Justia Minnesota Supreme Court Opinion Summaries

The State charged Ronald Fleck with second-degree assault after he stabbed his former girlfriend. During the trial, after all the evidence was presented to the jury, the district court submitted two forms of assault to the jurors, (1) assault-fear, prohibiting an act done with the intent to cause fear in another of immediate bodily harm or death, and (2) assault-harm, prohibiting the intentional infliction of bodily harm. The district court instructed the jurors that voluntary intoxication applied to an assault-fear offense but not an assault-harm offense. The jury found Fleck not guilty of second-degree assault-fear but guilty of second-degree assault-harm. The court of appeals reversed, concluding that the district court erred by failing to instruct the jury that voluntary intoxication applied to an assault-harm offense. The Supreme Court reversed the court of appeals' decision and reinstated Fleck's conviction, holding that the district court properly instructed the jury on the applicable law. View "State v. Fleck" on Justia Law

Appellant Herman Tanksley, Jr. was convicted of fourth-degree driving while impaired, which is driving with an alcohol concentration of 0.08 or more. Tanksley appealed, arguing that he was entitled to a Frye-Mack hearing on the reliability of first-void urine testing to resolve his claim that first-void urine testing does not reliably correlate with a driver's blood alcohol concentration. The court of appeals concluded that the district court abused its discretion in denying the Frye-Mack hearing to Tanksley but that the error was harmless. The Supreme Court granted transfer and affirmed the district court, holding that the district court was not required to hold a Frye-Mack hearing based on Tanksley's challenge, as blood alcohol concentration is irrelevant when the State seeks to prove the offense of driving with an alcohol concentration of 0.08 or more solely with evidence of the amount of alcohol in the defendant's urine. View "State v. Tanksley" on Justia Law

Appellant was employed by School District for three school years as the activities director and for one school year as interim middle school principal. Subsequently, School District terminated Appellant's employment. Appellant filed a grievance on the ground that he was a continuing-contract employee and entitled to continuing contract rights under Minn. Stat. 122A.40. School District denied the grievance. The court of appeals affirmed. At issue on appeal was whether Appellant's employment by the school district as an activities director fell within the definition of a "teacher" under section 122A.40, which would determine whether he was entitled to continuing-contract rights under the statute. The Supreme Court affirmed, holding that Appellant was not a professional employee required to hold a license from the state department and therefore was not a "teacher" within the meaning of the continuing-contract statute. View "Emerson v. Indep. Sch. Dist. 199" on Justia Law

Defendant Randolph Johnson was charged with felony domestic assault and misdemeanor fifth-degree assault. As part of a negotiated plea, Defendant pleaded guilty to an amended charge of misdemeanor domestic assault, and the State dismissed the felony charge. The district court ordered that Defendant submit to a DNA sample pursuant to Minn. stat. 609.117, subd. 1(1), which requires a defendant charged with a felony and then convicted of a misdemeanor arising out of the same set of circumstances to submit a DNA sample for the limited purpose of criminal identification, after concluding that the statute was constitutional as applied to Defendant. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in conducting a search of Defendant to collect a biological specimen for criminal identification purposes outweighed Defendants' reduced expectation of privacy following his misdemeanor conviction arising out of the same set of circumstances as his felony charge; (2) consequently, the statute did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Defendant's equal protection claim failed. View "State v. Johnson" on Justia Law

Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute. View "In re M.L.M." on Justia Law

Appellant Darryl Colbert was convicted of premeditated first-degree murder. The Supreme Court affirmed Colbert's conviction on direct appeal. Colbert subsequently filed five petitions for postconviction relief, and the postconviction court denied each petition. In this case, Colbert appealed the postconviction court's denial of his fifth petition for postconviction relief. The Supreme Court affirmed, holding that Colbert's petition was time-barred under Minn. Stat. 590.01, subd. 4, which states that a person seeking relief has two years from the disposition of the person's direct appeal to file a petition for postconviction relief, because it was filed more than two years after it arose. View "Colbert v. State" on Justia Law

Relators, two businesses, sought certiorari review of the Minnesota Tax Court's determination of the fair market value on the 2007, 2008, and 2009 assessment dates for an office building located in Ramsey County. At trial, the tax court heard expert testimony from Relators' appraiser and Ramsey County's appraiser. After trial, the County submitted a post-trial brief that argued for higher property valuations than the market values assigned to the property by either appraiser. The court then adopted, verbatim, the County's proposed market valuations on the three assessment dates. The Supreme Court reversed the tax court's decision, holding that the court's findings and conclusions failed to meet the standard articulated in Eden Prairie Mall, LLC v. County of Hennepin, which states that when the tax court rejects the testimony of both appraisers, the court must give a basis for its calculations and provide an adequate explanation and factual support in the record for its conclusions. View "444 Lafayette, LLC v. County of Ramsey" on Justia Law

Michael Ferguson was convicted of one count of felony drive-by shooting at an occupied building and eight counts of second-degree assault, arising out of an incident in which multiple shots were fired at a duplex occupied by eight people. After Ferguson successfully appealed his original sentence, the district court imposed sentence on the drive-by shooting conviction and all eight assault convictions. On appeal, the court of appeals held that Minn. Stat. 609.035 required the district court to sentence Ferguson only on the drive-by shooting at an occupied building conviction. The Supreme Court reversed the court of appeals and upheld the sentence imposed by the district court, holding that the court of appeals misapplied the rule that a district court may not sentence a defendant to more than one crime for each victim, and that a single sentence for drive-by shooting at an occupied building was not commensurate with Ferguson's culpability for using a dangerous weapon to intentionally cause eight persons to fear immediately bodily harm. View "State v. Ferguson" on Justia Law

Appellant Gary Roby was convicted of aiding and abetting the crimes of first-degree premeditated murder, first-degree murder while committing aggravated robbery, and second-degree intentional murder. The Supreme Court affirmed Roby's conviction on appeal. Roby subsequently filed this, his third petition for postconviction relief, arguing that newly discovered evidence should be considered in the interests of justice. The postconviction court denied Roby's petition without an evidentiary hearing, holding (1) Roby's claims that were based on a 1989 police report and a 2002 letter were time-barred, and (2) Roby's remaining claims failed on the merits. The Supreme Court affirmed, holding (1) all of Roby's claims were time-barred under the postconviction statute, and (2) Roby was not entitled to relief through application of the doctrine of equitable tolling. View "Roby v. State" on Justia Law

The City of Red Wing enacted an ordinance requiring inspections of rental property before landlords could obtain operating licenses and allowing the City to conduct inspections by application for and judicial approval of an administrative warrant in the absence of landlord or tenant consent. Appellants in this case were nine landlords and two tenants who refused to consent to inspections of their properties and successfully challenged three separate applications for administrative warrants. At the same time Appellants opposed the City's application, they filed a separate declaratory judgment action seeking to have the rental inspection ordinance declared unconstitutional. The court of appeals affirmed the district court's dismissal of the declaratory judgment action for lack of standing, concluding that Appellants had not alleged an injury that was actual or imminent. The Supreme Court reversed, concluding that the challenge to the constitutionality of the rental inspection ordinance presented a justiciable controversy. Remanded. View "McCaughtry v. City of Red Wing" on Justia Law