Justia Minnesota Supreme Court Opinion Summaries

The State charged Michael Sahr with first-degree criminal sexual contact. Defense counsel moved to dismiss the complaint, arguing that the facts, as alleged in the complaint, were insufficient to support the charged offense. The trial court dismissed the complaint. The State subsequently moved to file a new complaint charging Sahr with second-degree criminal conduct. The trial court denied the State's motion on the basis that filing a new complaint charging second-degree criminal sexual conduct would violate double jeopardy. The court of appeals remanded to the trial court for further proceedings. On remand, the trial court concluded (1) the offense set out in the proposed amended complaint was the "same offense" the court had dismissed in the original complaint and that jeopardy had attached before the complaint was dismissed; and (2) therefore, the signing of the proposed amended complaint would violate double jeopardy. The court of appeals reversed. The Supreme Court reversed the court of appeals, holding (1) the trial court's dismissal of the original complaint constituted an acquittal on the merits; and (2) Sahr's double jeopardy protections precluded the State from filing a new complaint charging Sahr with second-degree criminal sexual conduct and trying him on that offense. View "State v. Sahr" on Justia Law

Appellant Adrian Patterson and his codefendant Leroy Paul were indicted for first-degree murder and attempted first-degree murder. Patterson was scheduled to be tried in a joint trial with Paul. For his defense, Patterson retained Eric Newmark as his counsel of choice. The State moved to disqualify Newmark as Patterson's counsel based on alleged actual and potential conflicts of interest arising out of Newmark's past representation of Paul and three of the State's prospective witnesses. Even though Patterson waived his right to conflict-free counsel with respect to Newmark, the trial court granted the motion on the basis of potential conflicts with two of the State's prospective witnesses. After retaining another attorney and, following a jury trial, Patterson was found guilty and convicted of second-degree murder while committing a drive-by shooting and drive-by shooting. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in disqualifying Newmark as Patterson's counsel. View "State v. Patterson" on Justia Law

Appellant Robert Hughes was convicted of first-degree premeditated murder for the shooting death of his wife. The trial court sentenced Hughes to life imprisonment and ordered him to pay restitution to the Crime Victims Reparations board. The Supreme Court affirmed. Hughes subsequently filed a petition for postconviction relief raising eighteen claims. The two most significant claims were (1) the restitution order was improper, and (2) the Confrontation Clause was violated by the introduction at trial of statements made by Hughes's wife. The postconviction court denied Hughes's petition without a hearing. The Supreme Court affirmed, holding (1) because Hughes's wife's statements to her divorce attorney and police were nontestimonial, the trial court did not violate Hughes's Confrontation Clause rights when it admitted the statements at trial; and (2) all of Hughes's other claims were procedurally barred because they were or could have been raised on direct appeal. View "Hughes v. State" on Justia Law

Christopher Daly sued Zachary McFarland for injuries sustained from an accident. The jury returned a special verdict form finding that both Daly and McFarland were negligent, but that Daly's negligence was not a direct cause of the accident. The jury then allocated thirty percent of the fault for the accident to Daly. The district court entered judgment for Daly in the amount of $442,633, the full amount of damages that the jury found Daly to have suffered. McFarland moved for judgment as a matter of law, arguing that the court improperly reconciled the jury's special verdict form answers, and that McFarland was not negligent as a matter of law. In the alternative, McFarland moved for a new trial. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court abused its discretion in reconciling the special verdict form; and (2) because the jury found McFarland to be at least seventy percent causally negligent for the accident, the case was remanded with directions to enter a remittitur awarding Daly $309,843, and if Daly rejected the remittitur, to grant a new trial on liability issues. View "Daly v. McFarland" on Justia Law

Following a jury trial, Appellant Danny Ortega was convicted of aiding and abetting first-degree premeditated murder. The Supreme Court affirmed Ortega's conviction, holding (1) the district court did not err in denying Ortega's motion to suppress his statements to investigators because, after requesting counsel, Ortega reinitiated the discussion with investigators and then validly waived his right to counsel; (2) the district court did not abuse its discretion when it allowed the prosecutor to ask prospective jurors whether they believed there was anything more valuable than human life, as any error in the prosecutor's questioning of jurors during voir dire was harmless; and (3) the evidence was sufficient to convict Ortega of premeditated murder. View "State v. Ortega" on Justia Law

Appellant Jabaris Curt Boldman was found guilty by a jury of first-degree felony murder and second-degree intentional murder. The district court entered judgment of conviction for first-degree felony murder and imposed a life sentence. The Supreme Court vacated Appellant's conviction for first-degree felony murder, holding (1) the evidence was not sufficient to support the first-degree felony murder conviction but was sufficient to support a second-degree murder conviction; and (2) any alleged discovery violation on the part of the State was harmless. Remanded to the district court to enter a judgment of conviction and impose sentence on the second-degree murder charge. View "State v. Boldman" on Justia Law

Plaintiff Alice Ann Staab brought suit against Defendant Diocese of St. Cloud for injuries she sustained on premises Defendant owned and operated. A special jury verdict attributed fifty percent of the negligence to the sole defendant and fifty percent of the negligence to a nonparty to the lawsuit. The district court ruled that Minn. Stat. 604.02, subd. 1 does not apply in an action against only one defendant and ordered Defendant to pay the entire damages award. The court of appeals reversed, holding that under the plain language of section 604.02, subdivision 1, Defendant must pay only in proportion to the percentage of fault attributed to Defendant by the jury. The Supreme Court affirmed but under a different analysis, holding (1) section 604.02, subdivision 1, applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor and limits the amount collectible from the defendant to its percentage share of the fault assigned to it by the jury; and (2) consequently, Defendant must pay Plaintiff fifty percent of the jury award, Defendant's share of the fault as determined by the jury. View "Staab v. Diocese of St. Cloud" on Justia Law

Employee was injured in a work-related accident in Minnesota and then moved to Wyoming where she received medical treatment. The Wyoming medical providers submitted their charges to Employer's workers' compensation insurer. Relying on Minn. Stat. 176.136, subd. 1b(d), the insurer made payments in the amount provided under the workers' compensation benefit structure in Wyoming. Employee filed a workers' compensation medical request for the unpaid balance, arguing that Minn. Stat. 176.135, subd. 1 was controlling. The workers' compensation judge agreed and found for Employee. The workers' compensation court of appeals reversed. The Supreme Court affirmed, holding (1) Minn. Stat. 176.136, subd. 1b(d) limits a Minnesota employer's workers' compensation liability to an out-of-state medical provider to the amounts provided in the workers' compensation schedule of benefits in the state where the provider is located; and (2) section 16.136, subd. 1b(d) was not unconstitutional as applied. View "Schatz v. Interfaith Care Ctr." on Justia Law

Peter Lonergan and Robert Kunshier were both indeterminately civilly committed to the Minnesota sex offender program. Lonergan and Kunshier each sought relief from his commitment by filing a pro se motion under Minn. R. Civ. P. 60.02. After the district court denied the motions, both Lonergan and Kunshier appealed. The court of appeals affirmed the denial of Lonergan's motion, holding that as a sexually dangerous person, Lonergan could not use Rule 60.02 to seek a discharge from his indeterminate commitment or to make a constitutional challenge to the adequacy of his treatment at the sex offender program. The court also affirmed the denial of Kunshier's motion, concluding that Rule 60.02 may not be used to seek any relief from an indeterminate civil commitment order. The Supreme Court reversed in part, holding (1) the court of appeals erred in Kunshier's case when it articulated a blanket prohibition on use of Rule 60.02 motions by patients indeterminately committed as sexually dangerous persons or sexual psychopathic personalities; and (2) Lonergan's claims warranted reconsideration in light of this decision. Remanded. View "In re Lonergan" on Justia Law

The Rochester International Joint Zoning Board enacted a zoning ordinance that increased the size of a runway safety zone and changed the restrictions within the safety zone to allow fewer types of uses of land within the zone. The safety zone extended over property owned by Leon and Judith DeCook. The DeCooks brought an inverse condemnation action, alleging that the Board's decision constituted a taking for which the DeCooks were entitled to compensation. The district court first concluded there was no taking, and upon remand, again concluded that the Board's actions did not constitute a taking. The DeCooks appealed another time, and the Supreme Court ultimately held the ordinance constituted a taking of the DeCooks' property. The DeCooks subsequently moved for an award of attorney fees incurred during the appeals. The Supreme Court granted the motion, as the Cooks prevailed and were entitled under Minn. Stat. 117.045 to an award of reasonable costs and expenses, including attorney fees, incurred on appeal. View "DeCook v. Rochester Int'l Airport Joint Zoning Bd." on Justia Law