Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court concluding that federal regulations implementing the federal Health Insurance Portability and Accountability Act (HIPAA) is a "specific authorization in law" under Minn. Stat. 144.293, subd. 2(2), holding that the court of appeals did not err.After Children's Health Care informed Appellants that their child's protected health information was disclosed to Children's institutionally-related foundation and its business associate for fundraising purposes Appellants sued, arguing that Children's violated the Minnesota Health Records Act, Minn. Stat. 144.291-.298. The district court granted summary judgment for Children's, concluding that the disclosure of the patient's health information was specifically authorized in law by federal regulations implementing HIPAA. The court of appeals affirmed. The Supreme Court affirmed, holding that the disclosure of the health information at issue was permitted by a "specific authorization in law," as that phrase is used in the Minnesota Health Records Act. View "Schneider v. Children's Health Care" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree intentional felony murder while committing burglary, holding that the State presented sufficient evidence to sustain Defendant's conviction.After a jury trial, Defendant was found guilty of three counts, including first-degree intentional felony murder while committing burglary. The trial court imposed a life sentence with eligibility for release after thirty years. Defendant appealed, arguing that the State presented insufficient evidence to prove his intent to kill. The Supreme Court affirmed, holding that the circumstantial evidence presented by the State was sufficient to support Defendant's conviction for first-degree intentional felony murder. View "State v. Colgrove" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of one count of possession of a firearm by an ineligible person under Minn. Stat. 609.165, subd. 1b(a), holding that a dissembled and incomplete shotgun can meet the plain language definition of a firearm under section 609.165, subd. 1b(a).Law enforcement officers discovered a disassembled twenty-gauge shotgun in Defendant's backpack, and a forensic scientist used a bolt and washer from a similar firearm to assembly and successfully fire the shotgun at issue. Defendant was found guilty of one count of possession of a firearm by an ineligible person. The court of appeals affirmed. The Supreme Court affirmed, holding that the evidence was sufficient for the jury to reach the commonsense verdict that it did. View "State v. Stone" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the order of the district court granting summary judgment in favor of Defendant in this defamation case, holding that before Plaintiff may recover presumed damages, he must show that Defendant's speech was not only false but was made with actual malice.Plaintiff, a private figure, sued Defendant after a post on Defendant's social media page accused Defendant and others of sexual assault. The district court granted summary judgment for Defendant on the grounds that the speech involved a matter of public concern and was not made with actual malice. The court of appeals reversed, holding that the truth or falsity of Defendant's statement presented a genuine issue of material fact. The Supreme Court reversed, holding (1) the dominant theme of Defendant's post involved sexual assault in the context of the #MeToo movement, and therefore, her statement was entitled to heightened protection under the First Amendment; and (2) remand was required for a trial on the veracity of Defendant's speech and actual malice. View "Johnson v. Freborg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress evidence found during a search of his vehicle, holding that the odor of marijuana emanating from a vehicle, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement.After a traffic stop and subsequent search of his vehicle Defendant was convicting of possession of methamphetamine paraphernalia in the presence of a minor and fifth-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the odor of marijuana, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement. The district court granted the motion and dismissed the complaint. The court of appeals affirmed. The Supreme Court affirmed, holding that evidence of medium-strength odor of marijuana, on its own, is insufficient to establish a fair probability that the search would yield evidence of criminally-illegal conduct or drug-related contraband. View "State v. Torgerson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of falsely reporting a crime to a police officer, holding that the evidence was sufficient to support the conviction and that venue was proper in Waseca County.Defendant's conviction was based on her false report to police that the father of her child had abused their child. Because Defendant was in Blue Earth County when she made the report she argued on appeal that venue was improper in Waseca County and that the evidence was insufficient to sustain her conviction. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the State met its burden to show venue based on the location of the officer receiving the false report; and (2) the evidence was sufficient to support Defendant's conviction. View "State v. Johnson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the determination of the district court that the underlying First Amendment retaliation claim brought under 42 U.S.C. 1983 was time-barred, holding that the continuing violation doctrine did not apply to toll the statute of limitations.Plaintiff brought this action alleging that Defendant, the City of Duluth, retaliated against him in violation of his rights under the First Amendment by making false statements and engaging in other negative conduct toward him. In dismissing the claim, the trial court rejected Plaintiff's reliance on the continuing violation doctrine. The court of appeals reversed and reinstated Plaintiff's section 1983 retaliation claim against the City, concluding that the continuing violation doctrine did not apply because the acts Plaintiff alleged as retaliation were discrete acts that were actionable when committed and therefore did not constitute a continuing violation that tolled the statute of limitations. The Supreme Court affirmed, holding that the continuing violation doctrine did not apply in this case. View "Ringsred v. City of Duluth" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress evidence discovered in the vehicle that Defendant was driving, holding that the totality of the circumstances supported probable cause to search the vehicle.Law enforcement initiated a traffic stop after receiving a tip from an informant that a male in possession of a firearm was in the vehicle Defendant was driving. The district court granted Defendant's motion to suppress the firearm on the grounds that the officers lacked probable cause to search the vehicle. The court of appeals affirmed. The Supreme Court reversed, holding that the State met its burden and established probable cause to search the vehicle that Defendant was driving. View "State v. Mosley" on Justia Law

The Supreme Court affirmed Defendant's conviction, following a jury trial, of gross-misdemeanor indecent exposure, holding that an individually who willfully and lewdly exposes himself in the privately-owned, partially-enclosed backyard of his home has done so in a "in any place where others are present" within the meaning of the indecent-exposure statute, Minn. Stat. 617.23, subd. 1.After he was convicted, Defendant filed a petition for postconviction relief, arguing that the State failed to prove that he was in a "public place, or in any place where others are present" within the meaning of the statute. The district court denied the petition, concluding that Defendant's actions occurred in a public place. The court of appeals affirmed. The Supreme Court affirmed, holding that the privately-owned, partially-enclosed backyard of a home satisfies the "place" element of the indecent-exposure statute. View "Fordyce v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant postconviction relief by ordering a substantive sentencing hearing, holding that, under the circumstances of this case, it would be manifestly unfair for the district court not to hold a substantive sentencing hearing in accordance with State v. Warren, 592 N.W.2d 440 (Minn. 1999).After a jury trial, Defendant was convicted of two counts of first-degree murder. Defendant was seventeen years old when he committed the offenses. The district court sentenced Defendant to two consecutive sentences of life in prison without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, the district court resentenced Defendant to two consecutive sentences of life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant subsequently filed his postconviction petition requesting a substantive hearing to consider whether, pursuant to the test articulated in Warren, his modified sentences should be served concurrently rather than consecutively. The district court granted the petition. The Supreme Court affirmed, holding that the unique circumstances of this case warranted the exercise of this Court's inherent supervisory powers to direct that the district court hold a substantive sentencing hearing in accordance with Warren. View "State v. Thompson" on Justia Law