Justia Minnesota Supreme Court Opinion Summaries

Appellant Brent Kuhlmann was convicted after a jury trial of domestic assault and test refusal. On appeal, Appellant argued that the trial court committed reversible error when it accepted a stipulation on elements of the charged offenses without advising him of his right to a jury trial on these elements and securing, either in writing or on the record, his personal waiver of the right to a jury trial on the stipulated elements. The court of appeals affirmed Appellant's convictions. The Supreme Court affirmed, holding (1) the trial court erred in failing to obtain Appellant's personal waiver of the right to a jury trial on the previous-conviction elements of the charged offenses; (2) the trial court's failure to obtain Appellant's personal waiver of his right to a jury trial did not amount to structural error; and (3) under the plain error standard, the error did not affect Appellant's substantial rights or the outcome of the case. View "State v. Kuhlmann" on Justia Law

In 2004, Doctor informed Employer, a medical clinic, that he planned to exercise his rights under Employer's policy that rewarded length of service by giving benefits to physicians who were sixty years old or older and had at least fifteen years of taking night calls. Doctor agreed to postpone exercising his rights under the policy until the next year. In 2005, Employer told Doctor that the policy no longer existed. Doctor later withdrew from taking night call. As a result, Employer reduced Doctor's salary. In 2009, sued Employer for breach of contract and promissory estoppel, claiming Employer breached the policy by refusing to allow him to be exempt from night call without salary reduction. The district court granted Employer's motion to dismiss, holding that the two-year statute of limitations began to run in 2005 when Employer informed Doctor it would not honor its obligations under the policy. The court of appeals reversed, concluding that a new cause of action accrued each time a payment was due but not paid. The Supreme Court reversed, holding that Doctor's cause of action accrued, and the statute of limitations began to run, in 2005, and therefore, Doctor's claim was barred by the statute of limitations. View "Park Nicollet Clinic v. Hamann" on Justia Law

Petitioners, including a state senator, filed a petition for writ of quo warranto challenging the authority of the county district court to authorize expenditures by any executive branch agency in the absence of legislative appropriations, the authority of the attorney general to seek authorization for such expenditures, and the authority of the commissioner of the Minnesota Department of Management and Budget to make payments for executive branch agency expenditures as authorized by the district court. The petition sought an order enjoining Respondents, including the attorney general, governor, commissioner, and chief judge of the district court, from seeking court orders that violated the state legislature's prerogatives to appropriate funds. In the meantime, the legislature passed, and the governor signed, appropriations for each state agency retroactive to the start of the biennium, and there were no further district court proceedings seeking funding. The Supreme Court found that the constitutional questions about the relative powers of the three branches of government were moot and would not arise again unless the legislative and executive branches failed to agree on a budget to fund a future biennium, and therefore, dismissed the petition as moot. View "Limmer v. Swanson" on Justia Law

This case arose out of the 2007 collapse of the Interstate 35W Bridge. Individual plaintiffs commenced lawsuits against two contractors that performed work on the bridge pursuant to contracts entered into with the State. The contractors brought third-party complaints against Jacobs Engineering Group on the basis that Jacobs' predecessor negligently designed the bridge. One contractor also filed a third-party complaint against the State. The State cross-claimed against Jacobs for contribution, indemnity, and statutory reimbursement. Jacobs moved to dismiss the State's cross-claim as time-barred, arguing that the reimbursement provision of the compensation statutes compensating survivor-claimants of the collapse did not retroactively revive causes of action against Jacobs that had been previously extinguished by a prior version of the statute of repose. The district court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the provision retroactively revived the State's action for statutory reimbursement against Jacobs; (2) the provision did not violate Jacob's constitutional right to due process; and (3) revival of the action for statutory reimbursement did not unconstitutionally impair Jacobs' contractual obligations. View "In re Individual 35W Bridge Litig." on Justia Law

This case arose out of the 2007 collapse of the Interstate 35W Bridge. Individual plaintiffs commenced lawsuits against a contractor that performed work on the bridge pursuant to a contract entered into with the State. The contractor brought a third-party complaint against Jacobs Engineering Group for indemnity and contribution on the basis that Jacobs' predecessor negligently designed the bridge. Jacobs moved to dismiss the lawsuits as time-barred and argued that the 2007 amendments to Minn. Stat. 541.051 did not revive actions for contribution or indemnity that had previously been extinguished by a prior version of the statute of repose. The district court denied the motion to dismiss, but the court of appeals reversed. The Supreme Court affirmed the court of appeals, holding that the 2007 amendments to section 541.051 did not retroactively revive the contractor's action for contribution against Jacobs. View "In re Individual 35W Bridge Litig." on Justia Law

At issue in this case was the interpretation of approximately sixty collective bargaining agreements (CBAs) between the City of Duluth and its employees. Subject to certain conditions and exceptions, the CBAs guaranteed retired City employees health insurance benefits "to the same extent as active employees." The dispute in this case centered on the meaning of that phrase, specifically, whether the phrase guaranteed health insurance benefits to retirees to the same extent as employees who were active at the time of a retiree's departure, or to the same extent as current City employees. Several retired City employees filed a lawsuit, alleging that the City had wrongfully changed or threatened to change their health insurance benefits and claiming that CBAs guaranteed that health insurance benefits for retirees would be frozen as of the time of retirement. The district court held for the City. The court of appeals affirmed the district court's interpretation of the active-employees clause. The Supreme Court affirmed, holding that the CBAs unambiguously guaranteed health insurance benefits to retirees to the same extent as current City employees. View "Savela v. City of Duluth" on Justia Law

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed a police officer to testify in the State's case in chief that Borg did not respond to a mailed request for an interview by the officer. At issue on appeal was whether the Fifth Amendment prohibits the State from eliciting testimony during its case in chief regarding a criminal defendant's lack of response to a letter mailed to him by the police when the defendant was not under arrest or in custody and had not been informed of his Miranda rights. The Supreme Court reversed, holding that the district court did not err when it allowed the testimony because the Fifth Amendment does not prohibit the State from introducing evidence regarding a defendant's silence unless the government compelled the defendant to speak or to remain silent. View "State v. Borg" on Justia Law

At issue in this appeal was how sealed absentee ballots that were rejected and never counted during the 2008 general election were classified under the Minnesota Government Data Practices Act (MGDPA). Several television stations brought an action under the MGDPA seeking access to the ballots, alleging that they were public government data under the MGDPA. The district court granted summary judgment to the stations. The court of appeals reversed, concluding that Minn. Stat. 13.37(2) unambiguously provided that sealed absentee ballots were nonpublic or private data under the MGDPA. The Supreme Court affirmed, holding (1) the plain language of section 13.37(2), when read in conformity when the MGDPA and statutes governing absentee voting, unambiguously classified unopened absentee ballots not counted in the 2008 general election as not public government data; and (2) because the absentee ballots were not public data, the stations were not entitled under the MGDPA to inspect and copy the disputed ballots. View "KSTP-TV v. Ramsey County" on Justia Law

The Minnesota Board on Judicial Standards filed a formal complaint against Judge Patricia Karasov, judge of a district court, alleging violations of the Rules of the Code of Judicial Conduct and the Minnesota Constitution. A three-member panel appointed by the Supreme Court (1) found that Judge Karasov failed to reside within her judicial district during her continuance in office and failed to cooperate and be candid and honest with respect to the Board's investigation of her residency status, and (2) recommended that Judge Karasov be censured and suspended from judicial office for ninety days without pay. Both Judge Karasov and the Board appealed. The Supreme Court concluded (1) the Board proved by clear and convincing evidence that Judge Karasov committed judicial misconduct by clear and convincing evidence; (2) Judge Karasov's claim that she was denied due process of law by irregularities in the proceedings lacked merit; and (3) the appropriate judicial discipline was censure and suspension from judicial duties for six months without pay. View "In re Conduct of Judge Karasov" on Justia Law

The Minnesota Department of Health, as part of its newborn screening program, collected blood samples of newborn children to test for various disorders. The Department retained the excess blood samples for other uses and allowed outside research organizations to use them to conduct health studies. Nine families (Appellants) sued the State and the Department (Appellees), arguing that the Department violated the Genetic Privacy Act by collecting, using, storing, and disseminating the children's blood samples and test results without obtaining written informed consent. The district court granted summary judgment in favor of Appellees, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the blood samples collected and stored by the Department were genetic information subject to the restrictions of the Genetic Privacy Act; and (2) the newborn screening statutes provided an express exception to the Genetic Privacy Act only to the extent that the Department was authorized to administer newborn screening by testing the samples for disorders and to store the test results, and the newborn screening statutes did not expressly authorize the Department to collect, use, store, or disseminate the blood samples for any other use without written consent. View "Bearder v. State" on Justia Law