Justia Minnesota Supreme Court Opinion Summaries

Respondent Jill Engquist, as parent and natural guardian of minor Amber Engquist, sued Appellants, Steven and Christina Loyas, for injuries Amber sustained as a result of a dog bite that occurred at Appellants' residence. The district court entered judgment in favor of Appellants after finding that Amber provoked the dog to bite her. The court of appeals reversed on the ground that the jury instruction given by the district court misstated the meaning of provocation under Minn. Stat. 347.22. The Supreme Court affirmed, holding that because the jury could have found provocation without any consideration of the victim's knowledge of the danger, the jury instructions materially misstated the law and prejudiced Respondent. Remanded for a new trial. View "Engquist v. Loyas" on Justia Law

William Jacobs was charged with two counts of criminal sexual conduct. Jacobs moved to remove the judge assigned to his case for cause, basing his motion on the fact that the judge had not disclosed that his spouse was, at the time, an attorney with the county attorney's office that was prosecuting the case. Jacobs' motion was denied. The court of appeals denied Jacobs' writ of prohibition, holding that a spouse's position as an assistant county attorney in the public office that is prosecuting the case does not by itself create an appearance of partiality. The Supreme Court affirmed, holding that the judge was not required to disqualify himself from the case because a reasonable examiner, with full knowledge of the facts and circumstances in this case, would not question the judge's impartiality. View "State v. Jacobs" on Justia Law

Appellant Elaine Wesely filed a dental malpractice action, alleging that she received negligent care from dentist A. David Flor. To satisfy the statutory requirement of expert disclosure, Wesely submitted an affidavit disclosing the opinions of a doctor of internal medicine, not a dentist. After Flor moved to dismiss the claim, asserting the affidavit was deficient because the internist was not qualified to be an expert in the action, Wesely's counsel submitted a second affidavit identifying a dentist-expert and disclosing his opinions. The district court granted Flor's motion to dismiss, concluding that the second affidavit did not amend the original affidavit. The court of appeals affirmed. The Supreme Court reversed, holding that the second affidavit was an amended affidavit that was capable of correcting the alleged deficiencies of the first affidavit. Remanded. View "Wesely v. Flor" on Justia Law

Appellants were trustees of eight family trusts. After stock of closely-held corporation belonging to the trusts was fractionalized in a reverse stock split and Appellants were forced to accept cash in exchange for their shares, Appellants brought suit against the corporation. The district court dismissed all of Appellants' claims. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the valuation of the stock was not the product of common law fraud; (2) Minn. Stat. 302A.471 does not provide for dissenters' rights in the event of a reverse stock split; (3) Appellants were not entitled to equitable relief under Minn. Stat. 302A.751 because the corporation did not frustrate Appellants' reasonable expectations as shareholders; (4) merely conducting an involuntary redemption of Appellants' stock at a fair price, without more, did not constitute a breach of fiduciary duty; and (5) the district court did not err in determining the fair value of Appellants' stock when it adopted a valuation that relied in part on asset value. View "U. S. Bank N. A. v. Cold Spring Granite Co." on Justia Law

Following a jury trial, Lawrence Montanaro was convicted of first-degree murder of a police officer. After the statute of limitations for filing a postconviction petition expired, Montanaro filed a petition for postconviction relief. The postconviction court denied the petition without deciding whether Montanaro established an exception to the statute of limitations. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Montanaro's request for a new trial based on the court's conclusion that alleged errors in the jury instructions and the prosecutor's alleged misconduct during his closing argument did not satisfy the third prong of the plain error test because the errors did not affect Montanaro's substantial rights. View "Montanaro v. State" on Justia Law

Appellant Victor Martinez-Mendoza was charged by complaint with one count of first-degree criminal sexual conduct and one count of second-degree criminal sexual conduct. The State and Appellant reached a plea agreement in which Appellant would plead guilty to count two of the complaint and count one would be dismissed. Appellant subsequently pleaded guilty to count two, and the district court adjudged Appellant guilty of count two. Before the sentencing hearing, the State learned that the actual presumptive guidelines sentence for the count two offense involved a much shorter incarceration time than the parties had originally thought. The State moved to vacate the plea or, in the alternative, reinstate count one of the complaint. The district court denied the motion, citing double jeopardy concerns. The court of appeals reversed based on the parties' mutual mistake. The Supreme Court reversed, holding that jeopardy attached when the trial court accepted and recorded Appellant's guilty plea, and thus, any appeal by the State was barred as moot as a matter of law. View "State v. Martinez-Mendoza" on Justia Law

Lincoln Caldwell was convicted in district court of aiding and abetting first-degree premeditated murder for the benefit of a gang. Caldwell appealed his conviction and the denial of two postconviction petitions. The Supreme Court affirmed, holding that (1) Minn. Stat. 609.05 permits the conviction of a defendant for aiding and abetting first-degree murder notwithstanding the fact that the party who fired the shots that killed the victim was acquitted of first-degree murder and convicted of second-degree murder; (2) there was sufficient evidence for the jury to conclude that the party who fired the shots that killed the victim had the necessary intent and premeditation to sustain Caldwell's conviction; and (3) there was sufficient evidence that a group of persons with whom Caldwell associated, and for whose benefit he committed the crime of first-degree murder, was a statutorily-defined gang. View "State v. Caldwell" on Justia Law

Gregory Latterell, on behalf of his stepson Jared Boom's estate, sued Progressive Northern Insurance and AIG Insurance to recover underinsured motorist (UIM) benefits following Boom's death from a motor vehicle accident. Progressive, the insurer of Boom's vehicle, denied Latterell's claim for UIM benefits because of a business-use exclusion in Boom's insurance policy. AIG, Lattrell's insurer, also denied Latterell's claim. Latterell sued, and the district court granted summary judgment to Progressive and AIG. The court of appeals affirmed, holding (1) the business-use exclusion in the Progressive policy was enforceable under the Minnesota No-Fault Automobile Insurance Act and unambiguously excluded UIM coverage under the specific circumstances of this case, and (2) Latterell could not recover UIM benefits under the AIG policy. The Supreme Court reversed the denial of Latterell's summary judgment as to Progressive, holding that Progressive's business-use exclusion was unenforceable under the No-Fault Act. Remanded with instructions to enter judgment in favor of Latterell against Progressive. View "Latterell v. Progressive N. Ins. Co." on Justia Law

After a jury trial, the district court convicted Ronald Hill of first-degree premeditated murder. The Supreme Court affirmed Hill's conviction, holding (1) because the district court properly and carefully balanced the potential probative value and prejudicial effects of the proffered impeachment evidence, the court did not abuse its discretion when it admitted evidence of Hill's prior, unspecified felony conviction for impeachment purposes; (2) Hill was not entitled to a new trial because allegedly improper testimony that the State obtained Hill's DNA sample through a search warrant was harmless because it did not affect Hill's substantial rights; (3) any alleged error in admitting evidence that Hill shot the victim with a gun stolen during a home invasion was harmless because there was not a reasonable possibility that the alleged error significantly affected the verdict; and (4) the cumulative effect of any errors resulting from the admission of disputed testimony did not affect Hill's substantial rights, and therefore, Hill was not deprived of his constitutional right to a fair trial. View "State v. Hill" on Justia Law

Elizabeth Hawes was convicted of aiding and abetting her brother, Andrew Hawes, in the first-degree murder of their brother, Edwin Hawes. The district court sentenced Hawes to life imprisonment. The Supreme Court affirmed Hawes' conviction, holding (1) the circumstantial evidence was legally sufficient to support Hawes' conviction of aiding and abetting first-degree premeditated murder; (2) any error the the district court made when it ruled that out-of-court statements made by Andrew were not admissible as declarations against penal interest was harmless beyond a reasonable doubt; and (3) the district court did not abuse its discretion when it denied Hawes' motion for a new trial on the grounds of newly available evidence. View "State v. Hawes" on Justia Law