Justia Minnesota Supreme Court Opinion Summaries

Defendant was found guilty of first-degree murder while committing domestic abuse with a past pattern of domestic abuse, and second-degree murder while committing a felony. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to prove that Defendant assaulted the victim and caused his death; (2) the State presented sufficient evidence to prove Defendant had engaged in a past pattern of domestic abuse; (3) the district court did not err in failing to instruct the jury that a past pattern of domestic abuse requires proof beyond a reasonable doubt of at least two prior acts of abuse; and (4) the district court did not err in failing to instruct the jury that it needed to agree unanimously on which two specific acts of past abuse were proven beyond a reasonable doubt. View "State v. Hayes" on Justia Law

Appellants hired Respondent as the general contractor to build a seasonal residence on Appellant's property. Respondent purchased a general liability insurance policy from Midwest Family Mutual Insurance Company that included an absolute pollution exclusion. Respondent later purchased a boiler for Appellant's home that bore a label warning that the boiler was designed to run on natural gas only. Respondent connected the boiler to a liquid propane line. Appellants were later transported to hospital due to carbon monoxide poisoning from the boiler. Appellants brought litigation against Respondent. Midwest initiated a declaratory judgment action, requesting that the district court find Midwest had no duty to defend or indemnify Respondent because coverage was barred under the absolute pollution exclusion. The district court denied Midwest's motion for summary judgment, concluding that it would be inappropriate to rule as a matter of law that the absolute pollution exclusion barred coverage under the facts in this case since Respondent did not cause any environmental pollution. The court of appeals reversed, holding that carbon monoxide constitutes a pollutant in the Midwest policy. The Supreme Court affirmed, holding that carbon monoxide released from a negligently installed boiler is clearly a "pollutant" that is subject to the absolute pollution exclusion of the Midwest policy. View "Midwest Family Mut. Ins. Co. v. Wolters" on Justia Law

This case involved a facial challenge to the constitutionality of the City of Red Wing's rental property inspection ordinance. Appellants were landlords and tenants who brought suit seeking a declaratory that the City's ordinance violated the Minnesota Constitution. The district court granted summary judgment in favor of the City, concluding that Appellants lacked standing and that the constitutional claim failed on the merits. The court of appeals affirmed, ruling that Appellants lacked standing. The Supreme Court reversed, holding that Appellants' facial challenge presented a justiciable controversy. On remand, the court of appeals again affirmed, this time concluding that the City's ordinance did not violate the state constitution. The Supreme Court affirmed, holding (1) the law can be applied constitutionally; and (2) because Appellants did not satisfy their burden in a facial challenge to show that the ordinance operated unconstitutionally in all of its applications, Appellants' facial challenge failed. View "McCaughtry v. City of Red Wing" on Justia Law

Respondents, on behalf of their six-year-old daughter, Jocelyn, alleged that Appellants, a medical doctor and medical center, negligently failed to diagnose Jocelyn's cancer and that if they had timely diagnosed Jocelyn's cancer, her cancer would have been curable. But, Respondents asserted, because of the delayed diagnosis, it was likely Jocelyn's cancer would be fatal. The district court granted summary judgment in favor of Appellants, concluding (1) Minnesota law does not permit a patient to recover damages when a physician's negligence causes the patient to lose only a chance of recovery or survival; and (2) Respondents' proof of causation failed as a matter of law. The court of appeals reversed the grant of summary judgment in favor of Appellants. The Supreme Court affirmed, holding (1) Minnesota law permits recovery for "loss of chance" in a medical malpractice action; and (2) Respondents created a genuine issue of material fact on the issue of causation. View "Dickhoff v. Green" on Justia Law

The grandparent visitation statute allows a court to award visitation as part of several different kinds of proceedings, including a proceeding for parentage. The district court awarded grandparent visitation to the paternal grandmother (Grandmother) of T.H. after concluding that the recognition of parentage executed by T.H.'s parents pursuant to Minn. Stat. 257.75 was a "proceeding" for parentage under the grandparent visitation statute. The court of appeals affirmed. T.H.'s mother appealed, contending that the district court lacked subject matter jurisdiction to award visitation to Grandmother. The Supreme Court affirmed, holding (1) a recognition of parentage executed and filed with the appropriate state agency under section 257.75 is a "proceeding" for purposes of the grandparent visitation statute; and (2) therefore, a "proceeding" occurred in this case, and the district court had subject matter jurisdiction to award visitation to Grandmother. View "Christianson v. Henke" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and related charges. The district court sentenced Appellant on the first-degree murder conviction to a mandatory sentence of life imprisonment without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence on direct appeal. Appellant subsequently filed a second petition for postconviction relief, alleging that his sentence was unconstitutional under the Eighth Amendment. The postconviction court denied Appellant's petition without an evidentiary hearing, concluding that the petition was time barred and that none of the exceptions to the time bar applied. Appellant appealed, contending that his sentence violated the Eighth Amendment and that recent decisions of the U.S. Supreme Court satisfied an exception to the time bar. The Supreme Court affirmed, holding that the cases upon which Appellant relied were either not applicable to Appellant or did not apply retroactively to him. View "Chambers v. State" on Justia Law

Appellants were landowners who elected to require a utility to condemn their property in fee after Respondents sought to acquire easements through their property by eminent domain in order to construct a high-voltage electric transmission line. After making this election, Appellants requested that Respondents provide them with minimum compensation and relocation assistance. Respondents moved the district court for an order clarifying whether such benefits are available to property owners making an election under Minn. Stat. 216E.12. The district court concluded that such benefits were available to Appellants, but the court of appeals reversed. The Supreme Court reversed, holding that Appellants satisfied the statutory criteria for receiving minimum compensation and relocation assistance and were therefore entitled to such benefits. Remanded. View "N. States Power Co. v. Aleckson" on Justia Law

Father and Mother were divorced pursuant to a judgment and decree which provided that Father pay child support to Mother. Father later moved to modify his child-support obligation, arguing that certain distributions paid to Mother as a shareholder of a closely-held subchapter S corporation should be included in her gross income, as defined by Minn. Stat. 518A.29(a) and 518A.30 for the purpose of calculating the child-support amount. The district court granted the motion. The court of appeals reversed, determining that because the distributions either were not available to Mother or were designated to pay her income tax obligation, the distributions did not constitute gross income within the meaning of the statutes. The Supreme Court reversed, holding that gross income from a shareholder's interest in a closely-held subchapter S corporation must be calculated using the statutory formula in section 518A.30 and does not depend on the amount actually distributed or available to the parent shareholder. Remanded. View "Haefele v. Haefele" on Justia Law

Appellant in this case was a nine-year-old boy with severe autism, epilepsy, and chronic seizures. The Commissioner of the Minnesota Department of Human Services (DHS) found that Appellant was not dependent in "mobility" and therefore reduced his authorized personal care assistant (PCA) services covered through the Minnesota Medical Assistance program. The district court reversed the Commissioner's decision, concluding that Minn. Stat. 256B.0659 did not require Appellant to be physically incapable of mobility to be eligible for covered services. The court of appeals reversed because Appellant was physically able to begin and complete moving from place to place without assistance. At issue was whether a person who is physically able to move without assistance but lacks the ability to direct his movement to a specific location has a dependency in mobility under the statute. The Supreme Court affirmed, holding that the Commissioner's interpretation of the statute was supported by the plain and ordinary meaning of "mobility." View "A.A.A. v. Dep't of Human Servs." on Justia Law

After a jury trial, Appellant was convicted of fleeing a peace officer by means other than a motor vehicle pursuant to Minn. Stat. 609.487(6) after she ran from a police officer who was responding to a stabbing at a bar. Appellant argued in a pretrial motion that she was entitled to a voluntary intoxication jury instruction because section 609.487(6) contains a specific-intent requirement. The district court denied the motion, ruling that the offense is a general-intent crime. The court of appeals affirmed. The Supreme Court affirmed but on different grounds, holding (1) section 609.487(6) contains a specific-intent requirement, and the district court erred in failing to instruct the jury on voluntary intoxication in this case; but (2) the error was harmless beyond a reasonable doubt because the omission of the voluntary intoxication jury instruction did not significantly affect the verdict. View "State v. Wilson" on Justia Law