Justia Minnesota Supreme Court Opinion Summaries

A police officer applied for a search warrant for a residence based on information from a confidential reliable informant (CRI). The CRI reported that, within the previous 72 hours, they had visited the residence and observed people smoking methamphetamine and meth pipes inside. The CRI was not directed by law enforcement to visit the house and had a history of providing reliable information to the police. Based on this information, a district court judge issued a search warrant. When the warrant was executed, officers found drug paraphernalia and items testing positive for methamphetamine. The resident was charged with two drug-related offenses.The defendant moved to suppress the evidence, arguing that the warrant was not supported by probable cause. The Swift County District Court denied the motion, finding the warrant application sufficient. After a jury found the defendant guilty, the Minnesota Court of Appeals affirmed the conviction in a divided opinion. The majority held that the totality of the circumstances, including the CRI’s reliability and basis of knowledge, established probable cause, and rejected the argument that corroboration of the CRI’s tip was always required. The dissent argued that corroboration was necessary and that the lack of it meant probable cause was lacking.The Minnesota Supreme Court reviewed the case to clarify whether corroboration of a confidential reliable informant’s tip is an independent requirement for probable cause. The court held that corroboration is not an independent requirement but is always a relevant factor in the totality-of-the-circumstances analysis. Applying this standard, the court concluded that the limited, uncorroborated observations in the warrant application did not establish a fair probability that contraband or evidence of a crime would be found in the house at the time of the search. The court reversed the decision of the court of appeals and remanded the case for further proceedings. View "State of Minnesota vs. Nagle" on Justia Law

The appellant was convicted by a jury of three counts of first-degree murder and three counts of second-degree murder for the deaths of three individuals in 1995. He was sentenced in 1996 to three consecutive life sentences, as required by statute for first-degree murder. At the time of sentencing, a probation agent advised the court that a presentence investigation (PSI) would not affect the sentence because the law mandated life imprisonment. The appellant did not receive a PSI, and a post-sentence investigation was to be conducted by the Department of Corrections. Over the years, the appellant challenged his convictions and sentences through multiple postconviction petitions, all of which were denied.In 2024, the appellant filed a motion to correct or reduce his sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, arguing that the lack of a PSI and alleged errors in calculating his criminal history score rendered his sentences unlawful. The State argued that the motion was actually a postconviction petition subject to the two-year statute of limitations under Minnesota Statutes § 590.01, subdivision 4, and that the court lacked jurisdiction. The Carver County District Court agreed with the State, denied the motion, and stated it lacked jurisdiction, but did grant jail credit for time served.The Minnesota Supreme Court reviewed the case and held that the district court erred in concluding it lacked jurisdiction to hear the appellant’s motion under Rule 27.03, subdivision 9, because such motions are not subject to the statutory time bar and, even if they were, the time bar is not jurisdictional. However, the Supreme Court affirmed the district court’s denial of relief, holding that the appellant’s mandatory life sentences were lawful. The absence of a PSI and the alleged miscalculation of the criminal history score did not render the sentences unlawful, as neither the PSI statute nor the sentencing guidelines apply to mandatory life sentences for first-degree murder. View "Riley vs. State of Minnesota" on Justia Law

A transgender woman sought to compete in the women’s division of powerlifting competitions organized by a national governing body. After registering and applying for a therapeutic use exemption to take a medication as part of her gender-affirming care, she was informed that the organization’s policy categorically barred transgender women from competing in the women’s division. The organization justified its policy by asserting that transgender women have an unfair competitive advantage due to “male physiology.” The woman’s competition card was revoked, and she was denied participation.The case was first heard in the Minnesota District Court, which granted partial summary judgment in favor of the plaintiff on her claims of sexual orientation discrimination in both public accommodations and business, as well as sex discrimination in business, under the Minnesota Human Rights Act (MHRA). The district court found the organization’s policy facially discriminatory and not justified by a legitimate business purpose. However, it denied summary judgment on the claim of sex discrimination in public accommodations, citing a statutory exemption for athletic events. The court also issued injunctive relief, ordering the organization to cease discriminatory practices and revise its policy.On appeal, the Minnesota Court of Appeals reversed the district court’s grant of partial summary judgment and injunctive relief, finding genuine issues of material fact regarding the organization’s motivation and the applicability of the legitimate business purpose defense.The Minnesota Supreme Court held that the organization’s policy was facially discriminatory and constituted direct evidence of discrimination based on sexual orientation under the MHRA. The court reinstated summary judgment for the plaintiff on the public accommodations claim, as no statutory defense was asserted. However, it found a genuine dispute of material fact regarding the legitimate business purpose defense for the business discrimination claim, affirming the appellate court’s reversal on that issue. The case was remanded for further proceedings. View "Cooper vs. USA Powerlifting" on Justia Law

Atravius Weeks was indicted for first-degree premeditated murder, first-degree domestic abuse murder, and second-degree intentional murder after he confessed to shooting and killing Cortney Henry in Dakota County, Minnesota. The incident occurred in June 2021, and Weeks was apprehended shortly after the crime. At trial, Weeks raised concerns about the racial composition of the jury panel, noting that Black individuals were underrepresented compared to the county’s population. He argued that the jury pool did not reflect a fair cross-section of the community, as required by the Constitution.The Dakota County District Court denied Weeks’s request for a new jury panel and, after a jury found him guilty on all counts, entered convictions for all three murder charges. Weeks’s direct appeal was stayed to allow him to file a postconviction petition, which included an expert affidavit suggesting that the use of voter registration and driver’s license lists for jury selection systematically underrepresents Black people. The district court summarily denied the postconviction petition, finding that Weeks failed to show systematic exclusion of Black jurors under the three-prong test from State v. Williams, and cited prior Minnesota cases holding that the jury selection process does not systematically exclude people of color.The Minnesota Supreme Court reviewed the case and held that the district court abused its discretion by summarily denying the postconviction petition. The Supreme Court found that, when the facts alleged are viewed in the light most favorable to Weeks, the record does not conclusively show he is entitled to no relief, and genuine issues of material fact remain regarding systematic exclusion. The Court also held that the district court violated Minnesota Statutes section 609.04 by entering convictions for both first-degree domestic abuse murder and second-degree intentional murder in addition to first-degree premeditated murder. The Supreme Court reversed and remanded for an evidentiary hearing and ordered the vacation of the lesser murder convictions. View "State of Minnesota vs. Weeks" on Justia Law

A personal care assistance provider agency in Minnesota was audited by the Department of Human Services (DHS) for recordkeeping deficiencies related to its provision of services under the state’s Medicaid program. The agency, which served both traditional and PCA Choice recipients, was found to have various documentation errors, including missing or incomplete care plans and timesheets, as well as timesheets lacking required elements. DHS did not allege fraud or that services were not provided, but sought to recover over $420,000 in payments, arguing that these deficiencies constituted “abuse” under state law and justified monetary recovery.After an evidentiary hearing, an administrative law judge (ALJ) recommended limited recovery for some missing documentation but rejected most of DHS’s claims, finding that DHS had not shown the deficiencies resulted in improper payments. The DHS Commissioner disagreed, ordering full repayment. The Minnesota Court of Appeals reversed the Commissioner’s decision, holding that DHS must prove not only that the provider engaged in “abuse” but also that the abuse resulted in the provider being paid more than it was entitled to receive. The court also determined that provider agencies must maintain care plans for both traditional and PCA Choice recipients in their files.The Minnesota Supreme Court affirmed in part, reversed in part, and remanded. It held that, to obtain monetary recovery under Minn. Stat. § 256B.064, subd. 1c(a), DHS must prove either: (1) the provider engaged in conduct described in subdivision 1a and, had DHS known of the conduct before payment, it would have been legally prohibited from paying under a statute or regulation independent of subdivision 1a; or (2) the payment resulted from an error such that the provider received more than authorized by law. The Court also held that provider agencies must keep care plans for all PCA services, including PCA Choice, in their files. View "In the Matter of the SIRS Appeal by Best Care, LLC" on Justia Law

After being arrested and jailed following an alleged assault on hospital staff, an individual was found incompetent to proceed in a criminal case and was civilly committed as mentally ill. The district court appointed counsel to represent him in the civil commitment proceedings. Under Minnesota law at the time, civilly committed patients in jail were entitled to priority admission to a state-operated treatment program within 48 hours of the commitment order. Despite this, the individual remained in jail for over a month. His court-appointed counsel then petitioned for writs of mandamus and habeas corpus to enforce his statutory right to timely admission to a treatment facility.The district court granted the writ of mandamus, ordering the Commissioner of Human Services to admit the patient to a treatment facility, and directed the county sheriff to transport him accordingly. When the county refused to pay the appointed counsel for work performed in the extraordinary writ proceedings, the district court ordered the county to pay, finding that the counsel’s work was directly related to the civil commitment and that representation extended to all proceedings under the relevant statute.The Minnesota Court of Appeals reversed the district court’s order regarding payment for the extraordinary writ proceedings, holding that such proceedings were not “under” the civil commitment statute and thus did not entitle the patient to court-appointed counsel or require payment by the county. However, the appellate court affirmed the order for payment for representation in the initial commitment proceedings.The Minnesota Supreme Court reversed the appellate court’s decision, holding that a petition for an extraordinary writ to enforce a civilly committed patient’s right to timely admission to a state-operated treatment program is a proceeding under the civil commitment statute. Therefore, the patient is entitled to the assistance of court-appointed counsel in such proceedings, and the county must pay a reasonable sum for that representation. View "In the Matter of the Civil Commitment of: Swope" on Justia Law

A tenant entered into a lease for an apartment in Minneapolis that was subsidized under the Section 8 project-based voucher program, with the local public housing authority paying most or all of the rent directly to the landlord. After the tenant fell behind on utility payments, her electricity was disconnected, and she and her boyfriend broke into the building’s utility closet to restore power, inadvertently affecting other units. The landlord learned of this breach but continued to accept three months of rental payments from the public housing authority on the tenant’s behalf. Later, the landlord filed an eviction action based on the tenant’s breach of the lease.The Hennepin County District Court dismissed the tenant’s counterclaim regarding the utility shutoff and, following the Minnesota Court of Appeals’ decision in Westminster Corp. v. Anderson, held that the common law doctrine of waiver by acceptance of rent did not apply to rental payments made by a public housing agency. The district court found the tenant had materially breached the lease and did not address her retaliation defense. The Minnesota Court of Appeals affirmed the district court’s rulings on the waiver and breach issues but remanded for consideration of the retaliation defense.The Minnesota Supreme Court reviewed only the waiver issue. It overruled Westminster, holding that the common law rule—whereby a landlord who accepts rent with knowledge of a tenant’s breach waives the right to evict for that breach—applies equally to private and publicly subsidized tenancies. The court clarified that whether a landlord has accepted rent for purposes of this doctrine is a factual question, to be determined by the totality of the circumstances, including the landlord’s conduct after payment. The Supreme Court reversed the court of appeals and remanded for further proceedings. View "Hook & Ladder Apartments, L.P. v. Nalewaja" on Justia Law

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