Justia Minnesota Supreme Court Opinion Summaries
Dobbins v. State
After a jury trial, Appellant was convicted of first-degree murder. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, alleging, inter alia, that one of the witnesses who testified at Appellant's trial had given false testimony. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court reversed and remanded for a hearing. After an evidentiary hearing on remand, the postconviction court again denied the petition, concluding that Appellant was not entitled to a new trial under the Larrison v. United States test. The Supreme Court affirmed, holding the postconviction court did not abuse its discretion when (1) it concluded that certain out-of-court statements by the witness were inadmissible hearsay; and (2) it denied Appellant's request for the appointment of advisory counsel to assist him at his postconviction evidentiary hearing. View "Dobbins v. State" on Justia Law
State v. Barrientos
Respondent pleaded guilty to second-degree burglary and was placed on probation for five years. The district court also ordered Respondent to pay restitution in monthly payments. Near the expiration of Respondent's probation term, Respondent still owed $20,894 in restitution even though she had complied with the district court's payment schedule. After a hearing, the district court extended Respondent's probation for five years to facilitate continued payment of restitution. Respondent moved to amend the district court's order by reducing the extension to one year, arguing that the district court lacked the authority to extend her probation for five years because Minn. Stat. 609.135(2)(g) authorizes only two one-year extensions of probation based on the failure to pay restitution. The district court agreed and amended the extension of probation from five years to one year. The court of appeals affirmed. The Supreme Court reversed, holding that Minn. Stat. 609.135(1)(a) and Minn. Stat. 609.14 grant a district court authority to extend a term of probation up to the statutory maximum based on a defendant's failure to pay restitution by the end of the originally imposed probation term. Remanded. View "State v. Barrientos" on Justia Law
500, LLC v. City of Minneapolis
Appellant was a real estate firm that owned a vacant four-story building (the property) and sought to develop it into an office building. Before the Minneapolis City Council approved Appellant's site plan application, the Minneapolis Heritage Preservation Commission (Commission) nominated the property for designation as a local historic landmark. Appellant subsequently submitted an application for a certificate of appropriateness to the Commission. The City Council denied the application and subsequently designated the property as a local historic landmark. Plaintiff commenced this action against the City, alleging that the City violated Minn. Stat. 15.99(2)(a) by failing to approve or deny the application for a certificate of appropriateness within sixty days. The district court granted summary judgment for the City, concluding that section 15.99(2)(a) did not apply to an application for a certificate of appropriateness. The court of appeals affirmed. The Supreme Court reversed, holding that an application for a certificate of appropriateness is a "written request relating to zoning" under section 15.99(2)(a), and because the City failed to approve or deny Appellant's application within sixty days, summary judgment for the City was not proper. Remanded. View "500, LLC v. City of Minneapolis" on Justia Law
In re Application of Minn. Power for Auth. to Increase Rates for Elec. Serv. in Minn.
In 2009, Minnesota Power sought an increase in service rates of approximately 18.9 percent. As part of its submission to the Minnesota Public Utilities Commission, Minnesota Power also requested an interim rate increase of approximately $73.3 million. The Commission decided to set the interim rate increase at approximately $48.5 million after finding exigent circumstances existed. The court of appeals affirmed, concluding that the Commission did not err in finding exigent circumstances and did not abuse its discretion in setting interim rates. The Supreme Court affirmed, holding that substantial evidence supported the Commission's decision to set Minnesota Power's interim rate increase at $48.5 million. View "In re Application of Minn. Power for Auth. to Increase Rates for Elec. Serv. in Minn." on Justia Law
Posted in:
Government & Administrative Law, Utilities Law
Begin vs. Ritchie
On June 6, 2013, the Green Party of Minnesota and its chair, Brian Begin, filed a petition asserting that Respondent Secretary of State Mark Ritchie erred in decertifying the Green Party as a minor political party. Petitioners sought an order from the Supreme Court to direct the Secretary to correct his alleged error by restoring the Green Party’s minor political party status as of January 1, 2013. Because the Supreme Court concluded that the Green Party’s claims fell outside the scope of the applicable statute. As such, the Court dismissed the petition. View "Begin vs. Ritchie" on Justia Law
Posted in:
Election Law, Government & Administrative Law
Minnesota vs. Castillo-Alvarez
Appellant Juan Humberto Castillo-Alvarez challenged his convictions for second-degree murder and kidnapping. Appellant contended that Minn. Stat. 609.045 (2012) and the Double Jeopardy Clause of the Minnesota Constitution bar the prosecution in this case. He also asserted that the district court erred in admitting evidence of his unrecorded statement to law enforcement. Because neither section 609.045 nor the Minnesota Constitution bar the prosecution and because the district court properly admitted appellant's unrecorded statement, the Supreme Court affirmed.
View "Minnesota vs. Castillo-Alvarez" on Justia Law
Posted in:
Constitutional Law, Criminal Law
State v. Morrow
After a jury trial, Defendant was convicted of nine counts, including one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder, stemming from an incident in which Defendant fired a semiautomatic rifle at Joseph Rivera and two of Rivera's friends. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant's pretrial motion to dismiss the indictment, as any alleged misconduct by the State did not substantially influence the grand jury's decision to indict; (2) admitted Defendant's taped statement to police, as the statement was voluntary made; (3) admitted a photograph of Rivera as a child, as the photograph was admissible as spark of life evidence; (4) denied Defendant's motion for a mistrial based on a law enforcement officer's testimony that Defendant was truant and once swore at a teacher in high school; and (5) denied Defendant's request for surrebuttal closing argument, because even if the district court erred in denying the request, the error was harmless beyond a reasonable doubt. View "State v. Morrow" on Justia Law
State v. Griffin
After a jury trial, Defendant was convicted of first-degree murder by drive-by shooting and first-degree premeditated murder. Defendant appealed, arguing that the trial court erred in admitting out-of-court statements made by his wife and cell phone records obtained without a warrant. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting Defendant's wife's statement under Minn. R. Evid. 807; and (2) the district court did not err in finding Defendant had no subjective expectation of privacy in the cell phone records at issue under the Supreme Court's decision in State v. Gail, and therefore, the admission of the cell phone records did not violate Defendant's constitutional rights. View "State v. Griffin" on Justia Law
State v. Borg
After a jury trial, Defendant was convicted of third-degree criminal sexual conduct and sentenced to forty-eight months in prison. As part of the sentencing order, the trial court ordered Defendant to pay restitution. More than ninety days after entry of the order imposing Defendant's initial sentence, the court amended the restitution portion of Defendant's initial sentence. The State appealed the amended sentencing order, but the court of appeals dismissed the appeal because it was not filed within ninety days after the initial imposition of Defendant's sentence. The Supreme Court reversed, holding (1) the issuance of an order amending the restitution portion of a sentence constitutes a "sentence imposed" within the plain language of the relevant statute, such that the State had ninety days to appeal the amended sentencing order from the date it was entered; and (2) because the State appealed the amended sentencing order within ninety days, the appeal was timely. Remanded. View "State v. Borg" on Justia Law
Soyka v. Comm’r of Revenue
The Commissioner of Revenue ordered Sharon Soyka to pay income taxes, penalties, and interest for the 2007 tax year. Soyka had sixty days to appeal the Commissioner's order to the tax court. Instead, Soyka filed her notice of appeal to the Commissioner, who forwarded the documents to the tax court. The tax court dismissed Soyka's appeal as untimely filed because Soyka did not file her notice of appeal until more than a month after it was due and because Soyka did not file a request seeking an extension of time. The Supreme Court affirmed the tax court's dismissal of Soyka's appeal, holding (1) Soyka's failure to file her notice of appeal before the expiration of the statutory deadline deprived the tax court of subject matter jurisdiction over the appeal; and (2) because the tax court did not receive a copy of Soyka's extension request until the statutory period had expired, Soyka was not entitled to an extension of time to file her appeal. View "Soyka v. Comm'r of Revenue" on Justia Law