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The Supreme Court affirmed in part and reversed and remanded in part the court of appeals’ reversal of the district court’s grant of Company’s motion to dismiss Shareholder’s class action challenge to a merger transaction. The district court concluded (1) some claims were derivative, rather than direct, and were therefore subject to the demand and pleading requirements of Minn. R. Civ. P. 23.09; and (2) Shareholder failed to comply with Rule 23.09. The court of appeals reversed with the exception of one claim, concluding that most of the claims were direct, and therefore, Rule 23.09 did not apply. The Supreme Court clarified the test for distinguishing between direct and derivative claims and held that the district court did not err in dismissing some claims but erred in dismissing others. View "In re Medtronic, Inc. Shareholder Litigation" on Justia Law

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The Supreme Court affirmed Defendant’s conviction, rendered after a jury trial, of first-degree premeditated murder on an accomplice-liability theory. The court held (1) the district court did not commit clear error by denying Defendant’s Batson objection to the State’s peremptory challenge to exclude a black prospective juror trial because Defendant failed to establish a prima facie case of racial discrimination; and (2) the district court did not abuse its discretion or violate Defendant’s right to present a complete defense by refusing to allow Defendant to develop an alternative theory to explain why the murder weapon was found in a storage unit rented to an alleged accomplice. View "State v. Wilson" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the sentence imposed by the district court for Defendant’s convictions for third- and fourth-degree criminal sexual conduct on an accomplice-liability theory. The district court granted Defendant’s motion for a downward dispositional departure, stayed execution of a 140-month sentence for fifteen years, and required Defendant to comply with several probationary conditions. The court of appeals affirmed, concluding that an offender’s minor or passive role is an adequate reason for a downward dispositional departure and that the record supported the district court’s finding that Defendant played a minor or passive role in the third- and fourth-degree criminal sexual conduct. The Supreme Court affirmed, holding that the district court did not abuse its discretion by finding that Defendant’s minor or passive role in the offense was a substantial and compelling reason to depart from the Minnesota Sentencing Guidelines. View "State v. Stempfley" on Justia Law

Posted in: Criminal Law

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The court of appeals reversed the jury verdict for Appellant and awarded Respondent’s request to tax costs and disbursements for the appeal. Most of the award was for the interest that Respondent incurred on a loan that it obtained to enable it to post a supersedes bond, which was used to secure the judgment on the jury’s verdict during the appeal. Appellant sought review of the court of appeals’ taxation decision, arguing that the interest was not taxable on appeal. The Supreme Court granted a writ of prohibition and reversed the court of appeals’ decision to allow taxation of borrowing costs, holding that Minn. R. Civ. App. P. 139 does not permit the taxation of borrowing costs under the circumstances of this case. View "Klapmeier vs. Cirrus Industries, Inc." on Justia Law

Posted in: Civil Procedure

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The 2013 amendment to the Minnesota Whistleblower Act defining the term “good faith” eliminated the judicially created requirement that the putative whistleblower act with the purpose of “exposing an illegality.” Appellant filed a complaint in the United States District Court for the District of Minnesota alleging that Employer wrongfully terminated his employment in violation of the Minnesota Whistleblower Act. Employer argued in response that Defendant’s conduct was not protected under the Act. Employer based this argument on the Supreme Court’s interpretation of the Act in Obst v. Microtron, Inc., 614 N.W.2d 196, 202 (Minn. 2000), in which the court held that “good faith” requires a putative whistleblower to act with the purpose of “exposing an illegality.” Appellant argued in response that Obst is no longer good law following a 2013 amendment to the Act that defines “good faith” to mean “conduct that does not violate section 181.932, subdivision 3.” The district court certified the question to the Supreme Court as to whether the 2013 amendment abrogated the Supreme Court’s prior interpretation of “good faith.” The Supreme Court answered the certified question in the affirmative. View "United States District Court, District of Minnesota v. Edwards Lifesciences, LLC" on Justia Law

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The Supreme Court affirmed the Workers’ Compensation Court of Appeals’ (WCCA) reversal of the compensation judge’s dismissal of Respondent’s request for benefits under the Minnesota Workers’ Compensation Act (Minnesota Act). At the time of his injury, Respondent was performing longshoreman work. The compensation judge concluded that the Longshore and Harbor Workers’ Compensation Act provided Respondent’s exclusive remedy and that the case should be dismissed under the doctrine of forum non conveniens. The WCCA reversed, determining that the compensation judge’s dismissal for lack of jurisdiction was contrary to law and that the compensation judge lacked authority to dismiss Plaintiff’s claims under the doctrine of forum non conveniens. The Supreme Court affirmed, holding that the compensation judge had jurisdiction to hear Respondent’s claims brought under the Minnesota Act and that the judge abused his discretion by dismissing Respondent’s claims under the doctrine of forum non conveniens. View "Ansello v. Wisconsin Central, Ltd." on Justia Law

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Minnesota’s water’s edge rule, Minn. Stat. 290.17(4)(f), does not prohibit the inclusion in “net income” the income of a foreign entity that elects under federal tax law to be disregarded as a separate entity. At issue in this appeal from the tax court was whether the consequences of an election made under federal tax law by a foreign entity owned by Ashland Inc., a domestic unitary business, must be recognized in determining Ashland’s Minnesota tax liability. The Commissioner of Revenue concluded that the income and apportionment factors of the foreign entity were improperly included in Ashland’s combined return and so excluded them in calculating Ashland’s Minnesota tax liability. The tax court granted Ashland’s motion for summary judgment, concluding that the consequences of the federal election were properly included in the determination of Ashland’s net income on its Minnesota tax returns. The Supreme Court affirmed, holding that the tax court did not err in its conclusion. View "Ashland Inc. & Affiliates v. Commissioner of Revenue" on Justia Law

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The Supreme Court vacated Defendant’s sentence of 135 months in prison for his conviction for first-degree possession of methamphetamine, holding that resentencing was required under sentencing grid as amended by the Drug Sentencing Reform Act (DSRA). The DSRA, which took effect after Defendant committed his offense, reduced the presumptive sentencing range under the Minnesota Sentencing Guidelines drug offender sentencing grid for Defendant’s crime. The Supreme Court held that Defendant must be resentenced under the DSRA-amended sentencing grid, holding that the amelioration doctrine required that Defendant be resentenced. View "State v. Otto" on Justia Law

Posted in: Criminal Law

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The Supreme Court reversed the court of appeals affirming the district court’s dismissal of the State’s amended complaint against Minnesota School of Business and Globe University (the Schools). The State alleged that the Schools charged usurious interest rates and made loans without the required license for making private student loans at interest rates of up to eighteen percent. The State’s amended complaint sought permanent statutory injunctive relief to stop the Schools from engaging in unlicensed and usurious lending. The district court granted summary judgment for the Schools. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Schools charged usurious interest rates in violation of Minn. Stat. 334.01(1); and (2) the Schools were required to obtain a lending license under Minn. Stat. 56.01(a), and their failure to do so meant that they engaged in unlicensed lending. View "State v. Minnesota School of Business, Inc." on Justia Law

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The Supreme Court affirmed Appellant’s conviction for two counts of theft by false representation, holding that, even assuming that the trial court’s omission of the phrase “with intent to defraud” from the jury instructions on the elements of theft by false representation was error, the error was harmless. Appellant's convictions were based on her acts of submitting timesheets and receiving payments for personal care assistant services that she did not perform. The court of appeals affirmed the convictions, concluding that, when viewed as a whole, the district court’s jury instructions fairly and adequately explained the law. The Supreme Court agreed, holding that any alleged error in the jury instructions was harmless beyond a reasonable doubt. View "State v. Schoenrock" on Justia Law

Posted in: Criminal Law