Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals upholding the district court's award of attorney fees based on conduct that occurred outside the context of litigation, holding that the district court exceeded the scope of its inherent authority when it awarded attorney fees.In this case arising from a post-dissolution, mediated settlement agreement between Appellant and Respondent regarding the treatment of a college savings account. The agreement required that the account be awarded to the parties' daughter when she turned twenty-one years old, but when their daughter reached that age Appellant took no action to transfer the account. Ultimately, after intervention on the part of the district court, the transfer became effective. Respondent moved for conduct-based attorney fees under Minn. Stat. 518.14. The district court granted the motion.. The court of appeals affirmed. The Supreme Court reversed, holding that the district court exceeded the scope of its inherent authority in awarding attorney fees because the award was not necessary to the performance of a judicial function. View "Buckner v. Robichaud" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9, holding that Appellant's sentence of life imprisonment was mandated by Minn. Stat. 609.185(1).Appellant pleaded guilty to an amended count for first-degree intentional murder while committing a kidnapping and second-degree intentional murder. The district court ultimately convicted Appellant of first-degree premeditated murder and dismissed the second-degree murder count. In this action arising from Defendant's third motion to correct his sentence Defendant argued that the district court violated his due process right by sentencing him to a longer sentence than that recommended in the sentencing worksheet completed for the charge of second-degree murder. The district court concluded that the failure to file a sentencing worksheet for the charge of first-degree murder does not cause a defendant's sentence to be unauthorized or a defendant's due process rights to be violated. The Supreme Court affirmed, holding that there was no error. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant's motion to dismiss Plaintiff's action brought under 42 U.S.C. 1983 alleging that Minnesota's continuing predatory-offender registration requirements violated his rights under the federal and state constitutions, holding that there was no error.More than a decade after he pleaded guilty to second-degree assault and was required to register as a predatory offender under Minn. Stat. 243.166, subd. 1b Plaintiff brought this action. The district court concluded that the statutory limitations period of six years under Minn. Stat. 541.05, subd. 1(5) barred Plaintiff's section 1983 claims and that the continuing-violation doctrine does not apply to predatory-offender registration requirements. The court of appeals affirmed. The Supreme Court affirmed, holding that the continuing-violation doctrine did not toll the statute of limitations for Plaintiff's claims. View "Franklin v. Evans" on Justia Law

In this case stemming from a dispute involving an insurance claim the Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court dismissing, with prejudice, Plaintiff's complaint under Minn. R. Civ. P. 5.04(a) on the grounds that the complaint was not filed within one year of service, holding that Plaintiff satisfied Rule 5.04(a).Plaintiff served Defendant with a summons and complaint but did not file the summons and complaint with the district court at that time. Later, Plaintiff filed a copy of the summons and complaint but did not file the summons and complaint as a standalone document until more than one year after it had served Defendant. The district court dismissed the case with prejudice under Rule 5.04(a). The court of appeals reversed. The Supreme Court affirmed, holding (1) filing an "action" under Rule 5.04(a) refers to filing the summons and complaint; and (2) Plaintiff satisfied Rule 5.04(a) when it filed a copy of the summons and complaint as an exhibit in an ancillary motion pertaining to the same action. View "Glen Edin of Edinburgh Ass'n v. Hiscox Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals determining that the juvenile court had subject-matter jurisdiction over this case, rejecting Father's statutory interpretation argument about the interplay between the child protection and predatory offender registration statutes, and affirming the termination of Father's parental rights by the juvenile court, holding that Father was not entitled to relief on his claims of error.While Father was incarcerated for an offense that arose out of the same circumstances as an offense enumerated in the predatory offender registration statute Mother gave birth to H.Q., who was adjudicated as a child in need of protection or services. The juvenile court terminated Father's parental rights to H.Q. because of his conviction. The court of appeals affirmed the juvenile court's termination of Father's parental rights. The Supreme Court affirmed, holding that the juvenile court did not err in determining that clear and convincing evidence supported the statutory ground for termination in Father's case. View "In re Welfare of Child of S.B.G." on Justia Law

The Supreme Court reversed the decision of the court of appeals dismissing an administrative appeal for lack of appellate jurisdiction in the underlying case involving an air emissions permit issued by the Minnesota Pollution Control Agency for the NorthMet mining project in northern Minnesota, holding that the service and other steps taken by Appellants were effective to invoke appellate jurisdiction and that the appeal was timely-filed under the thirty-day service deadline set forth in Minn. Stat. 14.63.After the Agency issued the permit at issue to Poly Met Mining, Inc., Appellants filed a certiorari appeal. The court of appeals granted PolyMet's motion to dismiss the appeal for lack of jurisdiction on the ground that Appellants had failed to serve PolyMet's counsel within thirty days of receiving the decision. At issue before Supreme Court was whether the service requirements in the judicial review provisions of the Minnesota Administrative Procedure Act, Minn. Stat. 14.63-.69, require petitioners to serve appeal papers on a represented party's counsel. The Supreme Court reversed, holding that, when initiating judicial review where the parties were otherwise served directly, the Act's judicial review provisions do not require service on a represented party's attorney. View "In re Issuance of Air Emissions Permit No. 13700345-101 for PolyMet Mining Inc." on Justia Law

The Supreme Court affirmed the judgment of the Minnesota Tax Court reducing the Commissioner of Revenue's valuations of CenterPoint Energy Minnegasco's natural gas distribution pipeline system for January 2, 2018 through January 2, 2019, holding that the Commissioner was not entitled to relief.The tax court reduced the Commissioner's valuations and ordered the Commissioner to recalculate Minnegasco's tax liability. The Commissioner appealed, challenging the tax court's income-equalization and cost approaches. The Supreme Court affirmed, holding that the tax court (1) did not err in the way that it used the Commissioner's initial assessments when evaluating the totality of the evidence and making its independent evaluations; (2) did not abuse its discretion in considering the conflicting expert opinions; and (3) did not clearly err in finding external obsolescence. View "Commissioner of Revenue v. CenterPoint Energy Resources Corp." on Justia Law

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