Justia Minnesota Supreme Court Opinion Summaries

George Frandsen was employed by Ford Motor Company when he was injured in the course and scope of his employment. Ford assumed responsibility for the injury and paid Frandsen temporary total disability (TTD) benefits pursuant to the Minnesota Workers' Compensation Act. Later, the parties agreed to reclassify the TTD benefits Ford had previously paid to Frandsen as permanent total disability (PTD) benefit payments. After Frandsen turned sixty-seven years old, Ford petitioned the WCCA to discontinue payment of Frandsen's PTD benefits pursuant to Minn. Stat. 176.101, which states that permanent total disability shall cease at age sixty-seven because the employee is presumed retired from the labor market. The Workers' Compensation Court of Appeals (WCCA) denied Ford's petition, concluding that Ford had waived the retirement presumption by failing to expressly reserve the right to discontinue payment of Frandsen's PTD benefits in the settlement agreement. On review, the Supreme Court reversed the WCCA, holding (1) the retirement presumption applies unless the employee rebuts the presumption or proves knowing and intentional waiver by the employer, and (2) here the record lacked any evidence that Ford intended to continue paying PTD benefits to Frandsen after he turned sixty-seven. Remanded. View "Frandsen v. Ford Motor Co." on Justia Law

This case involved the assault of a pregnant woman, who, after the assault, received a cesarean section. The baby, named Destiny, later died. After a jury trial, Dameon Gatson was convicted of first-degree premeditated murder for aiding the perpetrator in the killing of Destiny and first-degree assault. On appeal, the Supreme Court affirmed, holding (1) the trial court did not err when it upheld the State's strike of a prospective juror; (2) the evidence was sufficient to support the verdict; (3) the trial court did not err by not instructing the jury on whether Destiny was a "human being" for purposes of the homicide statutes and on whether the removal of Destiny's life support was a superseding intervening cause of her death; (4) any error in admitting portions of the perpetrator's guilty plea was harmless beyond a reasonable doubt and any violation of Gatson's right to confrontation was harmless; (5) Gatson was not entitled to relief on his claim that the admission of the perpetrator's guilty plea violated hearsay rules; and (6) the trial court did not abuse its discretion in denying Gatson's motion for a new trial based on newly discovered evidence. View "State v. Gatson" on Justia Law

David Miller purchased a home owned by respondents Linda Lankow and Jim Betz. The home had previously been extensively remediated because of moisture intrusion damage. Respondents Donnelly Brothers and Total Service Company and defendant Diversified Contractors, Inc. did the remediation work. After discovering and notifying respondents and defendants of additional moisture intrusion damage, buyer began to repair the home. Buyer then commenced an action against respondents and defendant to recover damages. The district court excluded buyer's expert witness evidence as a sanction for the spoliation of evidence that resulted from buyer starting to make repairs to his home. The court then granted respondents' summary judgment motion on the basis that buyer could not make a prima facie case without the expert evidence. The court of appeals affirmed. The Supreme Court reversed, holding that the duty of a custodial party to preserve evidence may be discharged when the custodial party has a legitimate need to destroy the evidence and gives the noncustodial party notice sufficient to enable the noncustodial party to protect itself against the loss of the evidence. View "Miller v. Lankow" on Justia Law

John Miles was convicted of first-degree murder. Miles filed a petition for postconviction relief, alleging that he was entitled to a new trial on the basis of newly discovered evidence, specifically, the information in an interview between Miles's counsel and a witness of the homicide, who stated that Miles was not responsible for the shooting of the victim. The postconviction court denied the petition, concluding that it was time-barred under Minn. Stat. 590.01. On review, the Supreme Court affirmed without prejudice, holding (1) the postconviction court erred when it determined that the witness's statement could have been discovered by the exercise of due diligence prior to trial, (2) the postconviction court applied the wrong legal test when it concluded that the witness's statement did not establish by a clear and convincing standard that Miles was innocent, but (3) the court did not err when it denied Miles's petition without a hearing because Miles failed to offer newly discovered evidence with sufficient indicia of reliability to warrant relief under the statute. The Court concluded if Miles could base a new petition on a more satisfactory showing of a genuine statement from the witness, he was entitled to file a new petition. View "Miles v. State" on Justia Law

Employee was injured while working in Minnesota for Wisconsin-based Employer. Employee applied for Wisconsin and Minnesota workers' compensation benefits. Employer's insurance company, Travelers Insurance, covered the Wisconsin benefits but denied the claim for Minnesota benefits based on an exclusion of Minnesota coverage in Employee's policy. Employee then filed a claim for Minnesota benefits with the Minnesota Department of Labor and Industry. After settling the claim, the Department pursued a petition for reimbursement it had filed against Employer. A compensation judge found that Employer was not insured for Minnesota workers' compensation liability and ordered Employer to reimburse the Department. The Workers' Compensation Court of Appeals (WCCA) reversed, concluding that Employer was entitled to coverage from Travelers under the reasonable expectations doctrine. On review, the Supreme Court reversed and remanded for reconsideration in light of a recent Court decision clarifying that the doctrine should not be used to provide coverage in contravention of unambiguous policy terms. On remand, the WCCA again reversed the compensation judge. On review, the Supreme Court reversed, holding that the WCCA had no authority to declare unambiguous language of an insurance contract to be invalid and unenforceable because the exclusion conflicted with Wisconsin statutory provisions and public policy. View "Martin v. Morrison Trucking, Inc." on Justia Law

While Timothy Allen worked as a sales associate for respondent Burnet Realty, he executed agreements to participate in respondent's legal administration program (LA Program). Under the LA Program contracts, Allen and respondent agreed to an allocation of expenses should a dispute arise related to Allen's work for respondent. In litigation commenced after he stopped working for respondent, Allen claimed that respondent violated Minn. Stat. 60K.47 because the LA Program contracts were insurance, and, as a result, respondent was required to be, but was not, authorized to engage in the business of insurance in Minnesota. Allen also claimed other relief on the basis that the contracts were insurance. The district court granted summary judgment in favor of respondent, concluding that the contracts were not contracts of insurance. The court of appeals affirmed. The Supreme Court affirmed the grant of summary judgment to respondent, holding that the LA Program was not "insurance" under statutory definitions on statute or case law. View "Allen v. Burnet Realty, L.L.C. " on Justia Law

Appellant Audie Matthews was found guilty by a jury of first-degree murder for a shooting death. When police officers were investigating the shooting, a police dog picked up a "fear scent" near the scene of the shooting and followed the scent through the neighborhood, losing the scent near the location where an officer stopped Matthews for questioning. Matthews appealed, arguing (1) the district court erred in admitting expert testimony that the police dog tracked a fear scent, and (2) the State failed to present sufficient evidence to support his conviction. The Supreme Court affirmed the conviction, holding (1) Matthews failed to establish a reasonable likelihood that the admission of the fear scent testimony significantly affected the verdict under the four factors for harmless error review, and therefore, Matthews was not entitled to a new trial based on the district court's admission of the fear scent testimony; and (2) the alleged shortcomings in the State's evidence did not support a reasonable inference other than that of guilt. View "State v. Matthews" on Justia Law

Gerald Hanson was found guilty by a jury of first- and second-degree controlled substance crime and possession of drug paraphernalia. The cout of appeals reversed, concluding that the evidence was legally insufficient to support Hanson's conviction of first-degree controlled substance crime. At issue on review was whether the evidence that Hansons possessed small, unused bags, when coupled with the remaining evidence as a whole, formed a completed chain that led directly to Hanson's guilt of possessing more than ten grams of methamphetamine with intent to sell as to exclude beyond a reasonable doubt any rational inference other than guilt. On review, the Supreme Court reversed the judgment of the court of appeals, concluding that the evidence presented, when viewed as a whole, was sufficient to support Hanson's first-degree controlled substance crime conviction. View "State v. Hanson " on Justia Law

Daniel Dalbec was found guilty of third-degree criminal sexual conduct. At Dalbec's trial, counsel for the State and Dalbec agreed to submit written closing arguments to the trial court, but defense counsel failed to submit a closing argument. On appeal, Delbec argued that he was entitled to a new trial based on a structural error that allegedly occurred when the trial court adjudicated his guilt without having received a closing argument from his counsel. The court of appeals reversed Dalbec's conviction and granted Dalbec a new trial based on the structural error. The Supreme Court granted the State's petition for review and reversed the court of appeals. At issue was whether defense counsel's failure to submit a written closing argument constituted structural error requiring automatic reversal and a new trial. The Court held (1) defense counsel's failure to submit a closing argument did not result in structural error, and (2) the trial court's adjudication of Dalbec's guilt without the benefit of closing argument was not structural error. Remanded. View "State v. Dalbec" on Justia Law

In 2008, Marlow Timberland (MT) filed a tax petition challenging the taxes payable in 2008 on the belief that Lake County's property tax assessment of MT's recently purchased land was too high. MT then filed tax petitions challenging the taxes payable in 2009 and 2010, which were dismissed due to MT's failure to pay the taxes. MT moved to reinstate the 2009 and 2010 petitions based on its contention that the properties were overassessed and that it was unable to pay the taxes due. The Minnesota Tax Court issued an order granting Lake County's motion to dismiss the 2008 petition and denying MT's motion to reinstate the 2009 and 2010 petitions. On review, the Supreme Court reversed in part and affirmed in part, holding (1) the tax court erred by not allowing MT to amend its 2008 petition because an amendment would not result in any prejudice to Lake County; and (2) the tax court properly denied MT's motion to reinstate its 2009 and 2010 tax petitions, and reinstatement of those petitions was not required on an equitable basis. Remanded. View "Marlow Timberland, L.L.C. v. County of Lake " on Justia Law