Justia Minnesota Supreme Court Opinion Summaries

Appellants were landowners who elected to require a utility to condemn their property in fee after Respondents sought to acquire easements through their property by eminent domain in order to construct a high-voltage electric transmission line. After making this election, Appellants requested that Respondents provide them with minimum compensation and relocation assistance. Respondents moved the district court for an order clarifying whether such benefits are available to property owners making an election under Minn. Stat. 216E.12. The district court concluded that such benefits were available to Appellants, but the court of appeals reversed. The Supreme Court reversed, holding that Appellants satisfied the statutory criteria for receiving minimum compensation and relocation assistance and were therefore entitled to such benefits. Remanded. View "N. States Power Co. v. Aleckson" on Justia Law

Father and Mother were divorced pursuant to a judgment and decree which provided that Father pay child support to Mother. Father later moved to modify his child-support obligation, arguing that certain distributions paid to Mother as a shareholder of a closely-held subchapter S corporation should be included in her gross income, as defined by Minn. Stat. 518A.29(a) and 518A.30 for the purpose of calculating the child-support amount. The district court granted the motion. The court of appeals reversed, determining that because the distributions either were not available to Mother or were designated to pay her income tax obligation, the distributions did not constitute gross income within the meaning of the statutes. The Supreme Court reversed, holding that gross income from a shareholder's interest in a closely-held subchapter S corporation must be calculated using the statutory formula in section 518A.30 and does not depend on the amount actually distributed or available to the parent shareholder. Remanded. View "Haefele v. Haefele" on Justia Law

Appellant in this case was a nine-year-old boy with severe autism, epilepsy, and chronic seizures. The Commissioner of the Minnesota Department of Human Services (DHS) found that Appellant was not dependent in "mobility" and therefore reduced his authorized personal care assistant (PCA) services covered through the Minnesota Medical Assistance program. The district court reversed the Commissioner's decision, concluding that Minn. Stat. 256B.0659 did not require Appellant to be physically incapable of mobility to be eligible for covered services. The court of appeals reversed because Appellant was physically able to begin and complete moving from place to place without assistance. At issue was whether a person who is physically able to move without assistance but lacks the ability to direct his movement to a specific location has a dependency in mobility under the statute. The Supreme Court affirmed, holding that the Commissioner's interpretation of the statute was supported by the plain and ordinary meaning of "mobility." View "A.A.A. v. Dep't of Human Servs." on Justia Law

After a jury trial, Appellant was convicted of fleeing a peace officer by means other than a motor vehicle pursuant to Minn. Stat. 609.487(6) after she ran from a police officer who was responding to a stabbing at a bar. Appellant argued in a pretrial motion that she was entitled to a voluntary intoxication jury instruction because section 609.487(6) contains a specific-intent requirement. The district court denied the motion, ruling that the offense is a general-intent crime. The court of appeals affirmed. The Supreme Court affirmed but on different grounds, holding (1) section 609.487(6) contains a specific-intent requirement, and the district court erred in failing to instruct the jury on voluntary intoxication in this case; but (2) the error was harmless beyond a reasonable doubt because the omission of the voluntary intoxication jury instruction did not significantly affect the verdict. View "State v. Wilson" on Justia Law

Pursuant to a plea agreement, the district court convicted Respondent of aggravated forgery. After Respondent was discharged from probation, she filed a second petition for expungement of her criminal record. The district court granted Respondent's motion to expunge her criminal records, finding that sealing Respondent's record would yield a benefit commensurate with the disadvantages to the public. The court of appeals affirmed, holding that the district court had the inherent authority to expunge Respondent's criminal records held in the executive branch. The Supreme Court reversed in part, holding that because expungement of Respondent's criminal records held in the executive branch is not necessary to the performance of a unique judicial function, the district court did not have the authority to expunge Respondent's records held in the executive branch. View "State v. M.D.T." on Justia Law

In 2005, the Department of Revenue audited Relator and assessed Relator for the amount of sales tax he collected from his customers but failed to remit to the State. The Commissioner of Revenue (Commissioner) adjusted the initial assessment and assessed tax. The tax court upheld the Commissioner's assessment. The Supreme Court affirmed. In 2011, Plaintiff submitted to the Commissioner documents and an informal request for a refund based on his repayment of sales tax to his customers. The Commissioner responded to Relator by letter, in which he denied Plaintiff's request for a refund. Plaintiff appealed to the tax court. The tax court concluded it lacked subject matter over the appeal, holding that the Commissioner's letter was not an appealable order of the Commissioner because it was merely administrative correspondence. However, the court also denied Relator's claim for a refund. The Supreme Court (1) reversed the tax court's decision as to its jurisdiction, holding that the Commissioner's consideration of Relator's refund claim was a final decision on the claim that could be appealed; and (2) affirmed the tax court's decision on the merits of Relator's refund claim, holding that Relator's arguments either lacked merit or were barred by res judicata. View "Schober v. Comm'r of Revenue" on Justia Law

Employees filed a complaint against two employers (Employers), alleging that Employers violated the Minnesota Human Rights Act (MHRA) based on sexual harassment perpetrated by the sole owner of both entities (Owner). Employees also alleged that Owner was individually liable under MHRA's aiding and abetting provision. The district court dismissed Employees' claims. The court of appeals reversed, holding (1) the district court's determination that the harassment was not actionable was clearly erroneous, (2) Employees were entitled to judgment on their claims as a matter of law, and (3) Owner could not be individually liable for aiding and abetting Employers' MHRA violations. The Supreme Court reversed, holding (1) the court of appeals did not err in concluding that Owner could not be liable on an aiding and abetting theory; but (2) two separate errors of law infected the district court's determination that Employees did not prove their sexual harassment claims, and therefore, the Court was unable to ascertain exactly how the errors impacted the court's decision to dismiss Employees' claims. Remanded to the district court to reevaluate the evidence using the correct legal standard. View "Rasmussen v. Two Harbors Fish Co." on Justia Law

Respondent credit union sought to foreclose on the homestead that Appellant and her husband (Husband) owned. The district court granted summary judgment to Appellant after concluding that the mortgage Appellant signed with Respondent was void under Minn. Stat. 507.02 because it was not also signed by Husband. The court of appeals reversed, concluding that the mortgage was valid because Husband had quitclaimed all of his interest in the homestead property to Appellant before the mortgage was executed. The Supreme Court reversed, holding that the mortgage signed by Appellant in favor of Respondent was void because (1) the mortgage at issue here did not meet any of the statutory exceptions to the signature requirement in section 507.02; and (2) Husband's quitclaim deed did not constitute an explicit waiver of his rights under the homestead statute. View "Marine Credit Union v. Detlefson-Delano" on Justia Law

Respondent was adjudicated delinquent of felony burglary and misdemeanor theft. Thereafter, Respondent obtained a district court order expunging his juvenile delinquency records held by the judicial branch and sought to expunge his juvenile delinquency records held by the executive branch. The district court denied the request, but the court of appeals reversed. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) under Minn. Stat. 260B.198(6), the authority of the district court to expunge juvenile delinquency records in executive branch files is limited to the order adjudicating the juvenile delinquent; (2) to determine whether expungement is advisable within the meaning of section 260B.198(6), the district court must weight the benefit to the petitioner against the detriment to the public and the burden on the court; and (3) the district court should decide if Respondent's petition merits expungement by applying the balancing test the Court articulated here to the specific facts and circumstances of the case. View "In re J.J.P." on Justia Law

Plaintiff and his ex-wife both claimed their two children as dependents on their state individual income tax returns. The Minnesota Department of Revenue determined that only Plaintiff's ex-wife was entitled to claim the children as dependents and that Plaintiff had underpaid his state taxes. Plaintiff appealed. The extended deadline for filing Plaintiff's notice of appeal was December 27. On December 22, Plaintiff mailed his notice of appeal to the tax court and the Department of Revenue. The Department received the notice on December 27, but the notice sent to the court was marked by the court as filed on December 28. The The tax court dismissed Plaintiff's appeal for lack of subject matter jurisdiction on the ground that Plaintiff had not timely filed his notice of appeal. The Supreme Court affirmed, holding (1) the mailbox rule does not extend to statutorily created rights of appeal; and (2) Plaintiff failed to present direct evidence in support of his assertion that his notice of appeal arrived on December 27. View "Harbaugh v. Comm'r of Revenue" on Justia Law