Justia Minnesota Supreme Court Opinion Summaries

John Doe 76C (Doe) claimed the Archdiocese of St. Paul and Minneapolis and the Diocese of Winona (Dioceses) were liable for his damages resulting from alleged sexual abuse in the early 1980s by a priest under the Dioceses' control. Doe's claims were subject to six-year statutes of limitations. To support his argument that accrual of his claims was delayed and that his action was timely, Doe intended to offer general expert testimony on the theory of repressed and recovered memory. The district court concluded that Doe's expert testimony was inadmissible under the Frye-Mack standard, making his claims untimely, and granted the Dioceses summary judgment. The court of appeals reversed, concluding that Doe's expert testimony might be admissible under Minn. R. Evid. 702. The Supreme Court reversed, holding that Doe's expert testimony on the theory of repressed and recovered memory, offered to prove a disability delaying the accrual of a cause of action, was inadmissible under Rule 702 because it lacked foundational reliability and, as a result, Doe's claims were untimely. View "John Doe 76C v. Archdiocese of St. Paul & Minneapolis" on Justia Law

In 2008, Stearns County changed the tax classification of property co-owned by Respondent from residential nonhomestead to commercial. Respondent filed a petition under Minn. Stat. 278.01, claiming the property was misclassified, unequally assessed, and undervalued. The tax court dismissed the petition as untimely. Respondent did not appeal from the tax court's dismissal of its petition and instead filed a verified claim under Minn. Stat. 278.14 for a refund of taxes paid in 2009, claiming the property was misclassified for taxes payable in 2009. The County denied the refund claim. The tax court denied the County's motion to dismiss the section 278.14 appeal (Matter A11-1479). In the meantime, Respondent filed a timely petition under Minn. Stat. 278.01 with respect to property taxes assessed in 2009. The tax court ruled the property was properly classified as residential nonhomestead, its original classification (Matter A11-1480). The County petitioned for writ of certiorari in both matters. The Supreme Court dismissed the writs of certiorari, concluding that it lacked jurisdiction in each case. View "Beuning Family LP v. County of Stearns" on Justia Law

Defendant was convicted, after a stipulated facts bench trial, of first-degree possession of a controlled substance. More than five years after his conviction became final, Defendant filed a petition for postconviction relief. The postconviction court denied Defendant's petition as untimely and meritless. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Appellant's petition was untimely under Minn. Stat. 590.01, 4(c), which requires that a claim is brought within two years from the time the claimant knew or should have known that the claim existed; and (2) section 590.01, subdivision 4 was not unconstitutional as a violation of the separation of powers doctrine where the legislature did not intrude unto a judicial function when it enacted the time limitations provisions in the postconviction statute. View "Sanchez v. State" on Justia Law

Appellant Alexander Miller pleaded guilty to intentional second-degree murder of Crystal Lindorff by an Alford plea on March 11, 2005. Appellant's conviction was not reviewed on direct appeal. On May 11, 2009, Appellant filed this petition for postconviction relief. The postconviction court denied Appellant's petition, concluding that it was untimely and meritless. The court of appeals affirmed. The Supreme Court affirmed, holding that the postconviction court properly dismissed Appellant's postconviction petition, as (1) because Appellant filed the petition over two years after his claim arose, the petition was untimely; and (2) the time limits were constitutionally applied to Appellant's petition. View "Miller v. State" on Justia Law

This case required the Supreme Court to decide whether an airplane manufacturer owed a duty to a noncommercial pilot who, after purchasing an airplane from the manufacturer but failing to receive all of the flight training promised to him as part of that purchase, died when his airplane crashed. The district court found the manufacturer was negligent. The court of appeals reversed, concluding that the manufacturer did not have a duty to provide training and that the claims were barred by the educational malpractice doctrine. The Supreme Court affirmed, holding (1) the manufacturer did not owe a duty to the pilot, and thus the district court erred in its judgment; and (2) accordingly, the Court did not reach, among other things, the issues of educational malpractice or causation. View "Glorvigen v. Cirrus Design Corp." on Justia Law

Appellant was convicted of first-degree premeditated murder and first-degree murder while committing criminal sexual conduct. Appellant filed a notice of direct appeal, which the Supreme Court stayed pending postconviction proceedings in the district court. Appellant neither filed a petition for postconviction relief nor followed through with his direct appeal, and the Court dismissed his appeal. In this case, Appellant appealed the denial of his first petition for postconviction relief. The Supreme Court affirmed, holding (1) the postconviction court properly denied Appellant's petition as untimely under Minn. Stat. 590.01, 4(a); and (2) the time limit in section 590.01, 4(a) was constitutional as applied to Appellant, because even if the Due Process Clause of the Minnesota Constitution provided Appellant a right to one review, the two-year time limitation in subdivision 4(a) was a reasonable limitation on the alleged right. View "Carlton v. State" on Justia Law

This case required the Supreme Court to interpret the Minnesota dog owner's liability statute. Respondent Gordon Anderson was injured during an attack on his dog by another dog named Bruno, owned by Respondent Neil Christopherson. Anderson, along with his wife, sued Christopherson and his father, arguing, among other claims, that the Christophersons were strictly liable for Anderson's injuries under Minn. Stat. 347.22. The district court granted partial summary judgment to the Christophersons, holding (1) the Christophersons were not liable under the statute because Bruno's conduct was not focused on Anderson; and (2) Dennis Christopherson was not liable because he was not an "owner" of Bruno, as that term was defined under the statute. The court of appeals reversed, holding (1) a dog owner may be held strictly liable for injuries caused by a dog's affirmative conduct regardless of the focus of that conduct; and (2) there were genuine issues of material fact as to whether Anderson's injury was a direct and immediate result of Bruno's conduct and whether Dennis Christopherson was an owner of Bruno under the statute. The Supreme Court affirmed and remanded for a jury trial on both the question of whether Anderson's injuries were caused by Bruno's conduct under section 347.22 and also the question of whether Dennis Christopherson was an "owner" of Bruno under the statute. View "Anderson v. Christopherson" on Justia Law

Respondent Christian Ndikum was charged with possession of a pistol in public after he carried a briefcase containing a gun into a courthouse. At trial, Respondent requested that the district court instruct the jury that knowledge of possession is an element of the crime of possession of a pistol in public that the State must prove. The district court refused to so instruct the jury, and the jury found Respondent guilty as charged. The court of appeals reversed, concluding that the State had to prove knowledge of possession of a pistol as an element of the crime of possession of a pistol. The Supreme Court affirmed, holding (1) the State was required to prove that Respondent knew he possessed the pistol at issue; and (2) the district court abused its discretion by failing to so instruct the jury. View "State v. Ndikum" on Justia Law

After a grand jury indicted Defendant on two counts of first-degree premeditated murder, two counts of first-degree felony murder, and two counts of second-degree murder, the district court convicted Defendant on both counts of first-degree premeditated murder. Defendant challenged his convictions on four grounds. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's motion for dismissal of the indictment; (2) the record contained sufficient evidence to support the district court's verdict that Defendant was guilty of first-degree premeditated murder rather than heat-of-passion manslaughter; (3) the prosecutor's alleged misconduct during witness questioning did not affect Defendant's substantial rights under the plain-error test; and (4) the allegedly erroneous admission of a witness's out-of-court statement did not substantially influence the district court's verdict, and therefore, Defendant was not entitled to a new trial. View "State v. Hohenwald" on Justia Law

Jerrell Brown was convicted of aiding and abetting first-degree murder for the benefit of a gang in connection with a shooting death. On appeal, Brown (1) challenged his conviction, claiming that the trial court violated his right to a public trial and erred in its evidentiary rulings and jury instructions, and (2) claimed the prosecutor violated his right to a fair trial by failing to disclose impeachment evidence. The Supreme Court affirmed Brown's conviction, holding (1) because the facts of this case did not implicate the right to a public trial, the trial court did not err in its evidentiary rulings or its jury instructions; and (2) the undisclosed impeachment evidence was not material. View "State v. Brown" on Justia Law