Justia Minnesota Supreme Court Opinion Summaries

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

After meeting with Robert Swendra, an insurance agent selling American Family Insurance products, Curtis Graff purchased an automobile policy and an umbrella policy. Based on Swendra's representations, Graff wrongfully believed the umbrella policy contained $1 million in underinsured motorist (UIM) coverage. Later, Graff injured his back in a car accident with an underinsured motorist. Graff filed a complaint alleging breach of contract against American Family and negligent procurement of insurance coverage against the Swendra Agency. After Graff entered into a settlement agreement with American Family Graff's contract claim against American Family was dismissed, and the negligence claim against the Swendra Agency proceeded to trial. The jury found Swendra Agency liable and awarded damages. Pursuant to the collateral source statute, the district court reduced the damages award by $200,260. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the court of appeals did not err in finding that Graff's release of American Family did not extinguish Graff's claim against the Swendra Agency, and (2) the district court properly excluded the attorney fees paid to Graff's counsel from the collateral source calculation. View "Graff v. Robert M. Swendra Agency, Inc." on Justia Law

After a jury trial, appellant Justin Buckingham was convicted of attempted first-degree premeditated murder and attempted first-degree drive-by-shooting murder. The Supreme Court affirmed appellant's convictions but modified his sentence. Appellant subsequently filed a petition for postconviction relief, asserting that the district court admitted his statements to police in violation of his constitutional rights, his court-ordered psychological evaluation was incomplete, the district court gave the jury an erroneous accomplice liability instruction, and his trial counsel was ineffective. The district court denied Buckingham's petition for relief without a hearing, rejected Buckingham's claims on the merits, and held that most of Buckingham's claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding the district court did not abuse its discretion when (1) it held that Buckingham's claims were barred under Knaffla, and (2) it denied appellant an evidentiary hearing because the records of the proceeding conclusively showed that Buckingham was not entitled to postconviction relief. View "Buckingham v. State" on Justia Law

Appellant Clemmie Tucker pleaded guilty to second-degree unintentional felony murder. Under the terms of the plea agreement, the district court sentenced Tucker to 225 months in prison. The sentence represented an upward durational departure from the presumptive sentencing range of 128 to 180 months for a defendant convicted of second-degree unintentional murder with Tucker's criminal history score. Tucker filed a petition for postconviction relief in which he claimed the sentencing court abused its discretion when it imposed an upward departure based on particular cruelty to his victim. The court of appeals affirmed the denial of postconviction relief on the ground that Tucker's failure to render aid to his victim constituted particular cruelty. On review, the Supreme Court reversed, holding that the sentencing court's reason for departure was improper. Permitting an upward departure under the circumstances of the case failed to apply the plain meaning of the phrase "particular cruelty" and disregarded the fundamental requirement permitting sentencing departures only when a defendant's conduct in the commission of an offense is significantly more serious than that typically involved in the commission of the offense in question. Remanded. View "Tucker v. State" on Justia Law

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.