Justia Minnesota Supreme Court Opinion Summaries

Nicole Beecroft was found guilty of first-degree premeditated murder for the stabbing death of her newborn baby. The key factual issue at trial was whether Beecroft's baby was alive or dead when stabbed by Beecroft. Each party presented testimony on this issue from medical examiners and other forensic pathologists, but certain state officials interfered with Beecroft's forensic experts. Beecroft subsequently filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court reversed Beecroft's conviction, holding (1) the interference by the state officials undermined the integrity of the judicial system in this case; (2) the trial errors alleged by Beecroft did not in and of themselves warrant a reversal and the grant of a new trial; but (3) when the existence of alleged errors is combined with the improper conduct of state officials, a reversal is warranted in the interests of justice. Remanded for a new trial. View "State v. Beecroft" on Justia Law

At issue in this appeal was how to calculate an offender's criminal history score when the court permissively imposes a felony sentence consecutive to a gross misdemeanor sentence. Respondent Tito Campbell was convicted of six offenses, including gross misdemeanor criminal vehicular operation resulting in bodily harm and felony fleeing a police officer resulting in death. The district court imposed a twelve-month sentence for the gross misdemeanor and a consecutive 234-month sentence for the felony fleeing offense, using a criminal history score of three. The court of appeals reversed Campbell's sentence, concluding that zero criminal history points should have been used to calculate the duration of the felony sentence. The Supreme Court reversed the court of appeals and reinstated the district court's sentence, holding that the district court's calculation of Campbell's sentence was correct. View "State v. Campbell" on Justia Law

Appellant Carol LaMont filed suit against her employer, a school district, for violations of the Minnesota Human Rights Act (MHRA). Appellant claimed that she had been subjected to a hostile work environment based on her sex and that she had suffered sexual harassment. The district court granted summary judgment to the school district on both claims, concluding that a hostile work environment based on sex was not actionable, and even if it were, Appellant had not established that the conduct of the school district's employees was sufficiently severe or pervasive. The court of appeals affirmed. The Supreme Court affirmed but under different grounds, holding (1) a cause of action for a hostile work environment based on sex is actionable under the MHRA; but (2) Appellant's allegations were insufficient to state a claim of hostile work environment. View "LaMont v. Independent School District #728" on Justia Law

Relator 78th Street OwnerCo, LLC, the owner and landlord of a hotel, filed petitions contesting Hennepin County's assessments of its property for property taxes payable in 2008 and 2009, along with the taxes due in 2008 and 2009. The tax court dismissed both petitions for failure to comply with the statutory sixty-day rule, which states that failure to submit required documentation within sixty days results in automatic dismissal of the petition, because each petition did not include a copy of 78th Street's lease and a calculation of percentage rent paid, and the 2008 petition did not include a rent roll/tenant list. The Supreme Court affirmed, holding (1) 78th Street's argument that the information it did not submit was not relevant to the calculation of property tax for its hotel property was unavailing because a taxpayer is not permitted to evaluate relevancy under the sixty-day rule, and neither the relevancy standard nor the unavailability exception excuses a taxpayer from providing required information that is available to the taxpayer; and (2) neither version of the sixty-day rule was unconstitutionally vague as applied to 78th Street. View "78th St. OwnerCo, LLC v. County of Hennepin" on Justia Law

After a jury trial, Chaun Carridine was convicted of first-degree premeditated murder and sentenced to life in prison. The Supreme Court affirmed, holding (1) the district court did not err by rejecting Carridine's challenges to the State's exercise of two peremptory strikes; (2) any error by the district court in allowing the State to impeach Carridine through his prior statement did not substantially influence the jury's verdict, and therefore, the error, if any, was not prejudicial; (3) the district court did abuse its discretion in instructing the jury; (4) in the instances where there was or may have been prosecutorial misconduct, the misconduct was either harmless or did not affect Carridine's substantial rights, and therefore, the objected-to prosecutorial misconduct was harmless. View "State v. Carridine" on Justia Law

At issue in this case was how to calculate an offender's criminal history score when the court permissively imposes a felony sentence consecutive to a gross misdemeanor sentence. Respondent Tito Campbell was convicted of six offenses, including gross misdemeanor criminal vehicular operation resulting in bodily harm and felony fleeing a police officer resulting in death. The district court imposed a twelve-month sentence for the gross misdemeanor and a consecutive 234-month sentence for the felony fleeing offense, using a criminal history score of three. The court of appeals reversed Campbell's sentence, concluding that zero criminal history points should have been used to calculate the duration of the felony sentence. The Supreme Court reversed and reinstated the district court's sentence, holding that the district court did not err in assigning its criminal history points to Campbell during sentencing. View "State v. Campbell" on Justia Law

Relator Minh Nguyen was injured after falling from a ladder while employed by Audio Communications. Nguyen filed an amended petition to seek benefits for permanent total disability, but his petition did not seek to establish the date of onset of permanent disability. After a compensation judge awarded Nguyen benefits from March 4, 2008, for permanent total disability, Audio Communications petitioned the compensation judge for determination of the date of onset. The judge found that Nguyen became permanently and totally disabled as of March 1, 2007. Nguyen then petitioned to require Audio Communications to pay the attorney fees he incurred in partially succeeding in opposing Audio Communications' petition for determination of the date of onset of permanent total disability. The compensation judge denied the claim for attorney fees, and the WCCA affirmed. The Supreme Court affirmed, holding that an employer is not liable for the attorney fees incurred by an injured employee in successfully defending against the employer's petition to offset social security disability benefits paid to the employee against benefits paid by the employer for permanent total disability, where the employee's attorney fees can be paid from ongoing workers' compensation benefits paid to the employee. View "Nguyen v. Audio Commc'ns" on Justia Law

This case arose out of dispute between two counties over which county was the "county of financial responsibility" for the out-of-home placement costs incurred after October 1, 2008, for a minor child named S.M. The Minnesota Department of Human Services (MDHS) held that Nobles County was responsible for S.M.'s costs. The district court reversed, concluding that the legislative history of Minn. Stat. 256G.10 indicated the legislature intended the county of financial responsibility to be the county where the child last resided with a parent, and therefore, Brown County was the county of financial responsibility. The court of appeals affirmed. The Supreme Court reversed, holding (1) the language of section 256G.10 was unambiguous and, by its plain language, the county of financial responsibility was the county of the residence of the parent with whom the child last lived, determined at the time the child entered excluded time status; (2) the county of financial responsibility in this case was the county in which S.M.'s mother resided on May 16, 2008, the date S.M. entered excluded time status; and (3) therefore, Nobles County was the county of financial responsibility for S.M.'s out-of-home placement costs for services provided on and after October 1, 2008. View "In re S.M." on Justia Law

This case involved two mechanic's liens foreclosed against a hotel property. An agent of the lien claimants personally served mechanic's liens statements on the property owner. Appellant, a community bank, challenged the validity of this service. Appellant argued that a lien claimant may not personally serve a mechanic's lien statement, and therefore, service was improper. As a result, Appellant contended that the mechanic's liens were invalid and could not be foreclosed. The district court determined that service was proper and entered judgment in favor of the lien claimants. The court of appeals affirmed. The Supreme Court affirmed, holding that a lien claimant may personally serve a mechanic's lien statement, and therefore, service of the mechanic's lien statements in this case was proper. View "Eclipse Architectural Group, Inc. v. Lam" on Justia Law

A collision at a railroad crossing between a vehicle and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. The representatives of the decedents' estates brought separate wrongful death claims against BNSF. During trial, the district court instructed the jury, without objection from BNSF, to apply a common-law or "reasonable person" standard of care. The jury returned a verdict in appellants' favor. BNSF moved for a new trial, contending that the trial court erred by not applying the standard of care established by applicable federal regulations. The court of appeals concluded that the jury instruction and special verdict form using a common-law duty of care constituted plain error that substantially affected BNSF's rights and the fairness and integrity of the proceedings and remanded the matter. The Supreme Court reversed, holding that any error in the instructions and verdict form did not affect the fairness and integrity of the proceedings. View "Frazier v. Burlington N. Santa Fe Corp." on Justia Law