Justia Minnesota Supreme Court Opinion Summaries

After the district court determined that the parties involved in this appeal were not in a special relationship, a jury found Appellants Eric Rolland and Rolland Building Corporation not negligent in an incident in which a skid loader attachment used to perform landscaping at Respondent Bradley Domagala's home fell on Respondent's foot, resulting in the amputation of three toes. The court of appeals affirmed in part and reversed in part, holding (1) Appellants did not have a specific legal duty to warn Respondent arising in the context of a special relationship, but (2) Appellants had a general duty to warn as an exercise of the general duty of reasonable care. The Supreme Court affirmed, holding (1) the trial court's special instructions to the jury that Appellants had no duty to warn and no duty to protect Respondent were misleading as to the crucial elements of duty and breach of duty, and (2) the instructions were prejudicial to Respondent. Remanded for a new trial. View "Domagala v. Rolland" on Justia Law

Appellant Erik Jeffries pled guilty to felony domestic assault and negotiated an agreement with the State in which he would receive a stayed sentence. The district court indicated at the plea hearing that it was accepting Jeffries' plea and that Jeffries was convicted. At a later date, the court told Jeffries it was "giving you your pleas back" and set the case for trial. Jeffries subsequently reached another plea agreement with the State that resulted in a sixty-month executed sentence. Jeffries appealed, arguing that the Double Jeopardy Clause prohibited the State from prosecuting him a second time for felony domestic assault. The court of appeals affirmed the sentence. The Supreme Court reversed and vacated Jeffries' second conviction, holding (1) the district court unconditionally accepted Jeffries' first guilty plea, (2) the guilty plea was recorded as required by statute by its inclusion in the record of the plea hearing, (3) the second prosecution for the same offense violated the Double Jeopardy Clause, and (4) Jeffries did not forfeit his double-jeopardy claim by entering a second guilty plea. Remanded for resentencing on Jeffries' first conviction. View "State v. Jeffries" on Justia Law

Appellant Calvin Ferguson was convicted of first-degree premeditated murder and sentenced to life in prison without any possibility of parole. On appeal, the Supreme Court reversed, holding that the district court erred when it excluded evidence that had an inherent tendency to connect an alternative perpetrator to the shooting of the victim because (1) the evidence showed that the alternative perpetrator's physical description was in several ways similar to the description of the shooter, (2) the alternative perpetrator's vehicle matched the description of the shooter's vehicle, (3) the alternative perpetrator's nickname matched that of the shooter, and (4) the alternative perpetrator had a connection with the victim. Because the district court's exclusion of the alternative perpetrator evidence denied Ferguson his constitutional right to present a complete defense and the court's error was not harmless beyond a reasonable doubt, the case was remanded for a new trial. View "State v. Ferguson" on Justia Law

Appellant Mahdi Ali was indicted for murder in the first degree and murder in the second degree for the shooting deaths of three individuals. The indictment alleged that Ali was seventeen years old on the date of the alleged offenses and therefore automatically subject to trial in the district court. Ali moved to dismiss the indictment, contending that he was fifteen years old on the date of the shootings and that the jurisdiction of the juvenile court was therefore exclusive. The district court denied the motion, concluding that Ali had reached his sixteenth birthday before the date of the shootings. The court of appeals dismissed Ali's appeal, concluding that the district court's order denying Ali's motion to dismiss the indictment was not appealable. The Supreme Court reversed in part and affirmed in part, holding (1) the denial of a defendant's motion to dismiss an indictment for murder for lack of subject matter jurisdiction is immediately appealable as of right; and (2) when the age of the defendant determines the jurisdiction of the court, the State has the burden of proving, by a preponderance of the evidence, the defendant's age on the date of the alleged offense. View "State v. Ali" on Justia Law

Following a bench trial, Keonne Palmer was found guilty of first-degree premeditated murder, second-degree intentional murder, and possession of a firearm by a prohibited person. Palmer appealed. The Supreme Court affirmed, holding (1) the circumstantial evidence in this case led to the conclusion that Palmer considered, planned, and prepared for the victim's death, and therefore, the evidence was sufficient to support a conviction of premeditated murder; (2) any failure by the district court to consider lesser-included manslaughter offenses could not have affected Palmer's substantial rights because the inclusion of manslaughter charges would not have affected the outcome; and (3) the trial court did not improperly pronounce Palmer's sentence. View "State v. Palmer" on Justia Law

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. During the trial, the district court allowed a police officer to testify in the State's case in chief that Borg did not respond to a request for an interview by the officer. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed the officer to testify about "silence in response to police questions or attempts to pose questions." The Supreme Court reversed the court of appeals and affirmed Borg's conviction, holding that the Fifth Amendment does not prohibit the State from introducing evidence during the State's case in chief regarding a defendant's silence unless the government compelled the defendant to speak or remain silent. View "State v. Borg" on Justia Law

Before his death, Patrick Butler designated Appellant Maureen Kissack, one of his natural daughters, as joint owner of five certificates of deposit (CDs) with the right of survivorship. After Butler's death, the district court appointed Kissack as the personal representative of Butler's estate. Kissack, believing the CDs were nonprobate assets that she now owned, redeemed several of them and withdrew the proceeds without including the CDs in the inventory of estate assets filed with the district court. After another one of Butler's children protested this action, the district court ruled that the CDs were assets of Butler's estate and were subject to probate. After granting Kissack's motion for a new trial, the district court ruled in favor of Respondents, Butler's other natural daughters and surviving stepchildren. At issue on appeal was whether Respondents presented sufficient evidence to overcome the statutory presumption in favor of survivorship rights for joint accounts. The Supreme Court reversed the district court, holding that because Minn. Stat. 524.6-204(a) requires that the evidence offered to overcome the statutory presumption must specifically refer to the joint accounts at issue, Respondents failed to present sufficient evidence to satisfy their burden of proof. Remanded. View "In re Estate of Butler" on Justia Law

Respondent Jill Engquist, as parent and natural guardian of minor Amber Engquist, sued Appellants, Steven and Christina Loyas, for injuries Amber sustained as a result of a dog bite that occurred at Appellants' residence. The district court entered judgment in favor of Appellants after finding that Amber provoked the dog to bite her. The court of appeals reversed on the ground that the jury instruction given by the district court misstated the meaning of provocation under Minn. Stat. 347.22. The Supreme Court affirmed, holding that because the jury could have found provocation without any consideration of the victim's knowledge of the danger, the jury instructions materially misstated the law and prejudiced Respondent. Remanded for a new trial. View "Engquist v. Loyas" on Justia Law

William Jacobs was charged with two counts of criminal sexual conduct. Jacobs moved to remove the judge assigned to his case for cause, basing his motion on the fact that the judge had not disclosed that his spouse was, at the time, an attorney with the county attorney's office that was prosecuting the case. Jacobs' motion was denied. The court of appeals denied Jacobs' writ of prohibition, holding that a spouse's position as an assistant county attorney in the public office that is prosecuting the case does not by itself create an appearance of partiality. The Supreme Court affirmed, holding that the judge was not required to disqualify himself from the case because a reasonable examiner, with full knowledge of the facts and circumstances in this case, would not question the judge's impartiality. View "State v. Jacobs" on Justia Law

Appellant Elaine Wesely filed a dental malpractice action, alleging that she received negligent care from dentist A. David Flor. To satisfy the statutory requirement of expert disclosure, Wesely submitted an affidavit disclosing the opinions of a doctor of internal medicine, not a dentist. After Flor moved to dismiss the claim, asserting the affidavit was deficient because the internist was not qualified to be an expert in the action, Wesely's counsel submitted a second affidavit identifying a dentist-expert and disclosing his opinions. The district court granted Flor's motion to dismiss, concluding that the second affidavit did not amend the original affidavit. The court of appeals affirmed. The Supreme Court reversed, holding that the second affidavit was an amended affidavit that was capable of correcting the alleged deficiencies of the first affidavit. Remanded. View "Wesely v. Flor" on Justia Law