Justia Minnesota Supreme Court Opinion Summaries

Petitioner, the Commissioner of the Minnesota Department of Management and Budget, sought validation of certain tobacco appropriation bonds to be issued to refund, in advance of maturity, outstanding tobacco securitization bonds issued in 2011. The only disputed issue in this proceeding was whether the proposed tobacco appropriation bonds were constitutional under the Minnesota Constitution. The Commissioner argued that the bonds did not implicate Minnesota's constitutional limitations on incurring public debt. The attorney general argued that the bonds constituted a "subterfuge to evade the balanced budget requirement" of the Minnesota Constitution. The Supreme Court concluded (1) the proposed tobacco appropriation bonds did not constitute public debt for which the state's full faith, credit, and taxing powers have been pledged under the plain language of Minn. Const. art. XI, 4; and (2) therefore, the restrictions imposed by Minn. Const. art. XI, 5 do not apply to the bonds. View "Schowalter v. State" on Justia Law

A jury found Appellant guilty of first-degree premeditated murder and second-degree intentional murder. The Supreme Court affirmed, holding that the district court did not err in (1) denying Appellant's motion to suppress his statement to police, as Appellant was not in custody or under arrest when the statement was made; (2) refusing to instruct the jury that Appellant's girlfriend, H.J., was an accomplice as a matter of law, as the issue of whether H.J. was an accomplice was a fact question for the jury; (3) failing to instruct the jury on the aiding-and-advising theory of accomplice liability; and (4) admitting evidence of Appellant's prior assaults of H.J. View "State v. Scruggs" on Justia Law

Appellant was charged with first- and third-degree on the ground that Appellant injured a young child in his care. A jury found Appellant not guilty of both charges, and the district court entered a judgment of acquittal. Appellant then petitioned the district court for an order sealing the criminal records related to the alleged assault. The district court granted Appellant's petition, concluding that the State failed to prove by clear and convincing evidence that the public's interests outweighed Appellant's interests pursuant to Minnesota's expungement statute. The court of appeals reversed, finding that Appellant proved no specific disadvantage to himself against which to balance the interests of the public. The Supreme Court reversed the decision of the court of appeals, holding that an expungement petitioner is not required to prove specific disadvantages he or she will suffer if the petition is denied and may instead satisfy his or her burden of production simply by establishing the fact of his or her acquittal. View "State v. R.H.B." on Justia Law

At issue in this dispute over a mortgage was whether statutes of limitations apply to actions for declaratory judgment. The court of appeals reversed in part the district court's grant of summary judgment to Defendant based on the applicable statute of limitations, holding that to the extent Plaintiff's complaint sought declaratory relief, it was not barred by the statute of limitations. The Supreme Court reversed, holding that because the Uniform Declaratory Judgments Act is a procedural device through which parties may vindicate substantive legal rights, an action for declaratory judgment is barred by an applicable statute of limitations to the same extent that the same cause of action would be barred in a nondeclaratory proceeding. Remanded. View "Weavewood, Inc. v. S & P Home Invs., LLC" on Justia Law

Appellant pled guilty to first-degree murder while committing domestic abuse and was sentenced to life imprisonment with the possibility of parole. Defendant did not appeal but subsequently filed a postconviction petition, alleging that his guilty plea was invalid because it lacked a proper factual foundation. The postconviction court denied relief on the ground that the petition was untimely and lacked substantive merit. The Supreme Court affirmed, holding (1) because there was sufficient evidence of a past pattern of domestic abuse and sufficient evidence of an extreme indifference to human life, Appellant's claim that he was entitled to withdraw his plea failed on the merits, and therefore, Appellant failed to establish a manifest injustice entitling him to withdraw his guilty plea; and (2) therefore, the Court did not need to reach the remaining issues raised in this appeal. View "Lussier v. State" on Justia Law

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