Justia Minnesota Supreme Court Opinion Summaries

Policyholder obtained a title insurance policy from Insurer for a parcel of property it owned. Because an ambiguity in the legal description of the property prevented Policyholder from reselling the property, Policyholder filed an action seeking a declaration of Insurer's obligations under the policy and alleging breach of contract against Insurer. The district court held in favor of Policyholder, concluding that Insurer was liable because the title to the property was unmarketable. The court, however, limited Policyholder's recovery to the face value of the policy. The court of appeals affirmed the finding of liability but held that Policyholder was entitled to recovery in excess of the policy limit. The Supreme Court (1) affirmed the district court's grant of partial summary judgment to Policyholder on the question of Insurer's liability for its failure to defend and indemnify Policyholder; but (2) reversed the court of appeals' award of damages to Policyholder in excess of the policy limit and remanded for reinstatement of the district court's award of damages. View "Mattson Ridge, LLC v. Clear Rock Tile, LLP" on Justia Law

Petitioners sought an order requiring that Respondents, the St. Louis County Auditor and the Minnesota Secretary of State, place Erik Simonson's name on the ballot for the 2012 general election as the candidate for the Democratic-Farmer-Labor (DFL) Party for the office of State Representative for House District 7B. Petitioners contended that the County Auditor erred by refusing to accept the affidavit of withdrawal submitted by DFL-nominated candidate Kerry Gauthier and affidavit of candidacy submitted by newly nominated DFL candidate Simonson for the general election in District 7B. The Supreme Court concluded that Minnesota law required Simonson's name to be placed on the November 2012 ballot by order filed in September 2012, with this opinion to follow, holding (1) a major political party has statutory authority to fill a vacancy in nomination for a partisan office that was caused by the withdrawal of its originally nominated candidate after the primary, as long as the originally nominated candidate complied with the procedures for filing an affidavit of withdrawal; and (2) the County Auditor erred when he rejected the affidavit of withdrawal that Gauthier attempted to file and the certificate of nomination listing Simonson as the DFL-nominated candidate that the DFL attempted to file. View "Martin v. Dicklich" on Justia Law

In Martin v. Dicklich, the Supreme Court ordered the Saint Louis County Auditor to replace the name of Kerry Gauthier with the name of Erik Simonson as the Democratic-Farmer-Labor (FL) endorsed candidate for state representative, House District 7B, on the November 2012 general election ballot. Jay Fosle, who had previously declared his write-in candidacy for state representative, District 7B, was not served with a copy of the Martin petition. Fosle subsequently filed a petition with the Supreme Court, asking the Court to order that his name also be placed on the November 2012 ballot either as the "Independent candidate" or without party affiliation. The Supreme Court denied Fosle's petition by order filed in October 2012, with this opinion to follow, holding that there was no statutory or other basis on which to grant the relief Fosle sought here. View "Fosle v. Ritchie" on Justia Law

Relator challenged several personal liability assessments that the Commissioner of Revenue made against him based on unpaid petroleum and sales taxes owed by Twin Cities Avanti Stores, LLC (Avanti). On appeal, Relator asserted that the tax court erred by granting summary judgment to the Commissioner because (1) there were disputed, material questions of fact regarding his personal liability for the unpaid petroleum and sales taxes, and (2) the court abused its discretion in not allowing additional discovery to explore an estoppel defense. The Supreme Court reversed the tax court's grant of summary judgment in favor of the Commissioner and remanded for a trial, holding that there was a material dispute of fact whether Relator had the requisite control over the company's finances to be held personally liable for Avanti's tax liability. View "Stevens v. Comm'r of Revenue" on Justia Law

Relator challenged several personal liability assessments that the Commissioner of Revenue made against him based on unpaid petroleum and sales taxes owed by Twin Cities Avanti Stores, LLC. In his appeal, Relator did not dispute that he could be held personally liable but asserted that the tax court erred in granting summary judgment to the Commissioner because the court did not allow him additional discovery to explore an estoppel defense. The Supreme Court affirmed, holding that because Relator could not establish the elements of equitable estoppel, the tax court did not abuse its discretion when it denied his request for additional discovery to pursue such a claim. View "Nelson v. Comm'r of Revenue" on Justia Law

Petitioner, the Commissioner of the Minnesota Department of Management and Budget, sought validation of certain tobacco appropriation bonds to be issued to refund, in advance of maturity, outstanding tobacco securitization bonds issued in 2011. The only disputed issue in this proceeding was whether the proposed tobacco appropriation bonds were constitutional under the Minnesota Constitution. The Commissioner argued that the bonds did not implicate Minnesota's constitutional limitations on incurring public debt. The attorney general argued that the bonds constituted a "subterfuge to evade the balanced budget requirement" of the Minnesota Constitution. The Supreme Court concluded (1) the proposed tobacco appropriation bonds did not constitute public debt for which the state's full faith, credit, and taxing powers have been pledged under the plain language of Minn. Const. art. XI, 4; and (2) therefore, the restrictions imposed by Minn. Const. art. XI, 5 do not apply to the bonds. View "Schowalter v. State" on Justia Law

A jury found Appellant guilty of first-degree premeditated murder and second-degree intentional murder. The Supreme Court affirmed, holding that the district court did not err in (1) denying Appellant's motion to suppress his statement to police, as Appellant was not in custody or under arrest when the statement was made; (2) refusing to instruct the jury that Appellant's girlfriend, H.J., was an accomplice as a matter of law, as the issue of whether H.J. was an accomplice was a fact question for the jury; (3) failing to instruct the jury on the aiding-and-advising theory of accomplice liability; and (4) admitting evidence of Appellant's prior assaults of H.J. View "State v. Scruggs" on Justia Law

Appellant was charged with first- and third-degree on the ground that Appellant injured a young child in his care. A jury found Appellant not guilty of both charges, and the district court entered a judgment of acquittal. Appellant then petitioned the district court for an order sealing the criminal records related to the alleged assault. The district court granted Appellant's petition, concluding that the State failed to prove by clear and convincing evidence that the public's interests outweighed Appellant's interests pursuant to Minnesota's expungement statute. The court of appeals reversed, finding that Appellant proved no specific disadvantage to himself against which to balance the interests of the public. The Supreme Court reversed the decision of the court of appeals, holding that an expungement petitioner is not required to prove specific disadvantages he or she will suffer if the petition is denied and may instead satisfy his or her burden of production simply by establishing the fact of his or her acquittal. View "State v. R.H.B." on Justia Law

At issue in this dispute over a mortgage was whether statutes of limitations apply to actions for declaratory judgment. The court of appeals reversed in part the district court's grant of summary judgment to Defendant based on the applicable statute of limitations, holding that to the extent Plaintiff's complaint sought declaratory relief, it was not barred by the statute of limitations. The Supreme Court reversed, holding that because the Uniform Declaratory Judgments Act is a procedural device through which parties may vindicate substantive legal rights, an action for declaratory judgment is barred by an applicable statute of limitations to the same extent that the same cause of action would be barred in a nondeclaratory proceeding. Remanded. View "Weavewood, Inc. v. S & P Home Invs., LLC" on Justia Law

Appellant pled guilty to first-degree murder while committing domestic abuse and was sentenced to life imprisonment with the possibility of parole. Defendant did not appeal but subsequently filed a postconviction petition, alleging that his guilty plea was invalid because it lacked a proper factual foundation. The postconviction court denied relief on the ground that the petition was untimely and lacked substantive merit. The Supreme Court affirmed, holding (1) because there was sufficient evidence of a past pattern of domestic abuse and sufficient evidence of an extreme indifference to human life, Appellant's claim that he was entitled to withdraw his plea failed on the merits, and therefore, Appellant failed to establish a manifest injustice entitling him to withdraw his guilty plea; and (2) therefore, the Court did not need to reach the remaining issues raised in this appeal. View "Lussier v. State" on Justia Law