Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree arson under Minn. Stat. 609.561, subd. 1, holding that the evidence provided at trial was sufficient to support Defendant's conviction.On appeal, Defendant argued that the word "unlawfully" in the first-degree arson statute created an element of the offense that the State must prove beyond a reasonable doubt and that the State failed establish all of the elements of his crime by failing to present evidence to show that the burning of his house was "unlawful." The court of appeals affirmed the conviction. The Supreme Court affirmed, holding (1) under section 609.561, the State must prove that a person set a fire in a manner not authorized by law as an element of first-degree arson; and (2) the trial court failed properly to instruct the jury, but there was no reasonable likelihood that the jury would have reached a different result had it been properly instructed that the State was required to prove that Defendant started the fire unlawfully. View "State v. Beganovic" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that Minnesota Rule 8210.2450, subparts 2 and 3 (the rule) does not conflict with Minn. Stat. 203B.121 (the statute) and that the challenged rule was therefore invalid, holding that subpart 3 of the rule conflicted with subdivision 2(b)(3) of the statute.Appellants brought this declaratory judgment action seeking a prospective declaration that the administrative rule, which governed the acceptance of absentee ballots, was invalid because the rule subparts conflicted with the statute by infringing on discretion the legislature gave to ballot board members. The court of appeals determined that there was no conflict between the rule and the statute. The Supreme Court reversed in part, holding (1) Minn. R. 8210.2450, sub. 3, which authorized any ballot board member to review signatures in the event of an identification number mismatch, was invalid to the extent that the rule conflicted with Minn. Stat. 203B.121, subd.2(b)(3), which required that election judges conduct that review; and (2) the other challenged parts of the rule did not conflict with the statute. View "Minn. Voters Alliance v. Office of Minn. Secretary of State" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court declaring Appellant eligible to submit a petition seeking compensation based on exoneration under Minnesota's Incarceration and Exoneration Remedies Act, Minn. Stat. 611.362 to 611.368, holding that Appellant was not eligible for compensation based on exoneration.At issue was whether Appellant had established, by a fair preponderance of the evidence, that she was exonerated within the meaning of Minn. Stat. 590.11. The district court concluded that Appellant was eligible for compensation based on a finding of exoneration. The court of appeals agreed that Appellant was "exonerated" but remanded for the district court to determine a separate issue. The Supreme Court reversed, holding that Appellant was not eligible for compensation based on exoneration. View "Back v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that an unconstitutional provision in a proposed charter amendment was not severable, holding that the provision was not severable from the remainder of the proposed charter amendment.On August 8, 2022, the Bloomington City Council voted to reject the entirety of a proposed charter amendment based on its conclusion that the last of the proposed amendment's four sections, section 4.08, was manifestly unconstitutional. Appellants filed a petition seeking declaratory and injunctive relief to sever section 4.08 and submit the remaining valid provisions to voters. The district court denied the petition, concluding that it would be improper to sever section 4.08 from the remainder of the proposed charter amendment. The Supreme Court affirmed, holding that section 4.08 could not properly be severed from the proposed city-charter amendment. View "Kranz v. City of Bloomington" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversed the judgment of the district court denying Hennepin Healthcare System, Inc.'s motion to vacate an arbitration award in favor of AFSCME Minnesota Council 5, holding that the court of appeals erroneously substituted its own judgment for that of the arbitrator.Hennepin Healthcare and AFSCME, which represented two bargaining units of Hennepin Healthcare employees, arbitrated a dispute regarding Hennepin Healthcare's use of temporary staffing agency workers. The arbitrator issued an award in favor of AFSCME. The district court confirmed the award. The court of appeals reversed, concluding that because the arbitration award did not draw its essence from the collective bargaining agreement it must be vacated. The Supreme Court reversed, holding that Hennepin Healthcare failed to meet its burden to demonstrate that the arbitrator clearly exceeded the powers granted to him in the CBA because the award failed the essence test. View "Hennepin Healthcare System, Inc. v. AFSCME Minnesota Council 5, Union" on Justia Law

The Supreme Court affirmed the judgment of the Minnesota Tax Court, though its adjustments, increasing the market value of the real estate of the Minneapolis Hyatt Regency Hotel for the tax years 2016 through 2018, holding that when a county opposes discovery and the taxpayer moves to compel discovery, the balancing test found in Minn. Stat. 13.03, subdivision 6 is applicable.Relator, which owned the Hotel, challenged the market values assessed by the County of Hennepin for the tax years at issue, arguing that the tax court clearly erred when it accepted the appraisal report of Relator's expert but then made unsupported and unexplained adjustments to the expert's valuations. The Supreme Court affirmed, holding that the tax court (1) did not err or abuse its discretion in its discovery and evidentiary rulings; and (2) did not clearly err in adjusting Relator's valuation of the hotel real estate. View "1300 Nicollet, LLC v. County of Hennepin" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's petition for postconviction relief from his conviction for first-degree felony murder under an aiding and abetting theory of criminal liability, holding that Appellant's arguments did not entitle him to relief.In his petition for postconviction relief, Appellant claimed in part that he received ineffective assistance of trial counsel because counsel did not communicate an Alford plea deal to him. The district court denied the petition, concluding that Appellant failed to prove his claim by a preponderance of the evidence. The Supreme Court affirmed, holding that the evidence established beyond a reasonable doubt that Appellant committed first-degree felony murder under an aiding and abetting theory of criminal liability. View "State v. King" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Appellant's unjust enrichment award, holding that the district court did not clearly err in its award to Appellant.Over the course of the parties' romantic relationship Appellant made $282,736.02 in net cash payments to Respondent to renovate Respondent's home. Respondent sold her home for $1.2 million after the couple ended their relationship, and Appellant sued to recover his contribution. The district court awarded Appellant $282,736.02 for his contributions, concluding that Respondent had been unjustly enriched by Appellant's financial contributions. The court of appeals reversed because Appellant did not prove before the district court the increase in value to Respondent's home attributable to his financial contributions. The Supreme Court reversed, holding (1) the net amount of money that Appellant contributed directly to and on behalf of Respondent was an appropriate measure of relief for unjust enrichment; and (2) the district court did not clearly err in its award to Appellant. View "Herlache v. Rucks" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of fifth-degree possession of a controlled substance, holding that the search of Defendant's purse was constitutional under the automobile exception to the Fourth Amendment's search warrant requirement.Defendant, a passenger in a vehicle searched by law enforcement without a warrant, removed her purse from the car as she got out, but an officer directed her to leave the purse on the car. The officer's ensuing search of the purse revealed a controlled substance. Defendant filed a motion to suppress, arguing that the automobile exception did not apply because the purse was an extension of her person, not a container within the car. The district court denied the motion. The court of appeals affirmed the denial, concluding that the warrantless search of Defendant's purse was constitutional. The Supreme Court affirmed, holding that (1) the purse was a container that was inside the car at the time probable cause arose; and (2) because the purse could have contained marijuana, the officer was permitted to search it under the automobile exception. View "State v. Barrow" on Justia Law

The Supreme Court dismissed this appeal from the opinion of the court of appeals affirming the decision of the district court to grant a harassment restraining order (HRO) against Appellant, holding that Appellant's challenge to the HRO did not present a justiciable controversy because it was moot.The district court concluded that Appellant had engaged in repeated incidents of harassing conduct against Respondent and issued a six-month HRO. While Appellant's appeal was pending, the HRO expired. The court of appeals affirmed, and Appellant filed a petition for further review. The Supreme Court dismissed the appeal without reaching the merits, holding that Appellant's challenge to the HRO did not present a justiciable controversy because it was moot. View "Winkowski v. Winkowski" on Justia Law