Justia Minnesota Supreme Court Opinion Summaries
State v. Craig
After a jury trial, Appellant was convicted of possessing a firearm as an ineligible person in violation of Minn. Stat. 624.713(1)(2), which prohibits a person previously convicted of a crime of violence from possessing a firearm. After trial, Appellant unsuccessfully moved to vacate his conviction on the basis that the statute, as applied to him, violated the Second Amendment. The court of appeals upheld the statute as constitutional and affirmed Appellant's conviction. The Supreme Court affirmed, albeit on different grounds, holding that application of section 624.713(1)(2) to Appellant did not violate the Second Amendment as historically understood, because the Second Amendment as understood at the time of its ratification excluded those convicted of crimes of violence from exercising the right to possess a firearm. View "State v. Craig" on Justia Law
Hawes v. State
After a jury trial, Appellant was convicted of aiding and abetting the first-degree murder of his brother as well as obstructing an investigation. Appellant was sentenced to life in prison without the possibility for parole. Appellant subsequently filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed, holding (1) Appellant's ineffective-assistance-of-counsel claim failed because Appellant failed to show that, but for his attorneys' alleged errors, there was a reasonable probability the outcome of his trial would have been different; and (2) any error in the admission of statements made by Appellant's sister and girlfriend was harmless beyond a reasonable doubt. View "Hawes v. State" on Justia Law
Ferguson v. State
Following a jury trial, Appellant was convicted of first-degree premeditated murder and attempted first-degree premeditated murder. After Appellant's first petition for postconviction relief was denied, Appellant filed a second postconviction petition. After a hearing, the postconviction court denied Appellant's petition. Appellant appealed, contending (1) the postconviction court erred in concluding that an affidavit from a recanting witness is inadmissible hearsay, and (2) he was denied the effective assistance of counsel during the postconviction proceedings. The Supreme Court affirmed, holding (1) the postconviction court did not abuse its discretion in excluding the affidavit, as Appellant failed to establish corroborating circumstances clearly indicating the trustworthiness of Appellant's affidavit; and (2) Appellant did not have a constitutional right to effective assistance of postconviction counsel, and therefore, his ineffective-assistance-of-counsel claim failed as a matter of law. View "Ferguson v. State" on Justia Law
Green v. BMW of N. Am., LLC
Plaintiff leased a vehicle from BMW. Plaintiff claimed the leased vehicle was defective and brought suit against BMW. After a bench trial, the trial court awarded Plaintiff $25,157 in damages based on Minnesota's lemon law. The district court then granted Plaintiff's motion for an award of attorney fees and litigation costs, awarding Plaintiff a total of $229,064 in fees and costs. In reaching its conclusion on attorney fees, the court determined that it was "improper to compare the amount of reasonable legal fees to the amount of recovery in determining the proper fee award." The court of appeals affirmed. The Supreme Court reversed, holding (1) the amount involved in the litigation and the results obtained are relevant factors that the district court is to consider in awarding attorney fees under Minnesota's lemon law; and (2) the district court abused its discretion by failing to consider these factors in awarding attorney fees under the lemon law. Remanded. View "Green v. BMW of N. Am., LLC" on Justia Law
Berkovitz v. State
After a jury trial, Defendant was convicted of first-degree premeditated murder and attempted first-degree murder. Defendant was sentenced to life imprisonment. The Supreme Court affirmed Defendant's convictions on direct appeal. Defendant filed a petition for habeas corpus relief in federal district court, which was denied, and a petition for postconviction relief in state court, which was also denied. Defendant subsequently filed a second petition for postconviction relief, which the postconviction court denied after concluding that the petition was filed after the expiration of the two-year limitations period in Minn. Stat. 590.01, subd. 4(a)(2). The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the petition as untimely, as the petition satisfied neither exception to the limitations period. View "Berkovitz v. State" on Justia Law
Bradison vs. Comm’r of Revenue
In 1995, Katelyn Janson was severely injured in an automobile accident. A lawsuit ended with a settlement in which two annuities were established, both of which guaranteed payments to Katelyn starting in 2001 and established that, if Katelyn died before fifteen years expired, annuity payments would be made to her estate. Katelyn's mother and conservator, Candy Bradison, moved Katelyn to Wyoming in 2001 and to Minnesota in 2003. In 2006, Katelyn died. In 2010, Bradison sought, on behalf of Katelyn's estate, a refund of the amount the estate previously paid to the Minnesota Department of Revenue, arguing (1) the annuity payments were not includable in Katelyn's estate because Katelyn did not own the annuities; and (2) Katelyn was a Wyoming domiciliary at the time of her death. The tax court concluded (1) Katelyn was a Minnesota domiciliary at the time of her death; and (2) the annuity payments were includable in Katelyn's estate. The Supreme Court affirmed, holding (1) Katelyn's intangible property had a situs in Minnesota at the time of her death and could be taxed in accordance with Minnesota's estate tax provisions; and (2) Katelyn was the beneficial owner of the annuity payments, and the value of the payments was properly included in her estate. View "Bradison vs. Comm'r of Revenue" on Justia Law
McKee v. Laurion
After David McKee, a physician, acted in a manner Dennis Laurion considered rule and insensitive, Laurion posted critical comments about McKee on various "rate-your-doctor" websites and also sent letters to several medically-affiliated institutions complaining about McKee's conduct. McKee commenced this action against Laurion, asserting claims for defamation per se and interference with business. The district court granted summary judgment for Laurion, concluding that the individual statements were either protected opinion, substantially true, or lacked defamatory meaning. The court of appeals reversed with respect to six of the alleged defamatory statements. The Supreme Court reversed, holding that none of the six statements was actionable either because (1) there was no genuine issue of material fact as to the falsity of the statements, or (2) the statements were not capable of conveying a defamatory meaning that would harm McKee's reputation and lower him in the estimation of the community. View "McKee v. Laurion" on Justia Law
Posted in:
Injury Law, Minnesota Supreme Court
Martin v. State
After a jury trial, Appellant was convicted of aiding and abetting first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence. Appellant subsequently filed a petition for postconviction relief alleging seven claims. The postconviction court summarily denied the petition without a hearing. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the postconviction court erred in denying Appellant's request for an evidentiary hearing on his claim of witness recantation; but (2) the postconviction court did not err in finding Appellant's ineffective-assistance-of-counsel claim to be without merit and in concluding that Appellant's remaining claims were barred by State v. Knaffla. View "Martin v. State" on Justia Law
Beaulieu v. Dep’t of Human Servs.
Appellant, an enrolled member of the Leech Lake Band of Ojibwe, was civilly committed to the Minnesota Sex Offender Program (MSOP). Appellant appealed, challenging his indeterminate civil commitment by asserting three substantive claims. The Supreme Court affirmed, holding (1) the district court had jurisdiction to indeterminately civilly commit an enrolled member of the Leech Lake Band of Ojibwe; (2) the doctrines of collateral estoppel and res judicata did not preclude the State from presenting in the civil commitment proceeding evidence of conduct alleged in earlier criminal cases that ended in acquittals; and (3) Appellant waived his to right appellate review of his claim that the State violated the Minnesota Constitution when it committed him without a trial by jury. View "Beaulieu v. Dep't of Human Servs." on Justia Law
State v. McDonald-Richards
Appellant was convicted of aiding and abetting first-degree murder and aiding and abetting attempted first-degree murder. Appellant appealed, arguing that the district court committed reversible error in admitting a statement she made to police as the fruit of an unlawful arrest in violation of the Fourth Amendment. The Supreme Court affirmed, holding (1) the trial court erred in admitting Appellant's statement to police because the taint of Appellant's unlawful arrest was not purged at the time Appellant made her statement, and therefore, the statement was inadmissible; but (2) the trial court's error in admitting this statement was harmless beyond a reasonable doubt. View "State v. McDonald-Richards" on Justia Law