Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree felony murder, second-degree intentional murder, and being a prohibited person in possession of a firearm for the shooting death of a cab driver. The district court sentenced Defendant to life imprisonment on the first-degree felony murder conviction and to a sixty-month concurrent sentence on the firearm conviction but did not sentence Defendant on the second-degree intentional murder conviction. The Supreme Court vacated Defendant's second-degree intentional murder conviction but otherwise affirmed Defendant's convictions, holding (1) the district court did not err when it declined Defendant's request for a jury instruction on accomplice testimony; (2) the district court did not abuse its discretion when it instructed the jury to continue deliberating after the jury indicated it was deadlocked; and (3) the district court erred by convicting Defendant of both first- and second-degree murder because second-degree intentional murder is a lesser-included offense of first-degree murder. View "State v. Cox " on Justia Law

Appellant was convicted of aiding and abetting first-degree felony murder. The district court sentenced Appellant to life in prison. On appeal, Appellant claimed that numerous errors entitled him to a new trial. The Supreme Court affirmed Appellant's conviction, holding (1) the jury's verdict was unattributable to any error in admitting Appellant's statement recorded after he allegedly invoked his right to remain silent, and therefore, the admission of the statement into evidence was harmless; (2) the district court did not plainly err by allowing fear testimony at trial; (3) the district court did not abuse its discretion by not admitting certain hearsay statements; (4) the district court did not plainly err by giving a no-adverse-inerence jury instruction without Appellant's clear consent; and (5) Appellant was not entitled to a new trial based on the cumulative effect of the district court's errors. View "State v. Davis" on Justia Law

Six banks (the Banks) alleged that the negligent misrepresentation of Respondent, James H. Bedard, Inc., caused them to be damaged when the Housing and Redevelopment Authority of the City of Brainerd defaulted on bonds held by the Banks. Specifically, the Banks purchased $3.3 million in bonds from the City, which helped finance a development project in the City. In deciding to purchase the bonds, the Banks relied on an appraisal and feasibility study prepared by Bedard. The Banks filed a negligent misrepresentation claim against Bedard, alleging that Bedard's study overstated the value of the project and the rate at which the land would sell. The district court dismissed the action, concluding that the Banks failed to plead their negligent misrepresentation claim against Bedard with particularity. The court of appeals affirmed. The Supreme Court reversed, holding that because the Banks specifically pleaded facts underlying each of the elements of their negligent misrepresentation claim, the Banks pleaded the "ultimate facts" of their claim and thus satisfied the particularity requirement under Minn. R. Civ. P. 9.02. Remanded. View "Hardin County Savings Bank v. City of Brainerd Hous. & Redevelopment Auth." on Justia Law

The county assessor determined that the fair market value of a tax parcel, which was improved by a department store operated by respondent Federated Retail Holdings, Inc., was $17,000,000 for the year 2006. The assessor included the value of a leasehold interest held by Federated in the parcel adjacent to the tax parcel in its value determination. Federated timely filed petitions challenging the assessor's market value determinations. The tax court held that Federated's ownership interest in the tax parcel included the leasehold interest in the adjacent property, but concluded that the value of the leasehold interest was not subject to the jurisdiction of the tax court and therefore did not include it. The county appealed. The Supreme Court reversed, holding that the tax court had subject-matter jurisdiction to consider the value of Federated's leasehold interest in adjacent property because it constituted real property of the tax parcel under Minn. Stat. 272.03, 1 and affected the fair market value of the tax parcel. View "Federated Retail Holdings, Inc. v. County of Ramsey " on Justia Law

Appellant was arrested and charged with first-degree premeditated murder. At trial, Appellant admitted shooting the victim, but claimed he did so in self-defense and without premeditation. The jury, rejecting Appellant's self-defense claim, found Appellant guilty of first-degree premeditated murder, and the district court sentenced Appellant to life in prison without the possibility of release. Appellant thereafter filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed Appellant's conviction and the postconviction court's denial of postconviction relief, holding that each of Appellant's claims was either without merit or did not result in prejudice to Appellant. View "State v. Radke" on Justia Law

In this subrogation action, appellant Insurer sought to recover payments it made to its Insured for the repair of water damage allegedly caused by the negligence of respondent, the commercial tenant of Insured. The district court dismissed Insurer's subrogation claim as a matter of law, relying on the court of appeals decision in United Fire & Casualty Co. v. Bruggeman. The court of appeals affirmed. The Supreme Court reversed after rejecting the rule from Bruggeman, holding that the question of whether an insurer may pursue a subrogation action against the tenant of an insured, when the tenant's negligence caused damage to the insured's property, must be answered by examining the unique facts and circumstances of each case. Remanded. View "RAM Mut. Ins. Co. v. Rusty Rohde" on Justia Law

At issue in this case was whether the workers' compensation courts had the authority to hear a petition filed by Insured to determine whether Insurer had a duty to defend and indemnify Insured under a policy for workers' compensation insurance. Insurer moved to dismiss Insured's petition, arguing that the compensation judge did not have subject matter jurisdiction to hear the petition because it asserted a breach of contract claim rather than one arising under the workers' compensation laws. The compensation judge disagreed and denied Insurer's motion to dismiss. The workers' compensation court of appeals (WCCA) affirmed, concluding that Insured was seeking a declaration that its insurance coverage with Insurer was still "in effect," a question within the compensation judge's authority to decide. The Supreme Court affirmed, holding that the workers' compensation courts had jurisdiction to decide the issues presented in Insured's petition for declaration of insurance coverage, as the real nature of the claim was whether Insured's insurance coverage was in effect, a question that was within the authority of the compensation judge to answer. View "Giersdorf v. A & M Constr., Inc." on Justia Law

In these two cases, Petitioners, members of the Minnesota Legislature and others, filed petitions pursuant to Minn. Stat. 204B.44 seeking an order requiring Mark Ritchie, the Minnesota Secretary of State, to use the titles designated by the Minnesota Legislature for two proposed constitutional amendment ballot questions that were scheduled to appear on the November 2012 general election ballot. Petitioners contended that by failing to use the title designated by the Legislature for each ballot question, Respondents failed to comply with the statutory requirement to "provide an appropriate title" for the ballot question. The Supreme Court granted the petitions, holding that when the Legislature has included a title for a ballot question in the bill proposing a constitutional amendment, the "appropriate title" the Secretary of State must provide for that ballot question is the title designated by the Legislature. View "Limmer v. Ritchie" on Justia Law

This action was brought under Minn. Stat. 204B.44 seeking to correct an alleged error in the preparation of the ballot for the general election. Specifically, Petitioners sought to prevent the people of Minnesota from voting on the question of whether photographic identification should be required to vote in Minnesota. Without expressing an opinion as to the merits of changing Minnesota law to require photographic identification to vote, the Supreme Court concluded that Petitioners were not entitled to relief, holding that Petitioners did not meet their burden of demonstrating that there was an error that required the judiciary to intercede. View "League of Women Voters Minn. v. Ritchie" on Justia Law

A compensation judge found Respondent was barred from receiving workers' compensation benefits because his written notice of injury, given nearly two years after his last day of work, was not timely and because Respondent's employer did not have actual knowledge that Respondent's back problems were work-related. The workers' compensation court of appeals (WCCA) reversed, concluding that a reasonable person in Respondent's position would not have known his injury was compensable until Respondent's doctors provided written reports to Respondent's attorney establishing a relationship between Respondent's back problems and his job duties. The Supreme Court reversed the WCCA and affirmed the denial of benefits, holding (1) the WCCA erred in overturning the compensation judge's finding that Respondent failed to give timely notice to his employer of his work-related injury; and (2) the compensation judge did not err in finding that the employer did not have actual knowledge of such an injury. View "Anderson v. Frontier Commc'ns" on Justia Law