Justia Minnesota Supreme Court Opinion Summaries

A collision between an automobile and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. Plaintiffs, the representatives of the decedents' estates, brought wrongful death claims against BNSF, alleging negligence in the maintenance of warning signals and failure to comply with several state and federal regulations. 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 Plaintiffs' favor. A divided court of appeals reversed and remanded the matter for a new trial, concluding that the district court's 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. The Supreme Court (1) reversed the court of appeals' grant of a new trial on the ground of error in the instructions and verdict form, holding that any error did not affect the fairness and integrity of the proceedings; and (2) affirmed the district court's denial of BNSF's motion for a new trial. View "Frazier v. Burlington N. Santa Fe Corp." on Justia Law

After a jury trial, Appellant Daniel Anderson was convicted of first-degree murder for the death of his girlfriend's nineteen-month-old son. Anderson filed a petition for postconviction relief, arguing that it was error for the State to indict him under the domestic abuse murder statute and that he should have been indicted under what he claimed to be the more specific child abuse murder statute. The postconviction court denied relief without a hearing, reasoning that the claim was Knaffla-barred and that no exception to Knaffla applied. Under State v. Knaffla, a postconviction relief petition raising claims that were raised on direct appeal or that were known or should have been known but were not raised by the petition at the time of direct appeal is procedurally barred. The Supreme Court affirmed, holding that the postconviction court properly concluded that Anderson's claim was Knaffla-barred and that Anderson's petition was not saved by either exception to the Knaffla bar, as his claim was not novel and the interests of fairness and justice did not warrant consideration of his claim. View "Anderson v. State" on Justia Law

The property at issue in this case was the interest of Respondent, the judgment debtor, in a spendthrift trust. The district court issued a temporary injunction prohibiting Respondent from disposing of any money or property he had received, was due to receive, or will receive from the trust. The court of appeals reversed. The Supreme Court affirmed, holding (1) based on its plain language, Minn. Stat. 575.05 authorizes a district court to enjoin the deposition of a judgment debtor's property only if that property is in the hands of the judgment debtor or a third party or is due to the judgment debtor at the time the district court issues its order; and (2) because the judgment creditor, Appellant Fannie Mae, did not argue that Respondent's interest in the trust was Grossman's property that was currently in the hands of Grossman or a third party or currently due to Grossman, the requirements of section 575.05 were not met. View "Fannie Mae v. Heather Apartments Ltd. P'ship" on Justia Law

Appellants, Leland and Ilene Haugen and Haugen Nutrition and Equipment, defaulted on promissory notes held by respondent United Prairie Bank-Mountain Lake (UPB). The various loan agreements between the parties contained provisions in which Appellants agreed to pay UPB's reasonable costs and attorney fees associated with the protection of UPB's security interests and the enforcement of Appellants' obligation to repay the loans. The district court denied Appellants' motion to submit the question of reasonable attorney fees to the jury and subsequently awarded UPB over $400,000 in attorney fees. The court of appeals affirmed, holding that UPB's claim for the recovery of attorney fees was equitable in nature and thus did not give rise to a jury trial right under the Minnesota Constitution. The Supreme Court reversed in part, holding that Appellants were constitutionally entitled to a jury determination on UPB's claim for attorney fees because the nature of the claim was contractual and the remedy sought was legal. View "United Prairie Bank-Mountain Lake v. Haugen Nutrition & Equip., LLC" on Justia Law

Kelli Rohmiller was the sister of the mother of B.H. After B.H.'s mother died, B.H.'s father, Andrew Hart, was awarded custody of B.H. Rohmiller and her father, Clayton Rohmiller, subsequently petitioned the district court for visitation with B.H. The court jointly granted Rohmiller and Clayton unsupervised visitation with B.H. and provided that Rohmiller could exercise visitation without the presence of Clayton. Hart objected to Rohmiller's independent visitation with B.H. The court of appeals affirmed the district court's grant of visitation to Clayton but reversed the award of visitation to Rohmiller, holding that Minn. Stat. Ann. 257C.08 does not extend visitation rights to aunts generally and that she had no right to visitation under Minnesota law apart from the statute. The Supreme Court affirmed, holding (1) an aunt who does not stand in loco parentis with a child has not right under Minn. Stat. Ann. 257C.08 to visitation with the child over the objection's of the child's fit parent; and (2) an award of visitation outside of section 257C.08 and the common law and over the objections of a child's fit parent cannot be based solely on what is in the best interests of the child. View "Rohmiller v. Hart" on Justia Law

Appellant was convicted on six controlled substance crimes. The court of appeals affirmed Brist's convictions but remanded for the district court to modify Brist's sentence. On appeal, Brist argued that the admission of an audio recording of a statement made by her nontestifying coconspirator to a confidential government informant during a drug transaction violated her rights under the Confrontation Clause. The Supreme Court affirmed Brist's convictions, concluding that it was bound by Bourjaily v. U.S., which held that recorded statements of a nontestifying coconspirator, otherwise admissible as nonhearsay under materially identical evidentiary rules, are admissible at trial against another coconspirator without violating the Confrontation Clause. Therefore, the district court's admission into evidence of the coconspirator's statements in this case did not violate Brist's rights under the Confrontation Clause. View "State v. Brist" on Justia Law

The State charged Ronald Fleck with second-degree assault after he stabbed his former girlfriend. During the trial, after all the evidence was presented to the jury, the district court submitted two forms of assault to the jurors, (1) assault-fear, prohibiting an act done with the intent to cause fear in another of immediate bodily harm or death, and (2) assault-harm, prohibiting the intentional infliction of bodily harm. The district court instructed the jurors that voluntary intoxication applied to an assault-fear offense but not an assault-harm offense. The jury found Fleck not guilty of second-degree assault-fear but guilty of second-degree assault-harm. The court of appeals reversed, concluding that the district court erred by failing to instruct the jury that voluntary intoxication applied to an assault-harm offense. The Supreme Court reversed the court of appeals' decision and reinstated Fleck's conviction, holding that the district court properly instructed the jury on the applicable law. View "State v. Fleck" on Justia Law

Appellant Herman Tanksley, Jr. was convicted of fourth-degree driving while impaired, which is driving with an alcohol concentration of 0.08 or more. Tanksley appealed, arguing that he was entitled to a Frye-Mack hearing on the reliability of first-void urine testing to resolve his claim that first-void urine testing does not reliably correlate with a driver's blood alcohol concentration. The court of appeals concluded that the district court abused its discretion in denying the Frye-Mack hearing to Tanksley but that the error was harmless. The Supreme Court granted transfer and affirmed the district court, holding that the district court was not required to hold a Frye-Mack hearing based on Tanksley's challenge, as blood alcohol concentration is irrelevant when the State seeks to prove the offense of driving with an alcohol concentration of 0.08 or more solely with evidence of the amount of alcohol in the defendant's urine. View "State v. Tanksley" on Justia Law

Appellant was employed by School District for three school years as the activities director and for one school year as interim middle school principal. Subsequently, School District terminated Appellant's employment. Appellant filed a grievance on the ground that he was a continuing-contract employee and entitled to continuing contract rights under Minn. Stat. 122A.40. School District denied the grievance. The court of appeals affirmed. At issue on appeal was whether Appellant's employment by the school district as an activities director fell within the definition of a "teacher" under section 122A.40, which would determine whether he was entitled to continuing-contract rights under the statute. The Supreme Court affirmed, holding that Appellant was not a professional employee required to hold a license from the state department and therefore was not a "teacher" within the meaning of the continuing-contract statute. View "Emerson v. Indep. Sch. Dist. 199" on Justia Law

Defendant Randolph Johnson was charged with felony domestic assault and misdemeanor fifth-degree assault. As part of a negotiated plea, Defendant pleaded guilty to an amended charge of misdemeanor domestic assault, and the State dismissed the felony charge. The district court ordered that Defendant submit to a DNA sample pursuant to Minn. stat. 609.117, subd. 1(1), which requires a defendant charged with a felony and then convicted of a misdemeanor arising out of the same set of circumstances to submit a DNA sample for the limited purpose of criminal identification, after concluding that the statute was constitutional as applied to Defendant. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in conducting a search of Defendant to collect a biological specimen for criminal identification purposes outweighed Defendants' reduced expectation of privacy following his misdemeanor conviction arising out of the same set of circumstances as his felony charge; (2) consequently, the statute did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Defendant's equal protection claim failed. View "State v. Johnson" on Justia Law