Justia Minnesota Supreme Court Opinion Summaries

The subject property was located at 44 Lafayette Road in Saint Paul. Relators challenged the County's assessments for the assessment dates 2007, 2008, and 2009. After trial, the tax court adopted the market values proposed by the County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. The Supreme Court reversed and remanded with instructions for the tax court to explain its reasoning for rejecting the appraisal testimony and to describe the factual support in the record for its determinations. On remand, the tax court again adopted market values that exceeded the parties' appraisal opinions. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions in its calculation of parking income and expenses. Remanded for a further evidentiary hearing regarding the appropriate calculation of net parking income. View "444 Lafayette, LLC v. County of Ramsey" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, first-degree intentional drive-by shooting murder, attempted first-degree premeditated murder, and attempted first-degree intentional drive-by shooting murder. Defendant filed two petitions for postconviction relief, both of which were denied. Several years after his convictions, Defendant filed a third petition for postconviction relief, arguing that the grand jury selection process in Hennepin County violated his constitutional rights to due process and equal protection. Defendant maintained that his current petition was excepted from the statutory two-year time limit. The postconviction court denied Defendant's petition for postconviction relief, concluding that the petition was time barred and that the newly-discovered-evidence exception did not apply and alternatively, that the petition was barred under the Knaffla doctrine. The Supreme Court affirmed, holding that Defendant's petition failed to satisfy an exception to the two-year limitations period, and therefore, the petition was time barred. View "Francis v. State" on Justia Law

1st Fidelity Loan Servicing initiated a foreclosure by advertisement to collect the debt secured by a mortgage on the home of Respondent. 1st Fidelity subsequently purchased the property at the foreclosure sale. Respondent filed a complaint seeking a declaration that the sale was null and void and the recovery of monetary damages, alleging that 1st Fidelity failed to comply with certain statutory requirements. The district court granted summary judgment in favor of 1st Fidelity on the ground that it had substantially complied with the relevant statutes. The court of appeals reversed, concluding that Minnesota's foreclosure by advertisement statute requires strict compliance and that a foreclosing party's failure to strictly comply renders the foreclosure void. The Supreme Court affirmed, holding (1) a party must strictly comply with Minn. Stat. 580.02(3), which requires that all assignments of a mortgage be recorded before a party is entitled to make a foreclosure by advertisement; and (2) because 1st Fidelity did not strictly comply with section 580.02(3), the foreclosure was void. Remanded. View "Ruiz v. 1st Fidelity Loan Servicing, LLC " on Justia Law

Relator was at all times relevant to this case employed by the National Basketball Association as a referee. Relator did not file Minnesota income tax returns for the 2003 and 2004 tax years but subsequently filed a 2003 state tax return as a part-year Minnesota resident. The Commissioner of Revenue determined that Relator was a full-time, legal resident of Minnesota during the relevant tax years. Relator appealed, asserting that, in 2003, he established his domicile in Florida. The Commissioner again determined that Relator was a full-time Minnesota resident during the 2003 and 2004 tax years, and the tax court affirmed. The Supreme Court affirmed, holding that sufficient evidence supported the tax court's decision, and the court correctly concluded that Relator failed to carry his burden of overcoming the legal presumption that he remained domiciled in Minnesota during the 2003 and 2004 tax years. View "Mauer v. Comm'r of Revenue" on Justia Law

Defendant was convicted in 1990 of first-degree premeditated murder. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed a petition for postconviction relief requesting an evidentiary hearing to consider evidence he asserted was new and exculpatory. Specifically, Defendant sought a hearing to consider (1) newly discovered eyewitness testimony, which he claimed buttressed his alternative-perpetrator theory, and (2) whether he was entitled to have DNA testing of a sample from a smear found at the crime scene. The postconviction court denied Defendant's petition and motion without an evidentiary hearing, concluding that Defendant did not meet the standard for receiving an evidentiary hearing. The Supreme Court affirmed, holding that Defendant failed to meet the threshold required for relief, and thus, the postconviction court did not abuse its discretion when it denied Defendant's motion without an evidentiary hearing. View "Fort v. State" on Justia Law

In 2002, Employee suffered injuries in a work-related accident and was rendered a paraplegic. Employer and its insurer accepted liability for Employee's injuries and paid various workers' compensation benefits. In 2010, Employee filed a medical request seeing payment for the installation of a ceiling-mounted motorized lift system. A compensation judge (1) determined that the cost of making the structural changes was compensable under Minn. Stat. 176.135 because those changes were necessary to provide Employee with reasonable and necessary medical treatment, and (2) ordered Employer and its insurer to pay for the modifications in their entirety. The workers' compensation court of appeals reversed, concluding that the changes to Employee's home necessary to permit installation of the lift system constituted "alteration or remodeling" of Employee's home and that Employer's liability was therefore limited by Minn. Stat. 176.137. The Supreme Court affirmed, holding that the cost of the structural modifications to Employee's residence that were necessary to permit the ceiling-mounted track system to be installed were "alteration or remodeling" costs subject to section 176.137 and were not costs of medical treatment. View "Washek v. New Dimensions Home Health & State Fund Mut. Ins. Co. " on Justia Law

At the time of his divorce from Wife, Husband was a participant in a pension fund (Fund). To enforce the interest awarded to her under the decree, Wife needed to serve a domestic relations order (DRO) on the Fund and its administrators (collectively, the Plan) for qualification. Before Wife served any DRO on the Plan, Husband remarried. At the time of Husband's retirement, he made a survivor annuity payable to his current spouse upon his death. Wife eventually served a DRO on the Plan in 2005, but the Plan refused to qualify the DRO. After Husband died, Wife brought a motion to enforce the 2005 DRO. The district court ruled in favor of Wife, concluding (1) surviving spouse benefits do not vest in a plan participant's current spouse at the time of the plan participant's retirement; and (2) therefore, the 2005 DRO served on the Plan was a qualified domestic relations order. The court of appeals reversed. The Supreme Court affirmed, holding (1) under ERISA, surviving spouse benefits vest in a plan participant's current spouse at the time of the plan participant's retirement; and (2) accordingly, the 2005 DRO in this case could not be qualified. View "Langston v. Wilson McShane Corp." on Justia Law

Two children's foster parents filed a petition to adopt the children, as did the children's grandparents. The district court concluded that it was in the best interests of the children to be adopted by the foster parents and accordingly granted the foster parents' petition. The court then denied the adoption petition of the grandparents. The court of appeals affirmed. The grandparents appealed, contending that the district court erred in not according them preference and ignoring the plain language of Minn. Stat. 259.57(2)(c) by considering the grandparents' and the foster parents' petitions side-by-side. The Supreme Court affirmed, holding that the district court properly applied section 259.57(2)(c) and did not abuse its discretion in concluding that adoption by the foster parents was in the children's best interests. View "In re Petition to Adopt P.U.K." on Justia Law

On their 2007 Minnesota individual income tax return, John and Deborah Billion claimed a $55,904 deduction for carryover losses incurred in 2005 by a Minnesota subchapter S corporation in which John Billion was a shareholder. The Minnesota Commissioner of Revenue disallowed the Billions' deduction, resulting in an assessment of $3,736 in additional Minnesota income taxes for the 2007 tax year. The tax court upheld the assessment. The Supreme Court affirmed in part and reversed in part, holding (1) the Billions were entitled to a carryover net operating loss deduction of $7,834 on their 2007 individual income tax return; but (2) the tax court did not err in its judgment in all other respects. Remanded for recalculation of the Billions' Minnesota income tax liability for the 2007 tax year. View "Billion v. Comm'r of Revenue" on Justia Law

Second Chance Investments, LLC (SCI) purchased a fire insurance policy from Auto-Owners Insurance Company (Auto-Owners) that covered a building with the limit of insurance set at $2,095,500. The building subsequently suffered extensive fire damage. SCI filed a proof of loss claiming the building was a total loss. Auto-Owners rejected the proof of loss, contending that it did not state the actual cash value of the loss as required by the policy or provide a written estimate of repair to support the claim. After a continued dispute over whether the property was a total loss, Auto-Owners ultimately filed a complaint in district court seeking an order compelling SCI to submit the issue of whether the building was a total loss to a binding determination by an appraisal panel. The district court denied Auto-Owners' motion to compel appraisal and dismissed its complaint. The court of appeals affirmed, concluding that a court, rather than an appraisal panel, is the appropriate forum to determine whether the property suffered a total loss. The Supreme Court affirmed, holding that a party to a fire insurance policy does not have the statutory right to have an appraisal panel decide whether a claim involves a total loss. View "Auto-Owners Ins. Co. v. Second Chance Invs., LLC" on Justia Law