Campbell's sentence, concluding that zero criminal history points should have been used to calculate the duration of the felony sentence. The Supreme Court reversed and reinstated the district court's sentence, holding that the district court did not err in assigning its criminal history points to Campbell during sentencing. View "State v. Campbell" on Justia Law