Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing in part and affirming in part the district court's grant of summary judgment for Defendant, a school district, in this employment dispute, holding that summary judgment was properly granted on all of Plaintiff's claims.Plaintiff brought this action alleging that the suffered a hostile work environment and disparate treatment culminating in constructive discharge during her employment with Defendant. The district court granted Defendant's motion for summary judgment on both claims. The court of appeals reversed in part, concluding that Plaintiff had "presented sufficient evidence of disparate-treatment age discrimination to withstand summary judgment[.]" The Supreme Court reversed in part, holding that Plaintiff established a genuine issue of material fact as to whether she suffered an adverse employment action in the form of constructive discharge. View "Henry v. Independent School District #625" on Justia Law

In this dispute over Governor Walz's declaration of a peacetime emergency under the Emergency Management Act, Minn. Stat. 12.01-.61, and the executive order the Governor issued requiring that Minnesotans wear face coverings, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals dismissing the appeal as moot, holding that one issue on appeal met a mootness exception.Plaintiffs brought the underlying petition for a writ of quo warranto challenging the face-covering mandate, arguing that the Governor overstepped his powers under the Emergency Management Act and that the mask mandate violated several of their constitutional rights. The district court granted Defendants' motion to dismiss. While Plaintiffs' appeal was pending, the peacetime emergency and mask mandate ended. Consequently, the court of appeals dismissed the appeal as moot. The Supreme Court reversed in part, holding (1) the legal question of whether the Act authorizes a peacetime emergency for a public health emergency is functionally justiciable and an important issue of statewide significance that should be decided immediately; and (2) Plaintiffs' remaining challenges to the mask mandate did not meet any of the mootness exceptions. View "Snell v. Walz" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the district court dismissing this complaint brought by patients (collectively, Patients) in the Minnesota Sex Offender Program (MSOP), holding that the district court erred.Patients were ordered by the Minnesota Commitment Appeals Panel (CAP) to be transferred to Community Preparation Services (CPS), which would have been a reduction in custody. CAP issued Patients' transfers orders, but the orders did not provide a specific date by which the transfers to CPS should occur. State officials did not transfer Patients, and about two years after the transfer orders were issued Patients filed petitions for a writ of mandamus demanding that the transfers be effectuated. The state officials filed motions to dismiss, arguing that qualified immunity shielded them from liability. The district court granted the motions to dismiss, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the state officials had a clear obligation to execute the CAP transfer orders within a reasonable period of time; and (2) remand was required. View "McDeid v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Defendant's second petition for postconviction relief, holding that the district court did not abuse its discretion in denying the petition without holding an evidentiary hearing.After a jury trial, Defendant was found guilty of first-degree felony murder and attempted first-degree premeditated murder, among other crimes. Defendant later filed the postconviction petition at issue, asserting that he was denied his Sixth Amendment right to a trial before an impartial jury and that his trial counsel and appellate counsel provided ineffective assistance. The district court summarily denied the petition as time barred and procedurally barred. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Defendant's second postconviction petition as untimely. View "White v. State" on Justia Law

The Supreme Court held that the district court did not abuse its discretion when it summarily denied Appellant's eighth petition for postconviction relief as untimely.Appellant was convicted of first-degree premeditated murder under an aiding and abetting theory of liability. In his eighth petition for postconviction relief, Appellant invoked the time-bar exception for newly discovered evidence, relying on an affidavit of one of his codefendants. The district court summarily denied the petition as untimely based on its determination that the statements in the affidavit were not newly discovered. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Appellant's postconviction petition. View "El-Shabazz v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion under Minn. R. Civ. P. 60.02 to vacate the denial of his first postconviction petition and the district court's denial of his second postconviction petition, holding that the district court did not abuse its discretion by denying Appellant's motion and second petition.Defendant was found guilty of first-degree premeditated murder, first-degree aggravated robbery and other crimes. The district court imposed a life sentence without the possibility of parole. The Supreme Court affirmed on appeal and also affirmed the denials of Defendant's first postconviction petition and his motion to correct his sentence. At issue on this appeal was the district court's denial of his motion to vacate the denial of his first postconviction petition and the denial of his second postconviction petition. The Supreme Court affirmed, holding that Defendant's claims were time-barred under the postconviction statute. View "Blue Earth County v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Appellant's petition to withdraw his guilty plea under Minn. R. Crim. P. 15.05, subd. 1, holding that Appellant demonstrated that withdrawal was necessary to correct a manifest injustice.Appellant pleaded guilty to one count of first-degree felony murder during the commission of an aggravated robbery. The district court sentenced him to life imprisonment with the possibility of release after thirty years. Appellant subsequently filed his petition to withdraw his guilty plea, alleging that the plea colloquy did not establish an adequate factual basis for felony murder during the commission of an aggravated robbery. The postconviction court denied the petition. The Supreme Court vacated the judgment plea and remanded the case for trial on the charges pending when Defendant pleaded guilty, holding that there were insufficient facts to show that Appellant's conduct fell within the charge to which he pleaded guilty and that he must be allowed to withdraw his plea to avoid a manifest injustice under Minn. R. Crim. P. 15.05, subd. 1. View "Bonnell v. State" on Justia Law

The Supreme Court affirmed the ruling of Workers' Compensation Court of Appeals (WCCA) that Respondent was entitled to workers' compensation benefits, holding that Respondent was not entitled to relief on his claims on appeal.A licensed psychologist diagnosed Respondent, a former deputy sheriff for Carlton County, with post-traumatic stress disorder (PTSD). A compensation judge ruled that Respondent was not entitled to workers' compensation benefits because a subsequent psychological evaluation requested by the County resulted in a diagnosis of major depressive disorder but not PTSD. The WCCA reversed, holding (1) under Minn. Stat. 176.011, subd. 15(e), deputy sheriffs are entitled to a presumption that PTSD is an occupational disease if they present a diagnosis of PTSD, regardless of whether their employer offers a competing diagnosis; and (2) Respondent was entitled to the benefit of the presumption that he had a compensable occupational disease, and the County failed to rebut the presumption. View "Juntunen v. Carlton County" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder, attempted first-degree premeditated murder, and kidnapping, holding that any error in the proceedings below was harmless.Specifically, the Supreme Court held (1) any error on the part of the district court in failing to hold a hearing on the foundational reliability of cell-site location information (CSLI) evidence was harmless, and the district court was not required to hold a hearing to determine whether the CSLI evidence was generally accepted in the relevant community; (2) the district court did not err in trying Defendant's and his codefendant's cases together; and (3) Defendant was not prejudiced by the district court's denial of his request for an additional peremptory challenge. View "State v. Berry" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder, attempted first-degree murder, and kidnapping, holding that there was no error in the proceedings below.On appeal, Defendant argued, among other things, that the district court erroneously joined his and his codefendant's cases for trial and by denying subsequent severance motions. The Supreme Court affirmed his convictions, holding (1) the district court did not improperly join Defendant's and his codefendant's cases for trial and did not erroneously refuse to sever the cases once the trial was underway; (2) the prosecutor did not commit misconduct during closing arguments; and (3) Defendant was not entitled to relief as to the claims he raised in a pro se supplemental brief. View "State v. Davis" on Justia Law