Justia Minnesota Supreme Court Opinion Summaries

In 1998, a husband and wife established separate family trusts, naming their three adult children as beneficiaries. Upon the death of the last surviving parent in 2016, their son became the sole trustee, responsible for managing the trusts and eventually distributing the assets equally among the siblings after seven years. The principal asset was agricultural land, and the trust agreements gave the son an option to purchase this property within sixty days of the last parent’s death. However, he did not exercise this option until 2022, shortly before the trusts were set to terminate, and purchased the property from the trusts for over $2 million, funding the purchase with mortgage loans.The son’s sisters filed a petition in the Minnesota District Court, alleging that he breached his duties as trustee by improperly exercising the purchase option and seeking his removal, restoration of the property to the trusts, and other relief. The district court found that the purchase option had lapsed sixty days after their father’s death, and that the son had breached his fiduciary duties. The court ordered the son’s removal as trustee, appointed one sister as successor trustee, and directed the son to return the property to the trusts. The court also ordered further investigation into possible reimbursements and scheduled ongoing review hearings, reserving some issues for later determination.The Minnesota Court of Appeals dismissed the son’s interlocutory appeal as premature, finding that the district court’s order was not immediately appealable under Minnesota Rule of Civil Appellate Procedure 103.03(b), which allows appeals from orders granting or denying injunctions. The Minnesota Supreme Court affirmed, holding that the district court’s order was neither an injunction nor the functional equivalent of one, and thus not subject to immediate appeal under Rule 103.03(b). The Supreme Court clarified that statutory remedies under the Trust Code, such as removal of a trustee or restoration of property, do not constitute injunctions for appellate purposes. View "In re Johnson Trust" on Justia Law

A group of related companies, including a pharmacy benefit manager (HPS), filed a combined Minnesota corporate franchise tax return for the 2016 tax year. HPS provided pharmacy benefit management services to a health insurance company (HIC), which is headquartered in Wisconsin but has plan members in multiple states, including Minnesota. Initially, the companies attributed receipts from HPS’s services to Minnesota based on the number of HIC plan members who filled prescriptions in the state. Several years later, they amended their return to attribute all such receipts to Wisconsin, arguing that the services were received by HIC at its headquarters, and sought a refund of over $800,000.The Minnesota Department of Revenue denied the refund claim, concluding that the original method—attributing receipts to the state where the plan members received services—was correct. The companies appealed, and the case was transferred to the Minnesota Tax Court. Both parties moved for summary judgment, stipulating that all receipts at issue should be sourced together, either to Minnesota or Wisconsin. The Tax Court granted summary judgment to the Commissioner, holding that the statutory term “received” was not limited to the direct customer (HIC), and that the services were received in Minnesota by HIC plan members.The Minnesota Supreme Court reviewed the case. It held that under Minnesota Statutes section 290.191, subdivision 5(j), the term “received” is not limited to the direct customer, but can include a customer’s customer. The Court found that HPS’s services were received both by HIC in Wisconsin and by HIC plan members in Minnesota. Because the taxpayer failed to prove that all services were received outside Minnesota, and the parties had stipulated to an all-or-nothing sourcing, the Tax Court did not err in granting summary judgment to the Commissioner. The Supreme Court affirmed the Tax Court’s decision. View "Humana MarketPoint, Inc. v. Commissioner of Revenue" on Justia Law

The case concerns an individual who was convicted by a jury in Rice County District Court of 29 criminal offenses, including racketeering, theft, receiving stolen property, and falsifying information. The convictions arose from a scheme involving the purchase of used vehicles, alteration of vehicle identification numbers, and the sale of stolen vehicles. The district court sentenced the individual to 117 months in prison and ordered restitution to 13 victims, totaling over $124,000. The defendant challenged all restitution awards, specifically disputing four of them on the grounds that they were not sufficiently connected to his convictions and that he lacked the ability to pay.After a hearing, the Rice County District Court vacated the four disputed restitution awards, finding that the State had not met its burden to prove the amount of loss by a preponderance of the evidence. The State appealed, and the Minnesota Court of Appeals reinstated the four awards. The appellate court interpreted Minnesota Statutes section 611A.045, subdivision 3(a), to require that a defendant’s affidavit must specifically indicate whether the challenge is to the amount of loss, the appropriateness of restitution for the item, or both. The court concluded that the defendant’s affidavit only challenged the connection between the restitution and the convictions, not the amount of loss, and thus the burden did not shift to the State.The Minnesota Supreme Court reviewed the case and held that, under section 611A.045, subdivision 3(a), an offender’s affidavit must specify for each item whether the challenge is to the amount of loss, the appropriateness of restitution, or both, before the burden shifts to the State. However, recognizing that prior case law may have caused confusion, the Supreme Court remanded the case to the district court to allow the parties to comply with this clarified standard. The decision of the Court of Appeals was affirmed in part, reversed in part, and the case was remanded. View "State v. Seeman" on Justia Law

A county agency filed a petition to terminate a father’s parental rights to his child. The father consented to the voluntary termination and submitted a written affidavit to that effect. At a subsequent hearing, he confirmed his consent and understanding of the consequences. The district court relied on his admission and other evidence to terminate his parental rights, finding the termination was in the child’s best interests. The father did not file any post-trial motions but initially appealed on jurisdictional grounds, later voluntarily dismissing and then seeking to reinstate his appeal. The Minnesota Court of Appeals ultimately affirmed the termination, limiting its review to the jurisdictional issue.Over a year after the termination order became final, the father filed a motion in the district court to withdraw his admission, alleging it was obtained through fraud, undue influence, and duress. The district court struck the motion, reasoning that the father lacked standing because his parental rights had already been terminated and the time to challenge the order had expired. The Minnesota Court of Appeals dismissed his appeal, agreeing that he lacked standing to file the motion after finality.The Minnesota Supreme Court reviewed the case to clarify the timeframe for withdrawing an admission to a petition for termination of parental rights under Minnesota Rule of Juvenile Protection Procedure 56.03, subdivision 5(b). The court held that a person may file a motion to withdraw such an admission at any time if withdrawal is necessary to correct a manifest injustice, regardless of other time limits in the rules. The court further held that the district court must determine whether the motion makes a prima facie showing of manifest injustice and, if so, must hold an evidentiary hearing. The Supreme Court reversed the court of appeals and remanded for further proceedings. View "In the Matter of the Welfare of the Child of: B.D.D. and D.A.A." on Justia Law

The dispute arose between two longtime business partners who co-owned interests in several companies, including a parking facility management business. During the COVID-19 pandemic, the business faced financial difficulties, prompting the partners to seek a federal loan. One partner, who was in a position to influence the loan’s approval, allegedly pressured the other to sell his business interests at a reduced price, threatening to block the loan if the sale did not proceed. The sale was formalized through several transfer agreements containing broad releases of claims. The selling partner later sued, alleging he signed the agreements under duress and as a result of fraud.The case was first heard in the Minnesota District Court, which dismissed the complaint in its entirety, finding that the releases in the transfer agreements barred all claims. The district court also awarded costs and attorney fees to the defendants as prevailing parties under the agreements. The district court further held that the plaintiff was required to return the consideration received to void the releases, and, in the alternative, found that some claims failed on their own merits. The Minnesota Court of Appeals affirmed the dismissal, but on different grounds, holding that the plaintiff’s complaint failed to allege sufficient facts to invalidate the releases and thus the claims were barred. The appellate court also affirmed the award of costs and attorney fees.The Minnesota Supreme Court reviewed the case and clarified the pleading standard for motions to dismiss based on affirmative defenses. The court held that a plaintiff’s complaint does not need to anticipate and rebut an affirmative defense to survive a motion to dismiss; dismissal is only appropriate if the complaint’s allegations, construed in the plaintiff’s favor, establish an unrebuttable defense. The court reversed the lower courts’ dismissal of the complaint and the award of costs and attorney fees, and remanded the case for further proceedings. View "Hoskin vs. Krsnak" on Justia Law

In this case, the appellant was convicted by a jury in Hennepin County District Court of first-degree premeditated murder and second-degree intentional murder for the shooting death of Lavelle Jackson. The conviction was based in part on testimony from a jailhouse witness, S.P., who claimed the appellant confessed to the crime. After sentencing, the appellant sought postconviction relief, arguing that newly discovered evidence—specifically, testimony from Dequarn Bell, another inmate—would have undermined S.P.’s credibility and potentially changed the outcome of the trial.Following a stay of the direct appeal, the appellant petitioned for postconviction relief in the Hennepin County District Court, presenting affidavits and testimony from Bell and his trial attorney. Bell’s testimony suggested that S.P. was motivated by self-interest and that the appellant had maintained his innocence. After an evidentiary hearing, the district court denied the petition, finding Bell’s testimony not credible. In making this determination, the district court relied on detailed information about Bell’s criminal history, including facts not presented by either party at the hearing. These extra-record facts were obtained through the judge’s own independent investigation.The Minnesota Supreme Court reviewed the denial of postconviction relief. The court held that the district court’s deliberate investigation and consideration of facts outside the record violated the appellant’s constitutional right to an impartial judge under the Due Process Clause of the Minnesota Constitution. This violation constituted structural error, requiring automatic reversal without a harmless error analysis. The Supreme Court reversed the district court’s denial of postconviction relief in part and remanded the case for a new evidentiary hearing before an impartial judge. View "State of Minnesota vs. Duol" on Justia Law

The defendant was charged with multiple counts, including first-degree and third-degree criminal sexual conduct, domestic assault, and threats of violence. During jury deliberations, a juror was exposed to COVID-19, raising concerns that continued deliberations might pressure the jury to reach a verdict. After discussing the situation with counsel, the district court decided to end deliberations, take any unanimous verdicts, and declare a mistrial on any deadlocked counts. The defendant’s attorney, at the defendant’s request, asked for a complete mistrial on all counts. The jury ultimately reported no unanimous verdicts, and the district court declared a mistrial on all counts.Following the mistrial, the State refiled the charges. The defendant moved to dismiss, arguing that a retrial would violate the Double Jeopardy Clauses of the United States and Minnesota Constitutions. The Hennepin County District Court denied the motion, finding that double jeopardy did not bar retrial. The Minnesota Court of Appeals affirmed, holding that because the defendant requested the mistrial, double jeopardy would only bar retrial if the government had intentionally provoked the request, which was not the case here.The Supreme Court of Minnesota reviewed the case and affirmed the decision of the court of appeals. The court held that when a defendant requests and receives a mistrial, double jeopardy does not bar retrial unless the government intentionally induced or provoked the request. The court found no evidence that the district court or prosecution provoked the defendant’s mistrial request. The court also rejected arguments that the defendant had withdrawn his request or preserved an objection to the mistrial. As a result, the court concluded that double jeopardy did not attach, and the defendant may be retried. View "State v. Lerma" on Justia Law

In 1998, Joel Underwood, III, pleaded guilty to third-degree assault, which is classified as a crime of violence under Minnesota law. He was convicted and placed on probation. In 2000, after completing probation, a Dakota County district court issued an order restoring his civil rights and stating that he was prohibited from possessing a firearm for 10 years, which was consistent with the law at that time. In 2003, the Minnesota Legislature amended the relevant statute to impose a lifetime ban on firearm possession for individuals convicted of a crime of violence. Underwood was not specifically notified of this change. In 2021, he was found in possession of a firearm and charged under the amended statute.After being charged, Underwood waived his right to a jury trial and pleaded guilty to being an ineligible person in possession of a firearm. During the plea, he admitted to knowingly possessing a firearm and to his prior conviction but stated he did not know he was still ineligible to possess a firearm. The Anoka County District Court accepted his plea and sentenced him to the mandatory minimum. Underwood later petitioned for postconviction relief, arguing that his conviction violated due process because he relied on the 2000 discharge order and that his plea was invalid since he did not admit knowledge of his ineligibility. The postconviction court denied relief, and the Minnesota Court of Appeals affirmed, holding that there was no due process violation and that knowledge of ineligibility was not required for conviction.The Minnesota Supreme Court reviewed the case and affirmed the Court of Appeals. The court held that when a court order accurately reflects the law at the time but the law is later amended, the State does not violate due process by prosecuting under the amended statute. The court also held that the offense of ineligible person in possession of a firearm does not require proof that the defendant knew of their ineligibility, only that they knowingly possessed a firearm and had a prior conviction for a crime of violence. View "Underwood v. State" on Justia Law

A multinational science and technology company operated in approximately 90 countries, with a significant portion of its sales outside the United States. For the tax years 2013, 2014, and 2015, the company conducted some business in Minnesota, requiring its income to be apportioned for state tax purposes. The company used forward exchange contracts (FECs) as a hedging tool to manage foreign currency risk, generating substantial gross receipts from these transactions, though the net income from FECs was relatively small compared to overall gross receipts.After the company filed its Minnesota corporate franchise tax returns using the general apportionment method, which included gross receipts from FECs, the Minnesota Department of Revenue audited the returns. The Department determined that including gross receipts from FECs in the apportionment formula distorted the company’s Minnesota tax liability. The Commissioner of Revenue applied an alternative apportionment method under Minnesota Statutes section 290.20, which excluded gross receipts but included net income from FECs. The company appealed, and the Minnesota Tax Court upheld the Commissioner’s approach, finding that FEC transactions were qualitatively different from the company’s main business activities and that including their gross receipts caused a substantial quantitative distortion in the apportionment formula.The Supreme Court of Minnesota reviewed the case, applying a deferential standard to the tax court’s factual findings and de novo review to legal conclusions. The court held that the tax court did not err in finding that the Commissioner met his burden under section 290.20 to show that the general apportionment method did not fairly reflect the company’s Minnesota activities, and that the alternative formula—excluding gross receipts but including net income from FECs—fairly represented those activities. The Supreme Court affirmed the tax court’s decision. View "E. I. duPont de Nemours and Company & Subsidiaries v. Commissioner of Revenue" on Justia Law

Melvin Bilbro was charged after killing Shanna Daniels in her North Saint Paul apartment and setting the apartment on fire. Evidence at trial established that Bilbro and Daniels had a significant romantic and sexual relationship, as shown by their frequent text messages, terms of endearment, and testimony from acquaintances. On the night of the murder, Daniels was found dead with multiple stab wounds, and the fire in her apartment was determined to be intentionally set. Investigators found blood evidence linking Bilbro to the scene, and Daniels’s dog was discovered in Bilbro’s apartment. Bilbro denied involvement and claimed he was not in a relationship with Daniels.The State charged Bilbro with first-degree domestic-abuse murder, second-degree intentional murder, and first-degree arson. Bilbro waived his right to a jury trial on guilt but reserved the right to a jury for any facts supporting an aggravated sentence. The trial proceeded in Ramsey County District Court as a bench trial. The State presented evidence of Bilbro’s prior acts of domestic abuse against a former girlfriend, A.B., including physical assaults and an attempted murder for which Bilbro had previously been convicted. The district court found Bilbro guilty on all counts and sentenced him to life in prison for first-degree domestic-abuse murder and a consecutive 57-month sentence for arson, finding that the arson was committed to conceal the murder.On direct appeal, Bilbro argued that the evidence was insufficient to prove a significant romantic relationship with Daniels or a past pattern of domestic abuse, and that his Sixth Amendment right to a jury was violated when the court, rather than a jury, found facts authorizing the consecutive arson sentence under Minn. Stat. § 609.035. The Minnesota Supreme Court held that the evidence was sufficient to support the murder conviction and that the Sixth Amendment right to a jury under Blakely v. Washington does not apply to the threshold question of whether a sentence may be imposed for an offense under Minn. Stat. § 609.035. The court affirmed the district court’s judgment. View "Ramsey County v. Bilbro" on Justia Law