Justia Minnesota Supreme Court Opinion Summaries

Appellant was found guilty by a jury of first-degree murder while committing malicious punishment of a child with a past pattern of child abuse for the death of his seventeen-month-old stepson. The supreme Court affirmed Appellant's conviction, holding (1) the district court did not abuse its discretion or violate Appellant's right to present an alternative perpetrator defense in limiting access to social services records; (2) the district court did not err in ruling that potential reverse-Spreigl evidence was inadmissible or violate Defendant's right to present an alternative perpetrator defense in doing so; (3) the State presented sufficient evidence to prove the element of a past pattern of child abuse beyond a reasonable doubt; (4) the jury instructions on the element of a past pattern of child abuse fairly and correctly stated the applicable law; and (5) Defendant's defense counsel did not engage in ineffective assistance of counsel by failing to object to the jury instructions, as the jury instructions given were not erroneous. View "State v. Hokanson" on Justia Law

Following a jury trial, Appellant was convicted of first-degree felony murder, attempted second-degree criminal sexual conduct, and second-degree assault. The Supreme Court affirmed the convictions. Fourteen years later, Appellant filed his second petition for postconviction relief, which the postconviction court summarily denied as untimely filed. Appellant appealed, contending that his petition should be considered because it was not frivolous and was in the interests of justice pursuant to Minn. Stat. 590.01, 4(b) The Supreme Court affirmed, holding that Appellant's postconviction claims were time-barred under section 590.01, 4, and that Appellant's petition failed to satisfy the interests-of-justice exception in Minn. Stat. 590.01, 4(b)(5) because each of the claims in the petition was frivolous. View "Wallace v. State" on Justia Law

At issue in this case was whether a vehicle may be judicially forfeited under Minn. Stat. 169A.63 when the vehicle's driver is not convicted of the designated offense of second-degree driving while impaired. Respondent was the owner of the subject vehicle, which was operated by her boyfriend when he was stopped and arrested for DWI. The vehicle was impounded, and the State sought forfeiture of Respondent's vehicle pursuant to section 169A.63. Subsequently, the boyfriend pleaded guilty to third-degree DWI. Respondent sought a judicial determination of forfeiture under section 169A.63, subdivision 9(f), and the district court ordered forfeiture of the vehicle. The court of appeals reversed, concluding that the boyfriend was not convicted of a designated offense, and therefore forfeiture was prohibited. The Supreme Court affirmed, holding (1) under Minn. Stat. 169A.63, subds.8(f) and 9(a), when a claimant makes a timely demand for a judicial determination of the validity of an administrative forfeiture, the provisions of subdivision 9 govern the judicial determination of forfeiture; and (2) under subdivision 9(f), when a person charged with a designated offense appears in court and is not convicted of the designated offense, the court shall order the property returned to the person legally entitled to it. View "Patino v. One 2007 Chevrolet" on Justia Law

At issue in this case was whether Appellants, who were employees of a contractor that performed work pursuant to a municipal contract with the City of Minneapolis, may recover for the contractor's alleged breach of a prevailing wage provision in the contract. Appellants brought this action against the contractor, alleging that the contractor failed to pay them the prevailing wage in breach of the contract with the City, that the breach of the contract by the contractor violated state wage statutes, and that the contractor was unjustly enriched as a result. The district court granted the contractor's motion for summary judgment, concluding that Appellants were not intended third-party beneficiaries and that without a viable claim for breach of contract, Appellants' other claims failed. The court of appeals affirmed. The Supreme Court affirmed, concluding that Appellants were not intended third-party beneficiaries of the contract and that Appellants' other claims lacked merit. View "Caldas v. Affordable Granite & Stone, Inc." on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree felony murder and one count of attempted first-degree felony murder. The Supreme Court affirmed Defendant's convictions, holding (1) the district court did not err by refusing to suppress shell casings seized from the back stairway of Defendant's multifamily residence, as their seizure satisfied the plain-view exception to the presumptive rule against warrantless seizures; (2) the State did not commit prosecutorial misconduct when it referenced shell casings found in Defendant's truck; (3) the district court plainly erred when it failed to instruct the jury that, in order to find Defendant guilty of attempted first-degree felony murder, the jury had to find Defendant intentionally aided his alleged accomplices in the commission of the crime, but this error did not warrant the grant of a new trial. View "State v. Milton" on Justia Law

After a jury trial, Defendant was convicted of first-degree felony murder, second-degree intentional murder, and being a prohibited person in possession of a firearm for the shooting death of a cab driver. The district court sentenced Defendant to life imprisonment on the first-degree felony murder conviction and to a sixty-month concurrent sentence on the firearm conviction but did not sentence Defendant on the second-degree intentional murder conviction. The Supreme Court vacated Defendant's second-degree intentional murder conviction but otherwise affirmed Defendant's convictions, holding (1) the district court did not err when it declined Defendant's request for a jury instruction on accomplice testimony; (2) the district court did not abuse its discretion when it instructed the jury to continue deliberating after the jury indicated it was deadlocked; and (3) the district court erred by convicting Defendant of both first- and second-degree murder because second-degree intentional murder is a lesser-included offense of first-degree murder. View "State v. Cox " on Justia Law

Six banks (the Banks) alleged that the negligent misrepresentation of Respondent, James H. Bedard, Inc., caused them to be damaged when the Housing and Redevelopment Authority of the City of Brainerd defaulted on bonds held by the Banks. Specifically, the Banks purchased $3.3 million in bonds from the City, which helped finance a development project in the City. In deciding to purchase the bonds, the Banks relied on an appraisal and feasibility study prepared by Bedard. The Banks filed a negligent misrepresentation claim against Bedard, alleging that Bedard's study overstated the value of the project and the rate at which the land would sell. The district court dismissed the action, concluding that the Banks failed to plead their negligent misrepresentation claim against Bedard with particularity. The court of appeals affirmed. The Supreme Court reversed, holding that because the Banks specifically pleaded facts underlying each of the elements of their negligent misrepresentation claim, the Banks pleaded the "ultimate facts" of their claim and thus satisfied the particularity requirement under Minn. R. Civ. P. 9.02. Remanded. View "Hardin County Savings Bank v. City of Brainerd Hous. & Redevelopment Auth." on Justia Law

Appellant was convicted of aiding and abetting first-degree felony murder. The district court sentenced Appellant to life in prison. On appeal, Appellant claimed that numerous errors entitled him to a new trial. The Supreme Court affirmed Appellant's conviction, holding (1) the jury's verdict was unattributable to any error in admitting Appellant's statement recorded after he allegedly invoked his right to remain silent, and therefore, the admission of the statement into evidence was harmless; (2) the district court did not plainly err by allowing fear testimony at trial; (3) the district court did not abuse its discretion by not admitting certain hearsay statements; (4) the district court did not plainly err by giving a no-adverse-inerence jury instruction without Appellant's clear consent; and (5) Appellant was not entitled to a new trial based on the cumulative effect of the district court's errors. View "State v. Davis" on Justia Law

The county assessor determined that the fair market value of a tax parcel, which was improved by a department store operated by respondent Federated Retail Holdings, Inc., was $17,000,000 for the year 2006. The assessor included the value of a leasehold interest held by Federated in the parcel adjacent to the tax parcel in its value determination. Federated timely filed petitions challenging the assessor's market value determinations. The tax court held that Federated's ownership interest in the tax parcel included the leasehold interest in the adjacent property, but concluded that the value of the leasehold interest was not subject to the jurisdiction of the tax court and therefore did not include it. The county appealed. The Supreme Court reversed, holding that the tax court had subject-matter jurisdiction to consider the value of Federated's leasehold interest in adjacent property because it constituted real property of the tax parcel under Minn. Stat. 272.03, 1 and affected the fair market value of the tax parcel. View "Federated Retail Holdings, Inc. v. County of Ramsey " on Justia Law

Appellant was arrested and charged with first-degree premeditated murder. At trial, Appellant admitted shooting the victim, but claimed he did so in self-defense and without premeditation. The jury, rejecting Appellant's self-defense claim, found Appellant guilty of first-degree premeditated murder, and the district court sentenced Appellant to life in prison without the possibility of release. Appellant thereafter filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed Appellant's conviction and the postconviction court's denial of postconviction relief, holding that each of Appellant's claims was either without merit or did not result in prejudice to Appellant. View "State v. Radke" on Justia Law