Justia Minnesota Supreme Court Opinion Summaries

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

William Eldredge, an honorably discharged veteran and a firefighter employed by the City of Saint Paul, was notified by the City that it intended to terminate his employment. Eldredge challenged the termination under the Veterans Preference Act (VPA), which provided that Eldredge may not be removed from his job except for incompetency or misconduct shown after a hearing. The Saint Paul Civil Service Commission granted summary disposition in Eldredge's favor. The City sought judicial review by petitioning for and securing the issuance of a writ of certiorari from the district court. The court dismissed the writ after concluding that the City had missed the filing deadline for appeals under the VPA. The court of appeals reversed. The Supreme Court affirmed the court of appeals, holding (1) the district court erred when it concluded the writ was untimely, and (2) because the writ was timely, the district court had jurisdiction to consider the City's appeal. Remanded. View "City of Saint Paul v. Eldredge" on Justia Law

After Walter Randolph was convicted for misdemeanor domestic assault, the district court issued an order appointing private counsel to represent Randolph on appeal and required Rice County to cover the cost of appointed private counsel. The County objected to the order. The district court ordered a hearing to determine which entity had responsibility for Randolph's representation on appeal and joined intervenors Rice County and the State Board of Public Defense to the action. After a hearing, the district court (1) vacated the previous order; (2) ordered the State or District Public Defender's Office to either substitute one of its attorneys for the appointed private counsel or to pay appointed counsel reasonable attorneys fees; and (3) ordered the State Public Defender's Office to pay transcript costs. The Supreme Court granted the Board's petition for accelerated review and (1) reversed the district court's order appointing the public defender after finding that the legislature had not authorized public defenders to represent indigent misdemeanants on appeal; (2) reversed the district court's order that the State Public Defender's office pay for any required transcripts; (3) reinstated the earlier order appointing private counsel; and (4) ordered the State to cover the cost of appointed counsel. View "State v. Randolph" on Justia Law

Steven Leathers was convicted of five counts of first-degree assault against a peace officer pursuant to Minn. Stat. 609.221, 2(a). The district court sentenced Leathers to concurrent sentences totaling 189 months with eligibility for supervised release after 126 months in prison, or two-thirds of his sentence. Leathers appealed his conviction, and the State appealed the sentence. The court of appeals upheld Leathers' conviction but reversed the sentence, holding that Leathers was not eligible for supervised release. The Supreme Court granted review on the issue of supervised release. The Court reversed the court of appeals and affirmed the district court's decision, holding that the definition of the phrase "full term of imprisonment" in section 609.221, 2(b) means two-thirds of a defendant's executed prison sentence. Thus, Leathers was ineligible for work release or supervised release until he had served a full two-thirds of his sentence, after which point he would be eligible for supervised release. View "State v. Leathers" on Justia Law

Appellant Michelle Kern was involved in an accident with Cody Janson, whose vehicle was owned by Jessica Gerwing. A year later Kern was involved in an accident with Jennifer Torborg, whose vehicle was owned by James Torborg. Kern sought to recover property damages from the Torborgs in conciliation court, and the conciliation court entered a judgment against James Torborg. Kern and her husband then sued Janson, Gerwing, and the Torborgs in district court, claiming they were jointly and severally liable for Kern's personal injuries. The Torborgs moved for summary judgment, citing the doctrine of res judicata. Kern then moved to vacate the conciliation court judgment. The district court granted Kern's motion, and accordingly, denied the Torborgs' motion for summary judgment. The court of appeals reversed and remanded for entry of summary judgment in favor of the Torborgs because Kern consulted with an attorney before initiating the conciliation court action. On review, the Supreme Court reversed the judgment of the appellate court, holding that consultation with an attorney before initiating a conciliation court action does not automatically preclude vacation of the conciliation court judgment. Remanded. View "Kern v. Janson " on Justia Law

Two tribal members (Appellants) were committed as sexually dangerous persons under Minn. Stat. 253B.02, 18c and committed to the Minnesota Sex Offender Program. Appellants moved to dismiss their commitments for lack of subject matter jurisdiction based on their status as enrolled tribal members. The district court denied both motions to dismiss. Appellants appealed the district court's orders, and the court of appeals affirmed, holding that even though federal law did not affirmatively grant the State jurisdiction to commit appellants, federal law did not preempt appellants' commitments. On review, the Supreme Court affirmed, holding that (1) based on the terms of the state's civil commitment statute, appellants' commitments were civil causes of action subject to Congress' express grant of civil jurisdiction under 28 U.S.C. 1360(a); (2) in light of the strong State interests presented, the fact that Congress has not pervasively regulated this area of the law, and the minimal intrusion on tribal sovereignty, Minnesota's enforcement of chapter 253B was not preempted; and (3) the state had jurisdiction to civilly commit Appellants. View "In re Civil Commitment of Johnson" on Justia Law

Appellant Andy Prtine was convicted of first-degree felony murder for the stabbing death of Brent Ward. On appeal, Appellant argued that he was denied effective assistance of counsel because his attorney conceded in his closing argument without Appellant's consent that Appellant intended to kill Ward. The Supreme Court held that Appellant's counsel conceded guilt with respect to the element of intent to kill in his statement and remanded to the district court to determine whether Appellant acquiesced in his trial counsel's concession of intent to kill. The district court ruled that Appellant acquiesced in his counsel's concession that the killing was intentional. The Supreme Court affirmed Appellant's conviction, holding that (1) Appellant acquiesced in the concession, and (2) because Appellant acquiesced in his trial counsel's concession of guilt with respect to intent to kill, Appellant was not entitled to a new trial based on his ineffective-assistance-of-counsel claim. View "State v. Prtine" on Justia Law

After a jury trial, Jack Nissalke was convicted of first-degree premeditated murder and sentenced to life imprisonment. On appeal, the Supreme Court affirmed, holding (1) Nissalke was not entitled to a new trial based on the district court's entry into the jury room and communication with the jury outside the presence of counsel and Nissalke while the jury was deliberating; (2) the district court did not violate Nissalke's right to present a complete defense by refusing to admit certain alternative perpetrator evidence; (3) the State did not commit prejudicial misconduct by asserting facts not in evidence in opening statements and closing arguments and by shifting the burden of proof to Nissalke in closing; (4) although the district court erred by failing to remove a biased juror for cause, this error did not require reversal; (5) the evidence was sufficient to support Nissalke's conviction; (6) the State did not violate Nissalke's due process rights by failing to preserve physical evidence; and (7) Nissalke was not entitled to a new trial based on his claims of ineffective assistance of counsel. View "State v. Nissalke" on Justia Law