Justia Minnesota Supreme Court Opinion Summaries

Following a jury trial, Lawrence Montanaro was convicted of first-degree murder of a police officer. After the statute of limitations for filing a postconviction petition expired, Montanaro filed a petition for postconviction relief. The postconviction court denied the petition without deciding whether Montanaro established an exception to the statute of limitations. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Montanaro's request for a new trial based on the court's conclusion that alleged errors in the jury instructions and the prosecutor's alleged misconduct during his closing argument did not satisfy the third prong of the plain error test because the errors did not affect Montanaro's substantial rights. View "Montanaro v. State" on Justia Law

Appellant Victor Martinez-Mendoza was charged by complaint with one count of first-degree criminal sexual conduct and one count of second-degree criminal sexual conduct. The State and Appellant reached a plea agreement in which Appellant would plead guilty to count two of the complaint and count one would be dismissed. Appellant subsequently pleaded guilty to count two, and the district court adjudged Appellant guilty of count two. Before the sentencing hearing, the State learned that the actual presumptive guidelines sentence for the count two offense involved a much shorter incarceration time than the parties had originally thought. The State moved to vacate the plea or, in the alternative, reinstate count one of the complaint. The district court denied the motion, citing double jeopardy concerns. The court of appeals reversed based on the parties' mutual mistake. The Supreme Court reversed, holding that jeopardy attached when the trial court accepted and recorded Appellant's guilty plea, and thus, any appeal by the State was barred as moot as a matter of law. View "State v. Martinez-Mendoza" on Justia Law

Lincoln Caldwell was convicted in district court of aiding and abetting first-degree premeditated murder for the benefit of a gang. Caldwell appealed his conviction and the denial of two postconviction petitions. The Supreme Court affirmed, holding that (1) Minn. Stat. 609.05 permits the conviction of a defendant for aiding and abetting first-degree murder notwithstanding the fact that the party who fired the shots that killed the victim was acquitted of first-degree murder and convicted of second-degree murder; (2) there was sufficient evidence for the jury to conclude that the party who fired the shots that killed the victim had the necessary intent and premeditation to sustain Caldwell's conviction; and (3) there was sufficient evidence that a group of persons with whom Caldwell associated, and for whose benefit he committed the crime of first-degree murder, was a statutorily-defined gang. View "State v. Caldwell" on Justia Law

Gregory Latterell, on behalf of his stepson Jared Boom's estate, sued Progressive Northern Insurance and AIG Insurance to recover underinsured motorist (UIM) benefits following Boom's death from a motor vehicle accident. Progressive, the insurer of Boom's vehicle, denied Latterell's claim for UIM benefits because of a business-use exclusion in Boom's insurance policy. AIG, Lattrell's insurer, also denied Latterell's claim. Latterell sued, and the district court granted summary judgment to Progressive and AIG. The court of appeals affirmed, holding (1) the business-use exclusion in the Progressive policy was enforceable under the Minnesota No-Fault Automobile Insurance Act and unambiguously excluded UIM coverage under the specific circumstances of this case, and (2) Latterell could not recover UIM benefits under the AIG policy. The Supreme Court reversed the denial of Latterell's summary judgment as to Progressive, holding that Progressive's business-use exclusion was unenforceable under the No-Fault Act. Remanded with instructions to enter judgment in favor of Latterell against Progressive. View "Latterell v. Progressive N. Ins. Co." on Justia Law

After a jury trial, the district court convicted Ronald Hill of first-degree premeditated murder. The Supreme Court affirmed Hill's conviction, holding (1) because the district court properly and carefully balanced the potential probative value and prejudicial effects of the proffered impeachment evidence, the court did not abuse its discretion when it admitted evidence of Hill's prior, unspecified felony conviction for impeachment purposes; (2) Hill was not entitled to a new trial because allegedly improper testimony that the State obtained Hill's DNA sample through a search warrant was harmless because it did not affect Hill's substantial rights; (3) any alleged error in admitting evidence that Hill shot the victim with a gun stolen during a home invasion was harmless because there was not a reasonable possibility that the alleged error significantly affected the verdict; and (4) the cumulative effect of any errors resulting from the admission of disputed testimony did not affect Hill's substantial rights, and therefore, Hill was not deprived of his constitutional right to a fair trial. View "State v. Hill" on Justia Law

Elizabeth Hawes was convicted of aiding and abetting her brother, Andrew Hawes, in the first-degree murder of their brother, Edwin Hawes. The district court sentenced Hawes to life imprisonment. The Supreme Court affirmed Hawes' conviction, holding (1) the circumstantial evidence was legally sufficient to support Hawes' conviction of aiding and abetting first-degree premeditated murder; (2) any error the the district court made when it ruled that out-of-court statements made by Andrew were not admissible as declarations against penal interest was harmless beyond a reasonable doubt; and (3) the district court did not abuse its discretion when it denied Hawes' motion for a new trial on the grounds of newly available evidence. View "State v. Hawes" on Justia Law

Berry and Co. petitioned the tax court for relief from the County's property tax assessment of its property for 2007 and 2008. At trial, Berry and the County each offered expert appraiser testimony as to the estimated market value of the property. Both appraisers used the market sales comparison approach to value the subject property. The tax county determined that the highest and best use for the subject property was redevelopment and agreed with the County's expert on the valuation, which was higher than the original assessment. The Supreme Court affirmed, holding (1) the tax court's determination that the highest and best use of the subject property was redevelopment was not erroneous, and (2) the tax court's valuation of the subject property was supported in the record and was not clearly erroneous. View "Berry & Co., Inc. v. County of Hennepin" on Justia Law

After suffering a work-related injury, Employee underwent surgery at a hospital owned by HealthEast Care System. The injury required surgical implantation of a spinal cord stimulator. Employer's worker's compensation insurance provider, State Auto Insurance, paid part but not all of the surgical expenses, asserting (1) the withheld portion of the expenses was attributable to a price markup added by HealthEast to the price paid by HealthEast for the implant hardware used in Employee's surgery, and (2) the manufacturer of the implant hardware should be required to charge directly for the implant hardware. The compensation judge found that Employer and State Auto were liable for the unpaid balance. The Workers' Compensation Court of Appeals affirmed. The Supreme Court affirmed, holding (1) HealthEast could charge for the implant hardware because when more than one health care provider is responsible for the creation of a service, article, or supply, the provider that provides the service, article, or supply in its final form is entitled to charge for it; and (2) a compensation judge does not have the authority to determine a reasonable value of a treatment, service, or supply that is lower than eighty-five percent of the provider's usual or customary charge. View "Troyer v. Vertlu Mgmt. Co." on Justia Law

Samantha Heiges was arrested and charged with second-degree murder and first-degree manslaughter for allegedly drowning her baby daughter in a bathtub immediately after the baby was born. After a jury trial, the district court convicted Heiges of second-degree murder and sentenced her to 299 months in prison. The court of appeals affirmed Heiges's conviction. On review, the Supreme Court affirmed, holding (1) the scope of the term "confession" in Minn. Stat. 634.03 includes statements made to friends and acquaintances after the crime was committed but before the commencement of the police investigation; (2) Heiges's conviction did not violate Section 634.03 when the State established the trustworthiness of Heiges's confessions by presenting sufficient evidence to corroborate the attendant facts and circumstances of those confessions; (3) the facts admitted in Heiges's confession could be used to satisfy Minn. Stat. 634.051, which requires that the evidence that establishes the death of the victim be independent of the evidence that establishes the killing of the victim by the defendant; and (4) the evidence at trial, including Heiges's confessions, was sufficient to sustain Heiges's conviction for second-degree murder. View "State v. Heiges" on Justia Law

Continental Retail sought certiorari review of the market value determinations by the Minnesota Tax Court for a Continental commercial building for the assessment dates of 2006, 2007, and 2008. Continental filed petitions challenging the county assessor's estimated market value for the three years, and at trial, the tax court increased the market value determinations for all three years. On appeal, Continental argued that the tax court's value determinations were excessive and not supported by the record over the assessed value of the property. The Supreme Court affirmed, holding that the tax court's value determinations were supported by the record and were not clearly erroneous. View "Continental Retail, L.L.C. v. County of Hennepin" on Justia Law