Justia Minnesota Supreme Court Opinion Summaries

Plaintiff Alice Ann Staab brought suit against Defendant Diocese of St. Cloud for injuries she sustained on premises Defendant owned and operated. A special jury verdict attributed fifty percent of the negligence to the sole defendant and fifty percent of the negligence to a nonparty to the lawsuit. The district court ruled that Minn. Stat. 604.02, subd. 1 does not apply in an action against only one defendant and ordered Defendant to pay the entire damages award. The court of appeals reversed, holding that under the plain language of section 604.02, subdivision 1, Defendant must pay only in proportion to the percentage of fault attributed to Defendant by the jury. The Supreme Court affirmed but under a different analysis, holding (1) section 604.02, subdivision 1, applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor and limits the amount collectible from the defendant to its percentage share of the fault assigned to it by the jury; and (2) consequently, Defendant must pay Plaintiff fifty percent of the jury award, Defendant's share of the fault as determined by the jury. View "Staab v. Diocese of St. Cloud" on Justia Law

Employee was injured in a work-related accident in Minnesota and then moved to Wyoming where she received medical treatment. The Wyoming medical providers submitted their charges to Employer's workers' compensation insurer. Relying on Minn. Stat. 176.136, subd. 1b(d), the insurer made payments in the amount provided under the workers' compensation benefit structure in Wyoming. Employee filed a workers' compensation medical request for the unpaid balance, arguing that Minn. Stat. 176.135, subd. 1 was controlling. The workers' compensation judge agreed and found for Employee. The workers' compensation court of appeals reversed. The Supreme Court affirmed, holding (1) Minn. Stat. 176.136, subd. 1b(d) limits a Minnesota employer's workers' compensation liability to an out-of-state medical provider to the amounts provided in the workers' compensation schedule of benefits in the state where the provider is located; and (2) section 16.136, subd. 1b(d) was not unconstitutional as applied. View "Schatz v. Interfaith Care Ctr." on Justia Law

Peter Lonergan and Robert Kunshier were both indeterminately civilly committed to the Minnesota sex offender program. Lonergan and Kunshier each sought relief from his commitment by filing a pro se motion under Minn. R. Civ. P. 60.02. After the district court denied the motions, both Lonergan and Kunshier appealed. The court of appeals affirmed the denial of Lonergan's motion, holding that as a sexually dangerous person, Lonergan could not use Rule 60.02 to seek a discharge from his indeterminate commitment or to make a constitutional challenge to the adequacy of his treatment at the sex offender program. The court also affirmed the denial of Kunshier's motion, concluding that Rule 60.02 may not be used to seek any relief from an indeterminate civil commitment order. The Supreme Court reversed in part, holding (1) the court of appeals erred in Kunshier's case when it articulated a blanket prohibition on use of Rule 60.02 motions by patients indeterminately committed as sexually dangerous persons or sexual psychopathic personalities; and (2) Lonergan's claims warranted reconsideration in light of this decision. Remanded. View "In re Lonergan" on Justia Law

The Rochester International Joint Zoning Board enacted a zoning ordinance that increased the size of a runway safety zone and changed the restrictions within the safety zone to allow fewer types of uses of land within the zone. The safety zone extended over property owned by Leon and Judith DeCook. The DeCooks brought an inverse condemnation action, alleging that the Board's decision constituted a taking for which the DeCooks were entitled to compensation. The district court first concluded there was no taking, and upon remand, again concluded that the Board's actions did not constitute a taking. The DeCooks appealed another time, and the Supreme Court ultimately held the ordinance constituted a taking of the DeCooks' property. The DeCooks subsequently moved for an award of attorney fees incurred during the appeals. The Supreme Court granted the motion, as the Cooks prevailed and were entitled under Minn. Stat. 117.045 to an award of reasonable costs and expenses, including attorney fees, incurred on appeal. View "DeCook v. Rochester Int'l Airport Joint Zoning Bd." on Justia Law

A collision between an automobile and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. Plaintiffs, the representatives of the decedents' estates, brought wrongful death claims against BNSF, alleging negligence in the maintenance of warning signals and failure to comply with several state and federal regulations. 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 Plaintiffs' favor. A divided court of appeals reversed and remanded the matter for a new trial, concluding that the district court's 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. The Supreme Court (1) reversed the court of appeals' grant of a new trial on the ground of error in the instructions and verdict form, holding that any error did not affect the fairness and integrity of the proceedings; and (2) affirmed the district court's denial of BNSF's motion for a new trial. View "Frazier v. Burlington N. Santa Fe Corp." on Justia Law

After a jury trial, Appellant Daniel Anderson was convicted of first-degree murder for the death of his girlfriend's nineteen-month-old son. Anderson filed a petition for postconviction relief, arguing that it was error for the State to indict him under the domestic abuse murder statute and that he should have been indicted under what he claimed to be the more specific child abuse murder statute. The postconviction court denied relief without a hearing, reasoning that the claim was Knaffla-barred and that no exception to Knaffla applied. Under State v. Knaffla, a postconviction relief petition raising claims that were raised on direct appeal or that were known or should have been known but were not raised by the petition at the time of direct appeal is procedurally barred. The Supreme Court affirmed, holding that the postconviction court properly concluded that Anderson's claim was Knaffla-barred and that Anderson's petition was not saved by either exception to the Knaffla bar, as his claim was not novel and the interests of fairness and justice did not warrant consideration of his claim. View "Anderson v. State" on Justia Law

The property at issue in this case was the interest of Respondent, the judgment debtor, in a spendthrift trust. The district court issued a temporary injunction prohibiting Respondent from disposing of any money or property he had received, was due to receive, or will receive from the trust. The court of appeals reversed. The Supreme Court affirmed, holding (1) based on its plain language, Minn. Stat. 575.05 authorizes a district court to enjoin the deposition of a judgment debtor's property only if that property is in the hands of the judgment debtor or a third party or is due to the judgment debtor at the time the district court issues its order; and (2) because the judgment creditor, Appellant Fannie Mae, did not argue that Respondent's interest in the trust was Grossman's property that was currently in the hands of Grossman or a third party or currently due to Grossman, the requirements of section 575.05 were not met. View "Fannie Mae v. Heather Apartments Ltd. P'ship" on Justia Law

Appellants, Leland and Ilene Haugen and Haugen Nutrition and Equipment, defaulted on promissory notes held by respondent United Prairie Bank-Mountain Lake (UPB). The various loan agreements between the parties contained provisions in which Appellants agreed to pay UPB's reasonable costs and attorney fees associated with the protection of UPB's security interests and the enforcement of Appellants' obligation to repay the loans. The district court denied Appellants' motion to submit the question of reasonable attorney fees to the jury and subsequently awarded UPB over $400,000 in attorney fees. The court of appeals affirmed, holding that UPB's claim for the recovery of attorney fees was equitable in nature and thus did not give rise to a jury trial right under the Minnesota Constitution. The Supreme Court reversed in part, holding that Appellants were constitutionally entitled to a jury determination on UPB's claim for attorney fees because the nature of the claim was contractual and the remedy sought was legal. View "United Prairie Bank-Mountain Lake v. Haugen Nutrition & Equip., LLC" on Justia Law

Kelli Rohmiller was the sister of the mother of B.H. After B.H.'s mother died, B.H.'s father, Andrew Hart, was awarded custody of B.H. Rohmiller and her father, Clayton Rohmiller, subsequently petitioned the district court for visitation with B.H. The court jointly granted Rohmiller and Clayton unsupervised visitation with B.H. and provided that Rohmiller could exercise visitation without the presence of Clayton. Hart objected to Rohmiller's independent visitation with B.H. The court of appeals affirmed the district court's grant of visitation to Clayton but reversed the award of visitation to Rohmiller, holding that Minn. Stat. Ann. 257C.08 does not extend visitation rights to aunts generally and that she had no right to visitation under Minnesota law apart from the statute. The Supreme Court affirmed, holding (1) an aunt who does not stand in loco parentis with a child has not right under Minn. Stat. Ann. 257C.08 to visitation with the child over the objection's of the child's fit parent; and (2) an award of visitation outside of section 257C.08 and the common law and over the objections of a child's fit parent cannot be based solely on what is in the best interests of the child. View "Rohmiller v. Hart" on Justia Law

Appellant was convicted on six controlled substance crimes. The court of appeals affirmed Brist's convictions but remanded for the district court to modify Brist's sentence. On appeal, Brist argued that the admission of an audio recording of a statement made by her nontestifying coconspirator to a confidential government informant during a drug transaction violated her rights under the Confrontation Clause. The Supreme Court affirmed Brist's convictions, concluding that it was bound by Bourjaily v. U.S., which held that recorded statements of a nontestifying coconspirator, otherwise admissible as nonhearsay under materially identical evidentiary rules, are admissible at trial against another coconspirator without violating the Confrontation Clause. Therefore, the district court's admission into evidence of the coconspirator's statements in this case did not violate Brist's rights under the Confrontation Clause. View "State v. Brist" on Justia Law