Justia Minnesota Supreme Court Opinion Summaries

Relator Minh Nguyen was injured after falling from a ladder while employed by Audio Communications. Nguyen filed an amended petition to seek benefits for permanent total disability, but his petition did not seek to establish the date of onset of permanent disability. After a compensation judge awarded Nguyen benefits from March 4, 2008, for permanent total disability, Audio Communications petitioned the compensation judge for determination of the date of onset. The judge found that Nguyen became permanently and totally disabled as of March 1, 2007. Nguyen then petitioned to require Audio Communications to pay the attorney fees he incurred in partially succeeding in opposing Audio Communications' petition for determination of the date of onset of permanent total disability. The compensation judge denied the claim for attorney fees, and the WCCA affirmed. The Supreme Court affirmed, holding that an employer is not liable for the attorney fees incurred by an injured employee in successfully defending against the employer's petition to offset social security disability benefits paid to the employee against benefits paid by the employer for permanent total disability, where the employee's attorney fees can be paid from ongoing workers' compensation benefits paid to the employee. View "Nguyen v. Audio Commc'ns" on Justia Law

This case arose out of dispute between two counties over which county was the "county of financial responsibility" for the out-of-home placement costs incurred after October 1, 2008, for a minor child named S.M. The Minnesota Department of Human Services (MDHS) held that Nobles County was responsible for S.M.'s costs. The district court reversed, concluding that the legislative history of Minn. Stat. 256G.10 indicated the legislature intended the county of financial responsibility to be the county where the child last resided with a parent, and therefore, Brown County was the county of financial responsibility. The court of appeals affirmed. The Supreme Court reversed, holding (1) the language of section 256G.10 was unambiguous and, by its plain language, the county of financial responsibility was the county of the residence of the parent with whom the child last lived, determined at the time the child entered excluded time status; (2) the county of financial responsibility in this case was the county in which S.M.'s mother resided on May 16, 2008, the date S.M. entered excluded time status; and (3) therefore, Nobles County was the county of financial responsibility for S.M.'s out-of-home placement costs for services provided on and after October 1, 2008. View "In re S.M." on Justia Law

This case involved two mechanic's liens foreclosed against a hotel property. An agent of the lien claimants personally served mechanic's liens statements on the property owner. Appellant, a community bank, challenged the validity of this service. Appellant argued that a lien claimant may not personally serve a mechanic's lien statement, and therefore, service was improper. As a result, Appellant contended that the mechanic's liens were invalid and could not be foreclosed. The district court determined that service was proper and entered judgment in favor of the lien claimants. The court of appeals affirmed. The Supreme Court affirmed, holding that a lien claimant may personally serve a mechanic's lien statement, and therefore, service of the mechanic's lien statements in this case was proper. View "Eclipse Architectural Group, Inc. v. Lam" on Justia Law

A collision at a railroad crossing between a vehicle and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. The representatives of the decedents' estates brought separate wrongful death claims against BNSF. During trial, the district court instructed the jury, without objection from BNSF, to apply a common-law or "reasonable person" standard of care. The jury returned a verdict in appellants' favor. BNSF moved for a new trial, contending that the trial court erred by not applying the standard of care established by applicable federal regulations. The court of appeals concluded that the jury instruction and special verdict form using a common-law duty of care constituted plain error that substantially affected BNSF's rights and the fairness and integrity of the proceedings and remanded the matter. The Supreme Court reversed, holding that any error in the instructions and verdict form did not affect the fairness and integrity of the proceedings. View "Frazier v. Burlington N. Santa Fe Corp." on Justia Law

The State charged Michael Sahr with first-degree criminal sexual contact. Defense counsel moved to dismiss the complaint, arguing that the facts, as alleged in the complaint, were insufficient to support the charged offense. The trial court dismissed the complaint. The State subsequently moved to file a new complaint charging Sahr with second-degree criminal conduct. The trial court denied the State's motion on the basis that filing a new complaint charging second-degree criminal sexual conduct would violate double jeopardy. The court of appeals remanded to the trial court for further proceedings. On remand, the trial court concluded (1) the offense set out in the proposed amended complaint was the "same offense" the court had dismissed in the original complaint and that jeopardy had attached before the complaint was dismissed; and (2) therefore, the signing of the proposed amended complaint would violate double jeopardy. The court of appeals reversed. The Supreme Court reversed the court of appeals, holding (1) the trial court's dismissal of the original complaint constituted an acquittal on the merits; and (2) Sahr's double jeopardy protections precluded the State from filing a new complaint charging Sahr with second-degree criminal sexual conduct and trying him on that offense. View "State v. Sahr" on Justia Law

Appellant Adrian Patterson and his codefendant Leroy Paul were indicted for first-degree murder and attempted first-degree murder. Patterson was scheduled to be tried in a joint trial with Paul. For his defense, Patterson retained Eric Newmark as his counsel of choice. The State moved to disqualify Newmark as Patterson's counsel based on alleged actual and potential conflicts of interest arising out of Newmark's past representation of Paul and three of the State's prospective witnesses. Even though Patterson waived his right to conflict-free counsel with respect to Newmark, the trial court granted the motion on the basis of potential conflicts with two of the State's prospective witnesses. After retaining another attorney and, following a jury trial, Patterson was found guilty and convicted of second-degree murder while committing a drive-by shooting and drive-by shooting. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in disqualifying Newmark as Patterson's counsel. View "State v. Patterson" on Justia Law

Appellant Robert Hughes was convicted of first-degree premeditated murder for the shooting death of his wife. The trial court sentenced Hughes to life imprisonment and ordered him to pay restitution to the Crime Victims Reparations board. The Supreme Court affirmed. Hughes subsequently filed a petition for postconviction relief raising eighteen claims. The two most significant claims were (1) the restitution order was improper, and (2) the Confrontation Clause was violated by the introduction at trial of statements made by Hughes's wife. The postconviction court denied Hughes's petition without a hearing. The Supreme Court affirmed, holding (1) because Hughes's wife's statements to her divorce attorney and police were nontestimonial, the trial court did not violate Hughes's Confrontation Clause rights when it admitted the statements at trial; and (2) all of Hughes's other claims were procedurally barred because they were or could have been raised on direct appeal. View "Hughes v. State" on Justia Law

Christopher Daly sued Zachary McFarland for injuries sustained from an accident. The jury returned a special verdict form finding that both Daly and McFarland were negligent, but that Daly's negligence was not a direct cause of the accident. The jury then allocated thirty percent of the fault for the accident to Daly. The district court entered judgment for Daly in the amount of $442,633, the full amount of damages that the jury found Daly to have suffered. McFarland moved for judgment as a matter of law, arguing that the court improperly reconciled the jury's special verdict form answers, and that McFarland was not negligent as a matter of law. In the alternative, McFarland moved for a new trial. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court abused its discretion in reconciling the special verdict form; and (2) because the jury found McFarland to be at least seventy percent causally negligent for the accident, the case was remanded with directions to enter a remittitur awarding Daly $309,843, and if Daly rejected the remittitur, to grant a new trial on liability issues. View "Daly v. McFarland" on Justia Law

Following a jury trial, Appellant Danny Ortega was convicted of aiding and abetting first-degree premeditated murder. The Supreme Court affirmed Ortega's conviction, holding (1) the district court did not err in denying Ortega's motion to suppress his statements to investigators because, after requesting counsel, Ortega reinitiated the discussion with investigators and then validly waived his right to counsel; (2) the district court did not abuse its discretion when it allowed the prosecutor to ask prospective jurors whether they believed there was anything more valuable than human life, as any error in the prosecutor's questioning of jurors during voir dire was harmless; and (3) the evidence was sufficient to convict Ortega of premeditated murder. View "State v. Ortega" on Justia Law

Appellant Jabaris Curt Boldman was found guilty by a jury of first-degree felony murder and second-degree intentional murder. The district court entered judgment of conviction for first-degree felony murder and imposed a life sentence. The Supreme Court vacated Appellant's conviction for first-degree felony murder, holding (1) the evidence was not sufficient to support the first-degree felony murder conviction but was sufficient to support a second-degree murder conviction; and (2) any alleged discovery violation on the part of the State was harmless. Remanded to the district court to enter a judgment of conviction and impose sentence on the second-degree murder charge. View "State v. Boldman" on Justia Law