Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the conclusions of the district court and court of appeals that Minn. Stat. 515B.2-118(b), a statute of limitations contained within the Minnesota Common Interest Ownership Act, applied to bar Appellant's claims in this case, holding that the lower courts erred.Appellant owned and operated a common interest community in Richfield that was registered under the Act in 2004. Following a repair project, Appellant sought commercial contributions from Respondent, who refused under the belief that its property interest had been severed from the community. Both parties brought actions seeking declarations as to whether Respondent was required to contribute to the repair project. Respondent cited an amended declaration, recorded in 2007, in arguing that it was not a member of the community and thus not responsible for contributions. The district court and court of appeals concluded that section 515B.2-118(b) applied to bar Appellant's claims. The Supreme Court reversed, holding that the statute of limitations contained in section 515B.2-118 for challenging the validity of an amendment or supplemental declaration does not bar an action that broadly challenges not the underlying validity of an amended declaration but whether severance occurred under the statute. View "City Bella Commercial, LLC v. City Bella on Lyndale" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the tax court that the taxable 2018 market value of a DoubleTree in Bloomington was $25,500,000, an amount that exceeded the valuations offered by the DoubleTree's owner and the County of Hennepin, holding that remand was required on a single issue.The County initially assessed the value of the DoubleTree property at $31,586,400, but Relator, the DoubleTree's owner, appealed the valuation to the tax court. After a trial, the tax court determined that the taxable 2018 market value of the DoubleTree was $25,500,000. The Supreme Court vacated the judgment in part and otherwise affirmed, holding that remand was required for the tax court to revisit and explain its adoption of the percentage reduction to the sales price of one of the hotels it used in its sales comparison analysis to account for non-taxable assets included in the sales price of comparator hotels. View "Bloomington Hotel Investors, LLC v. County of Hennepin" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and his sentence of life in prison without the possibility of release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confrontation when it admitted the victim's dying declarations into evidence during the jury trial, and this Court reaffirms that dying declarations are an exception to the Confrontation Clause; (2) the district court did not violate Defendant's Fifth Amendment right to counsel by denying Defendant's motion to suppress his statements to police officers because Defendant validly waived his invoked right to counsel; and (3) there was no reasonable possibility that the admission of Spreigl evidence related to a prior assault charge into evidence significantly affected the verdict. View "State v. Buchan" on Justia Law

The Supreme Court held that an action taken by the Minnesota Pollution Control Agency (MPCA) in issuing a National Pollutant Discharge Elimination System/State Disposal System permit was arbitrary and capricious and that the permit did not comply with a Minnesota rule addressing wastewater discharges to groundwater, Minn. R. 7060.0600, subp. 2.At issue was the MPCA's issuance of the permit for a Poly Met Mining, Inc. project. The court of appeals reversed in part, concluding that the MPCA failed properly to consider whether the federal Clean Water Act (CWA) applied to future discharges from Poly Met's facility to groundwater. The Supreme Court remanded the cause, holding (1) remand was required because there were suggestions that the MPCA did not properly consider whether the permit complies with the CWA and that the MPCA did not genuinely engage in reasoned decision-making; (2) remand was required for consideration of whether a variance was available to allow the planned discharge to the unsaturated zone within the containment system; and (3) the prohibition on injecting polluted water directly to the groundwater saturated zone for long-term storage did not apply in this case. View "In the Matter of the Denial of Contested Case Hearing Requests & Issuance of National Pollutant Discharge Elimination System" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Defendant's motion for a new trial, holding that the record was insufficient to determine whether Defendant's right to a public trial was violated due to restrictions put in place by the district court arising from the COVID-19 pandemic.In December 2019, Defendant was charged with first-degree aggravated robbery. Because of the restrictions placed on trials due to the pandemic the county submitted a trial plan that excluded all spectators from the courtroom but included a one-way video feed that would broadcast the trial in an adjacent courtroom. The trial court overruled Defendant's objection, and the trial proceeded. After Defendant was convicted he moved for a new trial. The court of appeals denied the motion. The Supreme Court reversed, holding that additional findings were required on the decision to close the courtroom before it could be determined whether Defendant's public trial right was violated. View "State v. Bell" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress statements recorded on a body-worn camera, holding that the district court did not abuse its discretion in determining that the statements should be suppressed.In response to a domestic disturbance 911 call law enforcement officers found A.H. locked out of her apartment while Defendant was inside, and A.H. told the officers that Defendant had assaulted her both in the present and in the past. These statements were recorded by an officer's body-worn camera. Defendant was subsequently charged with one count of misdemeanor domestic assault. The district court granted Defendant's motion to suppress the body-worn camera recording on the grounds that their admission would violate Defendant's constitutional right to confrontation. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in determining that A.H.'s statements did not qualify as excited utterances under Minn. R. Evid. 802(2); and (2) properly suppressed the statements as inadmissible hearsay. View "State v. Tapper" on Justia Law

The Supreme Court reversed Defendant's conviction of first-degree premeditated murder and second-degree intentional murder following a jury trial, holding that the district court erred in entering a conviction for the lesser-included offense of second-degree intentional murder.After the trial, the district court entered judgment of convictions for both first-degree and second-degree murder but only imposed a sentence for the first-degree murder conviction. The Supreme Court held (1) the evidence was sufficient to prove the element of premeditation for the first-degree murder offense; (2) assuming, without deciding, that the district court erred by failing to identify a certain individual as an accomplice, the failure did not affect Defendant's substantial rights; (3) the district court did not commit any other reversible error in managing the trial and the jury instructions; and (4) the entry of a judgment of conviction for the second-degree intentional murder offense violated Minn. Stat. 609.04, subd. 1. View "State v. Gilleylen" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's second petition for postconviction relief, holding that Appellant was not entitled to relief on his allegations of error.After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and the denial of Appellant's initial petition for postconviction relief. Thereafter, Appellant filed another postconviction petition. The postconviction court summarily denied the petition and denied Appellant's motion to compel discovery. On appeal, Appellant argued, among other things, that his appellate counsel provided ineffective assistance. The Supreme Court affirmed, holding that Appellant was conclusively entitled to no relief. View "Allwine v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court ruling that an alternative residuary clause in a will devising half of the testator's estate to his heirs-at-law and the other half to his wife's heirs-at-law failed as a matter of law, holding that the devise failed as a matter of law.The testator's will in this case named his wife, if she survived him, as the primary beneficiary of the residue of his estate with an alternate residuary clause devising one-half of the estate to his wife's "heirs-at-law." The couple's marriage was later dissolved, after which the testator died without having revised his will. When Appellant, the personal representative of the testator's estate, petitioned for formal probate of the will he identified only the testator's siblings as heirs and devisees. Respondents, the wife's parents, claimed that they were wrongfully omitted as devisees in the petition. The district court ruled that any purported devise to Respondents failed as a matter of law. The court of appeals reversed. The Supreme Court reversed, holding that a gift to a spouse's heirs, none of whom are identified by name, fails if the marriage dissolves after execution of the will. View "In re Tomczik" on Justia Law

The Supreme Court affirmed the determination of the court of appeals, but on different grounds, determining that two amendments to the grantor's trust were validly executed and that the district court had properly reformed the trust, holding that the district court properly struck the part of the second trust amendment that was ambiguous and unenforceable.The Grantor in this case validly executed the trust, which was properly witnessed and notarized, and then executed two amendments that significantly increased the amount that Respondent would inherit. After the Grantor died, Appellant moved to invalidate the amendments. The district court granted the motion in part and struck a portion of the second trust amendment due to ambiguity but upheld the remaining terms of the amendment, including the increased amount inherited by Respondent. The court of appeals affirmed, holding that the amendments were validly executed and properly reformed under Minn. Stat. 501C.0415. The Supreme Court affirmed on other grounds, holding (1) the second trust amendment was validly executed; and (2) the district court properly upheld the portions of the second trust amendment governing asset distribution. View "In re Trust of Moreland" on Justia Law