Justia Minnesota Supreme Court Opinion Summaries

On December 21, 2012, Petitioner, the Independence Party candidate in the November 6, 2012 election for the U.S. House of Representatives, filed this petition pursuant to Minn. Stat. 204B.44 seeking declaratory and injunctive relief and asserting three claims: (1) Minn. Stat. 202A. 16(2), which identifies those who can participate in and vote at a precinct caucus, violates his First Amendment rights; (2) the Secretary of State improperly withheld from him the e-mail addresses of registered voters in his district in violation of the Minnesota Government Data Practices Act; and (3) the district court's refusal to accept his election contest for filing infringed on his constitutional right of access to the courts. The Supreme Court denied the petition, holding (1) laches bars Petitioner's first two claims, as Petitioner unreasonably delayed bringing these claims and granting relief on the claims would do substantial prejudice to the orderly administration of elections; and (2) Petitioner's third claim falls outside the scope of section 204B.44. View "Carlson v. Ritchie" on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief requesting a new trial or an evidentiary hearing based on recanted testimony from a witness and newly discovered evidence. The postconviction court denied Appellant's motion on the grounds that it was untimely because it was filed after the two-year statutory limit, and no exception to the limitations applied. The court further concluded that the jury would not have reached a different outcome without the witness's testimony. The Supreme Court affirmed, holding that Appellant's petition was untimely, and Appellant failed to demonstrate he was entitled to relief under the newly discovered evidence exception to the time bar. View "Clifton v. State" on Justia Law

After a trial, Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct and was sentenced to life in prison. On appeal, Appellant challenged his conviction on several grounds but did not raise an ineffective assistance of counsel claim. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, asserting a claim of ineffective assistance of trial counsel. The district court summarily denied Appellant's petition. The Supreme Court affirmed, holding that Appellant's postconviction claim was barred by application of State v. Knaffla, which provides that claims that were not raised on direct appeal or were known or should have been known but were not raised on direct appeal, are procedurally barred. View "Sontoya v. State" on Justia Law

In 2000, Appellant was indeterminately committed as a sexual dangerous person as a result of a series of sex offenses involving teenage girls. Appellant later petitioned for provisional discharge from civil commitment. After weighing the evidence presented by Appellant and the Commissioner of Human Services at a first-phase hearing, the Supreme Court Judicial Appeal Panel dismissed Appellant's petition under Minn. R. Civ. P. 41.02(b). The court of appeals affirmed. The Supreme Court reversed, holding that the Appeal Panel committed reversible error in applying Rule 41.02(b) by failing to view the evidence produced at the first-phase hearing in a light most favorable to Appellant and by weighing the evidence produced during the first phase of the hearing. Remanded. View "Coker v. Jesson" on Justia Law

After the City of Moorhead annexed Americana Estates (Americana), a residential subdivision with sixty-five metered electric service accounts, the City filed a condemnation petition to begin municipal electric service to residents of Americana. After a hearing, a three-member commission of the district court awarded the Red River Valley Cooperative Power Association (RRVC), which previously served Americana, $307,214. Both parties appealed the commission's award of damages. After a jury trial, the district court awarded a total compensation award to RRVC of $385,311. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the City's valuation was inconsistent with the plain language of Minn. Stat. 216B.47 by failing to give meaningful consideration to four statutory factors and thus was properly excluded from consideration by the district court; and (2) the district court did not abuse its discretion in excluding portions of an untimely revised report submitted by the City dealing with facility replacement costs. View "City of Moorhead v. Red River Valley Coop. Power Ass'n" on Justia Law

The Living Word Bible Camp, a tax-exempt organization, owned property in Itasca County. Living Word sought to obtain the necessary governmental approvals to use the property as a summer bible camp and retreat center. Itasca County classified the property as tax-exempt from 2001 to 2007 then reclassified the property as taxable as of 2008. Living Word challenged the reclassification for the 2008 and 2009 assessments. The tax court affirmed the County's reclassification because Living Word had failed to make sufficient progress in obtaining the necessary governmental approvals for its proposed use of the property. The Supreme Court reversed, holding that the tax court (1) erred in concluding that Living Word was not entitled to an exemption because it was not using the property in furtherance of a charitable purpose; and (2) erred in determining that Living Word's current activities on the property could not be considered in determining whether that use was sufficient to qualify as a tax-exempt use. Remanded. View "Living Word Bible Camp v. County of Itasca" on Justia Law

Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct causing personal injury. The Supreme Court affirmed the conviction on appeal. Appellant subsequently filed a petition for postconviction relief, alleging a claim of newly discovered evidence. After an evidentiary hearing, the postconviction court denied the petition, concluding that the newly discovered evidence was not credible and, therefore, was not likely to produce a result more favorable to Appellant. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Appellant's petition for postconviction relief, as the record supported the court's credibility determinations. View "Tscheu v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, second-degree intentional murder, and second-degree unintentional murder while committing a felony. Defendant appealed, seeking a new trial based on the district court's allegedly erroneous admission of expert testimony offered by a medical examiner and a firearms examiner. Defendant argued that the testimony was improperly admitted because it intruded on the fact-finding role of the jury. Defendant did not object to the testimony at trial. The Supreme Court affirmed Defendant's convictions, holding that the district court properly admitted the expert testimony of the medical examiner and the firearms examiner. View "State v. Xiong" on Justia Law

Defendant was charged with several misdemeanor offenses, including driving a motor vehicle with a blood-alcohol concentration of 0.08 percent or more. Defendant filed a request to preserve "blood tests," but subsequently, the State destroyed Defendant's blood sample used in a blood alcohol test in accordance with its retention policy. Defendant pleaded not guilty and successfully moved to suppress the results of his blood-alcohol test. The court of appeals affirmed the district court's suppression order, adopting a per se rule requiring suppression when the State destroys evidence after a defendant has made a demand to preserve the evidence. The Supreme Court reversed, holding that the State did not violate any of the Minnesota Rules of Criminal Procedure when it destroyed Defendant's blood sample, and the district court erred in suppressing the results of the blood test. View "State v. Hawkinson" on Justia Law

Eden Prairie Mall, LLC (EPM) owned a mall. Included in the mall parcel for property tax purposes were the mall's in-line tenants, five anchor tenants, and a movie theater complex. EPM sought review of the tax court's market value determinations for the mall and one of its anchor tenants for the assessment dates of 2005 and 2006. The tax court adopted the market values for the mall parcel proposed by Hennepin County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. On appeal, the Supreme Court concluded the tax court's value determinations were not supported by the record and remanded with instructions for the tax court to explain its reasoning and describe the factual support in the record for its determinations. On remand, the tax court adopted market values that exceeded its earlier determinations. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions because the tax court failed to explain its reasoning and describe the factual support in the record for its determinations. Remanded. View "Eden Prairie Mall, LLC v. County of Hennepin" on Justia Law