Justia Minnesota Supreme Court Opinion Summaries

After David McKee, a physician, acted in a manner Dennis Laurion considered rule and insensitive, Laurion posted critical comments about McKee on various "rate-your-doctor" websites and also sent letters to several medically-affiliated institutions complaining about McKee's conduct. McKee commenced this action against Laurion, asserting claims for defamation per se and interference with business. The district court granted summary judgment for Laurion, concluding that the individual statements were either protected opinion, substantially true, or lacked defamatory meaning. The court of appeals reversed with respect to six of the alleged defamatory statements. The Supreme Court reversed, holding that none of the six statements was actionable either because (1) there was no genuine issue of material fact as to the falsity of the statements, or (2) the statements were not capable of conveying a defamatory meaning that would harm McKee's reputation and lower him in the estimation of the community. View "McKee v. Laurion" on Justia Law

After a jury trial, Appellant was convicted of aiding and abetting first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence. Appellant subsequently filed a petition for postconviction relief alleging seven claims. The postconviction court summarily denied the petition without a hearing. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the postconviction court erred in denying Appellant's request for an evidentiary hearing on his claim of witness recantation; but (2) the postconviction court did not err in finding Appellant's ineffective-assistance-of-counsel claim to be without merit and in concluding that Appellant's remaining claims were barred by State v. Knaffla. View "Martin v. State" on Justia Law

Appellant, an enrolled member of the Leech Lake Band of Ojibwe, was civilly committed to the Minnesota Sex Offender Program (MSOP). Appellant appealed, challenging his indeterminate civil commitment by asserting three substantive claims. The Supreme Court affirmed, holding (1) the district court had jurisdiction to indeterminately civilly commit an enrolled member of the Leech Lake Band of Ojibwe; (2) the doctrines of collateral estoppel and res judicata did not preclude the State from presenting in the civil commitment proceeding evidence of conduct alleged in earlier criminal cases that ended in acquittals; and (3) Appellant waived his to right appellate review of his claim that the State violated the Minnesota Constitution when it committed him without a trial by jury. View "Beaulieu v. Dep't of Human Servs." on Justia Law

Appellant was convicted of aiding and abetting first-degree murder and aiding and abetting attempted first-degree murder. Appellant appealed, arguing that the district court committed reversible error in admitting a statement she made to police as the fruit of an unlawful arrest in violation of the Fourth Amendment. The Supreme Court affirmed, holding (1) the trial court erred in admitting Appellant's statement to police because the taint of Appellant's unlawful arrest was not purged at the time Appellant made her statement, and therefore, the statement was inadmissible; but (2) the trial court's error in admitting this statement was harmless beyond a reasonable doubt. View "State v. McDonald-Richards" on Justia Law

Respondent sued Appellants for negligence and resulting injuries sustained in a car accident. The parties entered into a tentative settlement subject to Respondent giving her underinsured motorist (UIM) carrier notice under Schmidt v. Clothier to preserve her potential UIM claim. The UIM carrier elected to substitute its check for the tortfeasor's check pursuant to Schmidt-Clothier. Respondent accepted the substitute check. The negligence claim proceeded to trial, where a jury found Appellants negligent. The district court entered judgment in favor of Respondent and the UIM carrier. The court of appeals affirmed the judgment for Respondent but reversed for the UIM carrier. The Supreme Court affirmed the reversal of the judgment in favor of the UIM carrier but reversed the court of appeals' decision affirming the judgment for Respondent, holding that an injured party may not continue to pursue a negligence claim against the tortfeasor after she has agreed to settle the negligence action under the Schmidt-Clothier procedure and has accepted the substituted check from the UIM carrier. View "Isaac v. Ho" on Justia Law

L.H. Bolduc Company, Inc. (Bolduc) was the subcontractor of Engineering and Construction Innovations, Inc. (ECI). Bolduc damaged a sewer pipe while working on a construction project. ECI repaired the damage and sought reimbursement from Bolduc's insurer, The Travelers Indemnity Company of Connecticut (Travelers) under an endorsement to Bolduc's policy naming ECI as an additional insured for liability caused by acts or omissions of Bolduc. Travelers denied coverage. ECI subsequently sued Bolduc and Travelers (collectively, Appellants) for negligence and breach of contract. A jury found that Bolduc was not negligent, and the district court granted summary judgment for Appellants on ECI's breach of contract claims, concluding that Appellants had no obligation to reimburse ECI for damages not caused by Bolduc. The court of appeals reversed, determining (1) ECI was entitled to coverage as an additional insured without regard to Bolduc's fault; and (2) Bolduc was required to indemnity ECI. The Supreme Court reversed, holding (1) ECI did not qualify as an additional insured with respect to the pipe damage; and (2) Bolduc could not be required to indemnify ECI without violating Minn. Stat. 337.02, which prohibits indemnification for the fault of others in construction contracts. View "Eng'g & Constr. Innovations, Inc. v. L.H. Bolduc Co., Inc." on Justia Law

Todd County assessed taxes on property owned by John and Carrie Beck based on its conclusion that the property had an estimated market value of $397,400 as of January 2, 2009. John petitioned the tax court for relief. After a trial, the tax court found the fair market value of the property on that date was $395,000. John appealed, arguing that the tax court erred by (1) adopting the appraisal of Todd County's expert despite several challenges John raised to the assumptions and values underlying the appraisal, (2) rejecting the testimonies of John and Carrie challenging the County's assessment of the property, and (3) not determining separate land and improvement values for the property. The Supreme Court reversed because the tax court completely failed to address why it rejected the extensive evidence offered by John in support of his petition for tax relief. Remanded for the tax court to explain adequately the reasoning underlying its valuation determination. View "Beck v. County of Todd" on Justia Law

From 1999-2006, Relator filed his Minnesota individual income tax return as a nonresident. After the Commissioner of Revenue conducted two audits of Relator's individual income tax returns spanning the 2002-2006 tax years, the Commissioner determined that Relator was a resident of Minnesota during the tax years. Relator appealed, arguing that he became a resident of Nevada in 1998, and therefore, the Commissioner erred in requiring him to pay taxes as a Minnesota resident during the relevant tax years. The tax court affirmed, concluding that Relator was a Minnesota domiciliary during the tax years and, therefore, was a resident of Minnesota for income tax purposes. The Supreme Court affirmed, holding that the tax court did not err in its application of the law, and the record supported the tax court's determination. View "Larson v. Comm'r of Revenue" on Justia Law

This case arose out of three biting incidents involving a dog owned by Respondent. After the first bite, the City of Lino Lakes designated Respondent's dog as "potentially dangerous," and after the second bite, the City designated the dog as "dangerous." After the third bite, the City ordered the dog to be destroyed. The court of appeals reversed the City's decisions, holding that Appellant's inability to challenge the "potentially dangerous" designation violated his right to procedural due process. The Supreme Court reversed the decision of the court of appeals, upheld the City's designation of the dog as "dangerous," and affirmed the City's order to destroy the dog, holding (1) Respondent was not constitutionally entitled to a hearing to challenge the "potentially dangerous" designation; and (2) substantial evidence supported the City's decisions. View "Sawh v. City of Lino Lakes" on Justia Law

Relators represented a putative class including all residential property owners in three Minneapolis neighborhoods. Relators challenged the assessed values that the City placed on Relators' properties and alleged that because their properties were overvalued, Relators were required to overpay property taxes in 2009 through 2011. The tax court dismissed Relators' complaint, holding (1) because Relators alleged that the City's assessment practices were illegal, Minn. Stat. 278 provided the Realtors' exclusive remedy, (2) Relators' 2008 and 2009 claims were untimely under chapter 278, and (3) Relators' 2010 claims failed because chapter 278 did not allow multiple taxpayers to file a single action concerning multiple properties. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) Relators' claims based on the 2008 and 2009 tax years were untimely pursuant to chapter 278; but (2) because the plain language of chapter 278 allows multiple taxpayers to file one tax action concerning multiple properties, the tax court erred in dismissing Relators' claims based on the 2010 tax year to the extent those claims alleged a violation of Minn. Stat. 273.11. View "Odunlade v. City of Minneapolis" on Justia Law