Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's second petition for postconviction relief as time-barred because Appellant's postconviction claim failed to satisfy the newly discovered evidence or the interests of justice exceptions, holding that the district court did not abuse its discretion.Defendant was convicted of premeditated first-degree murder following a jury trial. Defendant later brought this postconviction petition asserting that the State committed a Brady violation when it failed to disclose this exculpatory information before his trial. The district court summary denied the petition as time-barred. The Supreme Court affirmed, holding that because Defendant's claims did not satisfy the newly discovered evidence or the interests of justice exceptions the district court properly denied Defendant's second postconviction petition as untimely. View "Blanche v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree premeditated murder and attempted second-degree murder, holding that any error in the underlying proceedings was harmless.In its written findings of fact, the trial court made a finding related to Defendant's defense that was unsupported by the record concerning business closures at the beginning of the COVID-19 pandemic and used this finding as part of its assessment of Defendant's credibility. The Supreme Court affirmed, holding (1) the district court's pandemic-related finding did not require a new trial under any of the impartiality tests; and (2) the district court's failure to consider the lesser-included offense of second-degree unintentional felony murder in its deliberations was harmless. View "State v. Lopez" on Justia Law

The Supreme Court affirmed the judgment of the workers' compensation court of appeals (WCCA) affirming the findings and conclusions of the compensation judge determining that Employee was entitled to workers' compensation benefits because of her Gillette injury, holding that the WCCA's affirmance of the compensation judge's findings was not manifestly contrary to the evidence.Employee filed a claim petition alleging that she sustained a Gillette injury and sought workers' compensation benefits. The compensation judge ordered Employer to pay Employee benefits. The WCCA affirmed. The Supreme Court affirmed, holding that the WCCA's findings, including the date Employee's injury occurred, when Employee was required to notify Employer of her injury, and the calculation of Employe's post-injury earning capacity, were not manifestly contrary to the evidence. View "Schmidt v. Wal-Mart Stores, Inc." on Justia Law

The Supreme Court affirmed the judgments of the tax court declining to include a "concession fee" as rental income attributable to the properties in this case under the income-capitalization approach to property valuation, holding that the tax court did not err.At issue was Hennepin County's valuation of the respective properties owned by Enterprise Leasing Company of Minnesota and Avis Budget Car Rental, LLC at the Minneapolis-St. Paul International Airport. The tax court disagreed with Hennepin County's approach, decided not to include the concession fee as rental income, and estimated a market value in each case that was lower than the value that the County sought at trial. The Supreme Court affirmed in both cases, holding that the tax court did not clearly err in excluding the concession fee from rental income. View "Enterprise Leasing Co. of Minn. v. County of Hennepin" on Justia Law

In this appeal arising out of the application of a provision of the Minnesota Workers' Compensation Act known as the "assault exception" the Supreme Court held that the assault exception applied and that Relator Deangelo Profit was not entitled to recover workers' compensation benefits under the circumstances of this case.Profit suffered serious injuries when he was attacked at his job site by a mentally ill acquaintance while he was performing his work injuries. Profit sought workers' compensation benefits under Minn. Stat. 176.021, subd. 1, which are to awarded in cases "of personal injury or death of an employee arising out of and in the course of employment." The Workers' Compensation Court of Appeals concluded that Profit was not entitled to recover benefits under the assault exception. The Supreme Court affirmed, holding that the assault exception did not apply where the assailant "intended to injure [Profit] because of personal reasons" and his acts were "not directed against the employee as an employee, or because of the employment." View "Profit v. HRT Holdings" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court granting summary judgment ruling that the public's interest in an undeveloped road dedicated to public use by plat over 100 years ago had been extinguished by operation of the Marketable Title Act (MTA), Minn. Stat. 541.023, holding that the district court erred.On appeal, the Minnesota Department of Natural Resources and Itasca County argued that the lower courts erred in ruling that the MTA does not apply to roads dedicated to public use by plat. The Supreme Court agreed and reversed, holding that the MTA does not operate to extinguish public interests properly dedicated by plat. View "In re Application of Moratzka" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals in this criminal case and vacated both of Defendant's convictions for two marijuana-related fifth-degree controlled substance offenses, holding that the evidence was insufficient to support the convictions.One of Defendant's convictions was based on Defendant's alleged possession of approximately three pounds of plant material that the State asserted was marijuana, and the other conviction was based on Defendant's alleged possession with intent to sell one or more vaporizer cartridges filled with a liquid mixture containing THC. The court of appeals (1) reversed Defendant's conviction for possession of the plant material on the grounds that a 2019 amendment to the definition of marijuana in Minn. Stat. 152.01, subd. 9 explicitly excluded "hemp"; and (2) upheld Defendant's second conviction. The Supreme Court reversed in part, holding that the court of appeals (1) properly held that the State did not present sufficient evidence to prove that the plant material possessed by Defendant was marijuana as defined by the amended statute; but (2) erred in concluding that the State presented sufficient evidence to prove that the liquid mixture in the vaporizer cartridges was a prohibited schedule I controlled substance. View "State v. Loveless" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the restitution order issued by the district court in Defendant's criminal case, holding that Minn. Stat. 611A.045, subd. 3(a) imposes no burden on the State to prove a defendant's income, resources, and obligations.Defendant pleaded guilty to second-degree unintentional felony murder. As part of his sentence, the district court ordered him to pay $7,500 in restitution for the victim's funeral expenses. Defendant filed a motion to relieve his restitution obligation, arguing that under section 611A.045, subd.1(a)(2) a district court is required to consider the defendant's income, resources, and obligations. The district court denied the motion. The court of appeals affirmed, concluding that the State does not bear the burden of producing evidence of or proving a defendant's ability to pay restitution. The Supreme Court affirmed, holding that the State's statutory burden under Minn. Stat. 611A.045, subd.3(a) does not require the State to prove that the defendant is able to pay restitution based on his or her income, resources, and obligations. View "State v. Cloutier" on Justia Law

The Supreme Court remanded this criminal case to the court of appeals for a decision on the merits, holding that the State can appeal the dismissal of the charges against Defendant under Minn. R. Crim. P. 28.04, subdivision 1(1).After the State charged Defendant with second-degree criminal sexual conduct he filed a motion to dismiss for lack of probable cause. The district court granted the motion and dismissed the complaint. The State appealed. The court of appeals dismissed the appeal, concluding that the district court's order was not appealable under Minn. R. Crim. P. 28.04. The Supreme Court reversed and remanded the case for the merits, holding that the district court's order was appealable because the dismissal was not premised solely on a factual determination. View "State v. Gray" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Appellant's request for postconviction relief, holding that the State presented sufficient evidence to support the jury's guilty verdict of possession of shoplifting gear under Mo. Rev. Stat. 609.521(b).Appellant was detained by police after employees from a retail clothing store called the police with suspicions that Appellant was shoplifting. A search revealed pieces of aluminum foil in Appellant's possession, some of which were wrapped around security sensors attached to items of unpurchased merchandise. A jury found Appellant guilty of violating section 609.521(b). Appellant filed a petition for postconviction relief, arguing that the foil was not "an instrument designed to assist in shoplifting or defeating an electronic article surveillance system under the possession of shoplifting gear statute. The district court denied relief, and the court of appeals affirmed. The Supreme Court affirmed, holding that the evidence presented at trial was sufficient to support Appellant's conviction. View "Douglas v. State" on Justia Law