Justia Minnesota Supreme Court Opinion Summaries

John Miles was convicted of first-degree murder. Miles filed a petition for postconviction relief, alleging that he was entitled to a new trial on the basis of newly discovered evidence, specifically, the information in an interview between Miles's counsel and a witness of the homicide, who stated that Miles was not responsible for the shooting of the victim. The postconviction court denied the petition, concluding that it was time-barred under Minn. Stat. 590.01. On review, the Supreme Court affirmed without prejudice, holding (1) the postconviction court erred when it determined that the witness's statement could have been discovered by the exercise of due diligence prior to trial, (2) the postconviction court applied the wrong legal test when it concluded that the witness's statement did not establish by a clear and convincing standard that Miles was innocent, but (3) the court did not err when it denied Miles's petition without a hearing because Miles failed to offer newly discovered evidence with sufficient indicia of reliability to warrant relief under the statute. The Court concluded if Miles could base a new petition on a more satisfactory showing of a genuine statement from the witness, he was entitled to file a new petition. View "Miles v. State" on Justia Law

Employee was injured while working in Minnesota for Wisconsin-based Employer. Employee applied for Wisconsin and Minnesota workers' compensation benefits. Employer's insurance company, Travelers Insurance, covered the Wisconsin benefits but denied the claim for Minnesota benefits based on an exclusion of Minnesota coverage in Employee's policy. Employee then filed a claim for Minnesota benefits with the Minnesota Department of Labor and Industry. After settling the claim, the Department pursued a petition for reimbursement it had filed against Employer. A compensation judge found that Employer was not insured for Minnesota workers' compensation liability and ordered Employer to reimburse the Department. The Workers' Compensation Court of Appeals (WCCA) reversed, concluding that Employer was entitled to coverage from Travelers under the reasonable expectations doctrine. On review, the Supreme Court reversed and remanded for reconsideration in light of a recent Court decision clarifying that the doctrine should not be used to provide coverage in contravention of unambiguous policy terms. On remand, the WCCA again reversed the compensation judge. On review, the Supreme Court reversed, holding that the WCCA had no authority to declare unambiguous language of an insurance contract to be invalid and unenforceable because the exclusion conflicted with Wisconsin statutory provisions and public policy. View "Martin v. Morrison Trucking, Inc." on Justia Law

While Timothy Allen worked as a sales associate for respondent Burnet Realty, he executed agreements to participate in respondent's legal administration program (LA Program). Under the LA Program contracts, Allen and respondent agreed to an allocation of expenses should a dispute arise related to Allen's work for respondent. In litigation commenced after he stopped working for respondent, Allen claimed that respondent violated Minn. Stat. 60K.47 because the LA Program contracts were insurance, and, as a result, respondent was required to be, but was not, authorized to engage in the business of insurance in Minnesota. Allen also claimed other relief on the basis that the contracts were insurance. The district court granted summary judgment in favor of respondent, concluding that the contracts were not contracts of insurance. The court of appeals affirmed. The Supreme Court affirmed the grant of summary judgment to respondent, holding that the LA Program was not "insurance" under statutory definitions on statute or case law. View "Allen v. Burnet Realty, L.L.C. " on Justia Law

Appellant Audie Matthews was found guilty by a jury of first-degree murder for a shooting death. When police officers were investigating the shooting, a police dog picked up a "fear scent" near the scene of the shooting and followed the scent through the neighborhood, losing the scent near the location where an officer stopped Matthews for questioning. Matthews appealed, arguing (1) the district court erred in admitting expert testimony that the police dog tracked a fear scent, and (2) the State failed to present sufficient evidence to support his conviction. The Supreme Court affirmed the conviction, holding (1) Matthews failed to establish a reasonable likelihood that the admission of the fear scent testimony significantly affected the verdict under the four factors for harmless error review, and therefore, Matthews was not entitled to a new trial based on the district court's admission of the fear scent testimony; and (2) the alleged shortcomings in the State's evidence did not support a reasonable inference other than that of guilt. View "State v. Matthews" on Justia Law

Gerald Hanson was found guilty by a jury of first- and second-degree controlled substance crime and possession of drug paraphernalia. The cout of appeals reversed, concluding that the evidence was legally insufficient to support Hanson's conviction of first-degree controlled substance crime. At issue on review was whether the evidence that Hansons possessed small, unused bags, when coupled with the remaining evidence as a whole, formed a completed chain that led directly to Hanson's guilt of possessing more than ten grams of methamphetamine with intent to sell as to exclude beyond a reasonable doubt any rational inference other than guilt. On review, the Supreme Court reversed the judgment of the court of appeals, concluding that the evidence presented, when viewed as a whole, was sufficient to support Hanson's first-degree controlled substance crime conviction. View "State v. Hanson " on Justia Law

Daniel Dalbec was found guilty of third-degree criminal sexual conduct. At Dalbec's trial, counsel for the State and Dalbec agreed to submit written closing arguments to the trial court, but defense counsel failed to submit a closing argument. On appeal, Delbec argued that he was entitled to a new trial based on a structural error that allegedly occurred when the trial court adjudicated his guilt without having received a closing argument from his counsel. The court of appeals reversed Dalbec's conviction and granted Dalbec a new trial based on the structural error. The Supreme Court granted the State's petition for review and reversed the court of appeals. At issue was whether defense counsel's failure to submit a written closing argument constituted structural error requiring automatic reversal and a new trial. The Court held (1) defense counsel's failure to submit a closing argument did not result in structural error, and (2) the trial court's adjudication of Dalbec's guilt without the benefit of closing argument was not structural error. Remanded. View "State v. Dalbec" on Justia Law

In 2008, Marlow Timberland (MT) filed a tax petition challenging the taxes payable in 2008 on the belief that Lake County's property tax assessment of MT's recently purchased land was too high. MT then filed tax petitions challenging the taxes payable in 2009 and 2010, which were dismissed due to MT's failure to pay the taxes. MT moved to reinstate the 2009 and 2010 petitions based on its contention that the properties were overassessed and that it was unable to pay the taxes due. The Minnesota Tax Court issued an order granting Lake County's motion to dismiss the 2008 petition and denying MT's motion to reinstate the 2009 and 2010 petitions. On review, the Supreme Court reversed in part and affirmed in part, holding (1) the tax court erred by not allowing MT to amend its 2008 petition because an amendment would not result in any prejudice to Lake County; and (2) the tax court properly denied MT's motion to reinstate its 2009 and 2010 tax petitions, and reinstatement of those petitions was not required on an equitable basis. Remanded. View "Marlow Timberland, L.L.C. v. County of Lake " on Justia Law

William Eldredge, an honorably discharged veteran and a firefighter employed by the City of Saint Paul, was notified by the City that it intended to terminate his employment. Eldredge challenged the termination under the Veterans Preference Act (VPA), which provided that Eldredge may not be removed from his job except for incompetency or misconduct shown after a hearing. The Saint Paul Civil Service Commission granted summary disposition in Eldredge's favor. The City sought judicial review by petitioning for and securing the issuance of a writ of certiorari from the district court. The court dismissed the writ after concluding that the City had missed the filing deadline for appeals under the VPA. The court of appeals reversed. The Supreme Court affirmed the court of appeals, holding (1) the district court erred when it concluded the writ was untimely, and (2) because the writ was timely, the district court had jurisdiction to consider the City's appeal. Remanded. View "City of Saint Paul v. Eldredge" on Justia Law

After Walter Randolph was convicted for misdemeanor domestic assault, the district court issued an order appointing private counsel to represent Randolph on appeal and required Rice County to cover the cost of appointed private counsel. The County objected to the order. The district court ordered a hearing to determine which entity had responsibility for Randolph's representation on appeal and joined intervenors Rice County and the State Board of Public Defense to the action. After a hearing, the district court (1) vacated the previous order; (2) ordered the State or District Public Defender's Office to either substitute one of its attorneys for the appointed private counsel or to pay appointed counsel reasonable attorneys fees; and (3) ordered the State Public Defender's Office to pay transcript costs. The Supreme Court granted the Board's petition for accelerated review and (1) reversed the district court's order appointing the public defender after finding that the legislature had not authorized public defenders to represent indigent misdemeanants on appeal; (2) reversed the district court's order that the State Public Defender's office pay for any required transcripts; (3) reinstated the earlier order appointing private counsel; and (4) ordered the State to cover the cost of appointed counsel. View "State v. Randolph" on Justia Law

Steven Leathers was convicted of five counts of first-degree assault against a peace officer pursuant to Minn. Stat. 609.221, 2(a). The district court sentenced Leathers to concurrent sentences totaling 189 months with eligibility for supervised release after 126 months in prison, or two-thirds of his sentence. Leathers appealed his conviction, and the State appealed the sentence. The court of appeals upheld Leathers' conviction but reversed the sentence, holding that Leathers was not eligible for supervised release. The Supreme Court granted review on the issue of supervised release. The Court reversed the court of appeals and affirmed the district court's decision, holding that the definition of the phrase "full term of imprisonment" in section 609.221, 2(b) means two-thirds of a defendant's executed prison sentence. Thus, Leathers was ineligible for work release or supervised release until he had served a full two-thirds of his sentence, after which point he would be eligible for supervised release. View "State v. Leathers" on Justia Law