Justia Minnesota Supreme Court Opinion Summaries

Diane Cox was charged with issuing dishonored checks with a value of more than $500 in violation of the dishonored-check statute, which is a felony. Cox filed a motion to dismiss, arguing that the sentencing disparity between the dishonored-check statute and the theft-by-check statute violated her constitutional right to equal protection of the law because issuing a dishonored check is a lesser-included offense of theft-by-check yet is punished more harshly than the greater offense. The district court denied Cox's motion but certified to the court of appeals the question of whether the disparity in the severity of punishment between the two statutes, which arguably contemplate the same acts committed under the same circumstances by persons in like situations, constitutes an equal protection violation as applied to defendant and those similarly charged. The appellate court answered the question in the negative. The Supreme Court affirmed, holding that Cox is not similarly situated to a defendant who commits theft by check because her conduct would not support a conviction for theft by check, and therefore Cox was not denied equal protection of the law. View "State v. Cox" on Justia Law

Appellant John Koppi was convicted of second-degree refusal to submit to chemical testing. Under state laws, refusing a chemical test is not a crime unless an officer had probable cause to believe the person was operating a motor vehicle while impaired. Koppi appealed, arguing that the district court abused its discretion in giving the jury an erroneous instruction that articulated a purely subjective definition of probable cause. The court of appeals affirmed. The Supreme Court found because the jury instruction did not require the jury (1) to evaluate probable cause based on the totality of the facts and circumstances and (2) to determine whether a reasonable police officer would find probable cause, the instruction did not articulate a correct, objective standard of probable cause. The Court held Koppi was entitled to a new trial because the erroneous jury instruction was not harmless beyond a reasonable doubt. The Court also held that Koppi waived his second argument because Koppi failed to properly preserve it. Reversed and remanded. View "State v. Koppi" on Justia Law

After respondent was granted a permit by the Minnesota Public Utilities Commission (âMPUCâ) for routing and construction of a pipeline to deliver natural gas to an energy center within appellantâs city limits, appellant commenced an action for declaratory and injunctive relief seeking to require respondent to obtain a franchise from appellant to operate the pipeline. The district court dismissed, concluding that appellant did not have franchise authority over respondentâs pipeline, and the appeals court affirmed. The Supreme Court reversed and remanded, holding (1) a municipality is authorized by Minn. Stat. 301B.01 to impose a franchise on a public utility that has constructed and operates a gas pipeline located on public property within the municipality, regardless of whether the pipeline itself supplies gas to the public; (2) a municipality is authorized by Minn. Stat. 216B.36 to impose a franchise on a public utility that serves customers within the municipality or that uses public property within the municipality to serve customers elsewhere; and (3) the issuance of a permit by the MPUC for the construction of a gas pipeline does not preempt pursuant to Minn. Stat. 216G.02 a municipal ordinance requiring a franchise for the operation of the pipeline after construction is complete.

In district court, appellant was convicted of aiding and abetting first-degree premeditated murder. At issue was whether the district court erred when it denied appellantâs pretrial motion to suppress statements made to law enforcement officials after appellant allegedly invoked his state and federal constitutional rights to remain silent and to have counsel present during custodial interrogation. The Supreme Court affirmed, holding (1) an invocation of the right to remain silent is ambiguous if the suspectâs statement could be interpreted as either a general refusal to answer any questions or as an expression of unwillingness to discuss a specific topic, and (2) when a suspect makes an equivocal invocation of the right to counsel, providing the suspect with a Miranda warning is sufficient as a matter of law to satisfy Minnesotaâs âstop and clarifyâ rule.

Appellant Dario Bonga pled guilty to first-degree premeditated murder less than one day after he confessed to killing Carlos San Miguel and attempted to kill himself while in custody awaiting trial. The district court accepted Appellantâs guilty plea, convicted him, and sentenced him to life in prison. Appellant filed a petition for post conviction relief in which he sought to withdraw his guilty plea, arguing that he was not competent to plead guilty. On appeal to the Supreme Court, Appellant argued that the district court did not give sufficient weight to evidence that suggested he was incompetent to plead when it sentenced him to life. Particularly, Appellant argued that the court should have ordered an examination and report on Appellantâs mental condition when it learned that Appellant attempted suicide the day before the hearing. The Supreme Courtâs review of the record revealed that on several occasions Appellant was offered counsel, dismissed counsel, sought to speak with the prosecutors, and asked to represent himself at trial. The record would also reveal that the trial court asked Appellant multiple times, on the record, whether he understood the nature of the charges against him and whether Appellant understood the risk he ran by representing himself. The Court was satisfied that the trial court gave Appellant every opportunity to seek counsel and preserve his legal rights. Finding no error, the Supreme Court affirmed Appellantâs conviction and sentence.

Appellants Bruce and Cindy Thompson filed a claim for basic economic loss benefits against their insurer, Respondent Western National Insurance Company (Western National), arising from injuries they sustained in an automobile accident. Western National paid some benefits, but a dispute arose over the Thompsonsâ obligation to submit to examinations requested by Western National. The Thompsons filed for no-fault arbitration, and Western National moved to stay the arbitration in order to seek a declaratory judgment in the district court. The arbitrator entered awards in favor of the Thompsons. In court, Western National moved for summary judgment, and the Thompsons moved to confirm their awards. The district court denied Western Nationalâs motion and confirmed the awards, concluding that the reasonableness of the Thompsonsâ refusal to attend the examinations was an issue handled by the arbitrator. The appellate court reversed, concluding that the examination question was a question of law for the court to decide. The Supreme Court reversed the appellate court, holding that the examination issue was a question of fact for the arbitrator. The Court reinstated the arbitration awards in favor of the Thompsons.

Respondents Dr. Rajbir Sarpal and his wife Carol purchased a parcel of property in 2003 on which they built their home. The property was encumbered by two easements reserved by the City of North Oaks for a future trail. The Sarpals wanted a shed on their property, and in 2006, went to the City to obtain the necessary permits. A City employee gave Dr. Sarpal an "as-built" survey in order to obtain the necessary permits, but the survey was dated to a time before the Sarpals' home was built. Dr. Sarpal, acting as his own general contractor, drew up the plans, submitted them to the requisite authorities, and built the shed on his property. He would later find out that the shed encroached on the City's two easements. Dr. Sarpal petitioned the local zoning board for a variance in order to save the shed, but was denied. The City sued to have the shed removed. The court dismissed all of the City's claims, holding that because the Sarpals relied on the survey given to them by the City, the City was equitably estopped from suing for the easements now. The appellate court affirmed the lower court's decision. The Supreme Court held that when a government entity makes a "simple mistake" when providing a document to a party upon which the party relies to obtain building permits and the government approves that permit, the mistake is not wrongful conduct sufficient to support the conclusion that the government is equitably estopped from enforcing its zoning ordinances.

Eden Prairie Mall (EPM) challenged the assessed value determinations of one of its anchor tenants. For the tax years 2005 and 2006, the court concluded that the market values of EPM and the tenant should have been assessed at higher rates than the assessments that were entered into evidence at trial. EPM argued that the tax court's valuations were excessive and not supported by the record. EPM filed for bankruptcy during the tax court proceedings and subsequently argued that the tax court violated the automatic stay provision of the bankruptcy code when the court increased its taxes. Upon review, the Supreme Court found that the tax court's reassessment did not violate the automatic stay of the bankruptcy code, but that the record did not support the reassessments. The Court reversed the tax court's holding, and remanded the case for further proceedings.

D.T.R., a minor, was born in 2004 to Lynette Marthe and her then-husband Derek Reiter. At the time, both believed Reiter was D.T.Râs biological father. However, in 2007, genetic testing would prove that Michael Richards was D.T.R.âs biological father. In 2008, Richards sought joint legal custody of D.T.R., and named Marthe and Reiter as parties. Before trial, the parties stipulated paternity, but could not agree who should be deemed D.T.R.âs âlegalâ father. The case proceeded to trial in 2009. While the paternity suit was pending, Marthe and Reiter had filed for divorce. In 2010, the district court filed detailed and thorough findings of fact and conclusions of law, and issued an order that concluded that a parent-child relationship existed between Reiter and D.T.R., and adjudicated Reiter as the childâs âlegalâ father. Marthe appealed the courtâs determination of paternity, but Richards did not. The appellate court questioned Martheâs standing to appeal the dismissal of Richardsâ petition. After additional briefing on the issue, the appellate court dismissed Martheâs appeal. On appeal to the Supreme Court, Marthe argued that she had standing to appeal as an aggrieved party pursuant to the applicable state case law and the Minnesota Parentage Act. Reiter asserted that Marthe did not have standing because her rights were not affected by the judgment adjudicating paternity. According to Reiter, Martheâs rights would be affected when her individual interests were at stake, such as a decision determining custody, parenting time or child support. The Supreme Court concluded that Marthe had standing to appeal as an aggrieved party the district courtâs determination of D.T.R.âs paternity. The Court reasoned that the determination of paternity directly impacted her responsibility for child support and her rights related to child support. The Court reversed the appellate courtâs holding, and remanded the case for further proceedings.

The issue for the Supreme Court to resolve in this case stems from the arrest of Appellant Brian Hester. Appellant was arrested by a Lower Sioux Indian Community Police officer on DWI charges. The temperature was between 10 and 15 degrees below zero at the time the Lower Sioux officer stopped Appellant. Appellant was transferred to a local jail for further tests to determine the level of Appellantâs impairment. After completing the field sobriety tests at the jail, the officer placed Appellant under arrest. Appellant was advised that refusing to submit to further testing would constitute a crime. Appellant refused and was charged with first-degree driving while impaired, and first-degree test refusal. A jury found Appellant guilty of only the test-refusal charge. Appellant sought to vacate the judgment, claiming that the arresting officer was not a âpeace officerâ as defined by state law. Appellate courts found that the officer was indeed a police officer, and had the authority to require Appellant to take the subsequent tests. On further review, the Supreme Court found that the Lower Sioux were not in compliance with state law requiring them to carry the correct liability insurance limits at the time Appellant was arrested. The lack of liability insurance undermined the officerâs authority to request that Appellant take the subsequent chemical tests. Accordingly, the Supreme Court vacated Appellantâs conviction for criminal test refusal.