Justia Minnesota Supreme Court Opinion Summaries

After Gordon Brown’s debt to Citizens State Bank Norwood Young America (Bank) became delinquent, Gordon petitioned to dissolve his twenty-three-year marriage to Judy Brown. The Browns executed a marital termination agreement that was incorporated into the marital dissolution decree. Pursuant to the dissolution judgment and decree, Gordon transferred to Judy several assets. When it was unable to collect from Gordon on the original judgment, the Bank brought this action under Minnesota’s Uniform Fraudulent Transfer Act (MUFTA) to levy execution on the assets Gordon transferred to Judy, alleging that the transfers were made with the intent to defraud the Bank. The district court granted summary judgment in favor of the Bank, determining that the transfers were voidable under MUFTA. The court of appeals affirmed. The Supreme Court affirmed the district court’s judgment granting the Bank authority to levy execution on assets fraudulently transferred to the extent necessary to satisfy the Bank’s claim, holding that MUFTA applies to transfers made pursuant to an uncontested marital dissolution decree. View "Citizens State Bank Norwood Young Am. v. Brown" on Justia Law

Defendant was convicted of stalking and violating an order for protection. The district court imposed a sentence for each offense and ordered the two sentences to be served consecutively. The court held that Minn. Stat. 609.035, subd. 1, generally limits the number of sentences a defendant may receive for multiple convictions arising out of a single course of conduct; Minn. Stat. 518B.01, subd. 16, does not create an exception to Minn. Stat. 609.035, subd. 1; if separate sentences are not precluded by Minn. Stat. 609.035, subd. 1, the fact that the convictions involve a single course of conduct does not prevent a district court from imposing permissive consecutive sentences in accordance with Minn. Sent. Guidelines II.F.2.b. In this case, because the court concluded that the district court and the court of appeals erred by conflating two distinct issues - whether separate sentences may be imposed and how separate sentences should be served - the court reversed and remanded with instructions to vacate the sentence imposed for violating an order of protection. View "State v. Jones" on Justia Law

Appellant argued that he is entitled to a new trial because the court found that the judge who presided over his conviction and sentencing failed to reside in her judicial district from July 1, 2009, to September 30, 2009. The court held that Minn. Stat. 351.02(4) does not apply to a district court judge residing in Minnesota but outside her judicial district because a district court judge does not hold a "local" office as that term is used in the statute. Accordingly, because this portion of the statute does not apply to the judge in this case, the court affirmed. View "State v. Irby" on Justia Law

The funds filed suit alleging that, among other things, the pharmacies engaged in fraudulent, misleading, or deceptive practices in connection with the sale of merchandise by failing to pass on the funds the entire difference between the acquisition cost of the generic prescription drug dispensed and its brand name equivalent as required by Minn. Stat. 151.121, subd. 4. The district court granted the pharmacies's Rule 12 motion to dismiss the complaint. The court held that section 151.21, subd. 4 does not create a private cause of action in favor of union-sponsored health and welfare benefit funds against pharmacies for failing to pass on the difference between the acquisition cost of brand name drugs and substituted generic prescription drugs; an omission-based consumer fraud claim is actionable under Minn. Stat. 325F.69, subd. 1 when special circumstances exist that trigger a legal or equitable duty to disclose the omitted facts; the amended complaint did not allege facts that would trigger a legal or equitable duty for the pharmacies to disclose prescription-drug acquisition costs; and, therefore, the complaint failed to state a claim upon which relief can be granted under Minn. Stat. 325F.69, subd. 1. Accordingly, the court affirmed in part and reversed in part. View "Graphic Communications Local 1B, et al. v. CVS Caremark Corp., et al." on Justia Law

Lyon filed a breach of contract action against Illinois Paper in federal district court, alleging that Illinois Paper had breached a contractual representation and warranty that all lease transactions presented to Lyon for review would be "valid and fully enforceable agreements." The Seventh Circuit certified questions to the court under Minn. Stat. 480.065. The court reformulated the questions and held that a claim for breach of a contractual representation of future legal compliance is actionable under Minnesota law without proof of reliance. View "Lyon Financial Services, Inc. v. Illinois Paper and Copier Co." on Justia Law

Sinuon and Lawrence Leiendecker, husband and wife, were involved in litigation with Asian Women United of Minnesota (AWUM), a nonprofit organization, for a decade. In this lawsuit, the fifth suit between the parties,the Leiendeckers sought to recover for injuries allegedly inflicted by AWUM and other defendants through the suits the defendants brought against the Leiendeckers in the past. AWUM moved for dismissal under Minnesota’s anti-SLAPP statutes. The district court denied AWUM’s anti-SLAPP motion, concluding that the allegations in the Leiendeckers’ complaint were sufficient to defeat the motion. The Supreme Court reversed, holding that the anti-SLAPP statutes required the Leiendeckers to produce evidence to defeat the anti-SLAPP motion rather than rely solely on the allegations in their complaint. View "Leiendecker v. Asian Women United of Minn." on Justia Law

The Commissioner of Revenue notified JME of Monticello (JME), a waste management service provider, that it intended to audit JME’s waste management returns for a certain period. After the audit, JME was assessed approximately $87,000 in additional solid waste management taxes and interest. The Commissioner reached this determination after concluding that JME improperly calculated its waste management tax based on JME’s incorrect interpretation of Minn. Stat. 297H.04. JME appealed and brought a motion for summary judgment. The tax court upheld the Commissioner’s tax order. The Supreme Court affirmed, holding that the Commissioner correctly interpreted section 297H.04 and had correctly calculated the tax. View "JME of Monticello, Inc. v. Comm’r of Revenue" on Justia Law

After a jury trial in 1992, Appellant was found guilty of two counts of first-degree murder and two counts of attempted first-degree murder. Appellant was fifteen years old at the time. Under a mandatory sentencing scheme, the district court imposed life sentences with the possibility of release after thirty years for the first-degree murder convictions. After the United States Supreme Court decided Miller v. Alabama in 2012, Appellant filed a postconviction motion to correct his sentence, arguing that his sentence violated the rule announced in Miller. The postconviction court denied the motion, concluding that Appellant’s sentence was lawful because Miller was not retroactive. The Supreme Court affirmed without reaching the issue of Miller’s retroactivity, holding that Miller did not make the sentencing scheme at issue here unlawful because the mandatory sentencing scheme did not require life imprisonment without the possibility of release. View "Ouk v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder and sentenced to a term of life imprisonment. The Supreme Court affirmed on appeal. After Appellant’s first petition for postconviction relief was denied, Appellant filed the petition for postconviction relief at issue in this appeal. Defendant requested an evidentiary hearing and court-appointed counsel to assist with his petition. The postconviction court denied Appellant’s requests and summarily denied the petition, concluding that the petition was procedurally barred. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion denying the petition without appointing counsel and without holding an evidentiary hearing. View "Hughes v. State" on Justia Law

After she was arrested for driving while impaired, Driver took a urine test, which revealed an alcohol concentration of twice the legal limit. Pursuant to the state’s implied consent law, Driver’s license was revoked. Driver sought judicial review, arguing that her license should not have been revoked because she acted out of necessity to protect herself from her violent husband. After an implied consent hearing, the district court upheld the revocation, concluding that necessity is not an affirmative defense that drivers may raise to challenge a civil license revocation. The Supreme Court affirmed, holding that the plain language of Minn. Stat. 169A.53(3) does not permit a driver to raise the affirmative defense of necessity at an implied consent hearing. View "Axelberg v. Comm’r of Pub. Safety" on Justia Law