Justia Minnesota Supreme Court Opinion Summaries

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The Supreme Court reversed the decision of the court of appeals concluding that the United States Supreme Court's decision in Missouri v. McNeely, 569 U.S. 141 (2013), is substantive in the context of a conviction for test refusal, holding that the rule announced in McNeely is procedural and does not apply retroactively to test-refusal convictions on collateral review.In 2010, Defendant was convicted of first-degree test refusal for refusing to submit to a warrantless blood and urine test. In 2016, he filed a petition for postconviction relief, arguing that his conviction was unconstitutional. The district court ultimate determined that Defendant was entitled to postconviction relief, regardless of whether McNeely applied. The court of appeals reversed, holding that McNeely applied retroactively. The Supreme Court reversed and remanded the case, holding that McNeely did not apply retroactively to Defendant's test-refusal conviction, and the district court not properly articulate the pre-McNeely standard for exigent circumstances. View "Johnson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder of Andrew Gokee and attempted first-degree premeditated murder of Hudson Gauthier, holding that the district court did not abuse its discretion when it denied Defendant's request for an accomplice-testimony jury instruction under Minn. Stat. 634.04.During trial, Defendant requested an accomplice-testimony jury instruction, arguing that the jury could reasonably find that Gauthier was an accomplice. The district court concluded that the instruction was precluded as a matter of law because Defendant intended to present evidence identifying Gauthier as an alternative perpetrator. The Supreme Court affirmed, holding (1) there was no evidence that Defendant and Gauthier worked as accomplices to kill Gokee; and (2) Defendant was not entitled to relief on his remaining claims of error. View "State v. Montano" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the conclusion of the court of appeals that this appeal was moot but affirmed the court's decision dismissing the appeal, holding that Appellant, a Level III predatory offender serving the conditional release term of his sentence, was not entitled to a writ of habeas corpus.Before the time that Appellant filed this habeas petition, his conditional release had been revoked on five separate occasions. An order was later entered preventing the Department from using Appellant's inability to maintain an agent-approved placement due to his epilepsy as a basis for future revocations of his conditional release. In his habeas corpus petition, Appellant argued that his epilepsy was the sole reason for the revocation of his conditional release and continued incarceration. During the appeal from the denial of relief the Department released Appellant from prison. The court of appeals determined that Appellant's release from prison rendered his appeal moot. The Supreme Court affirmed in part and reversed in part, holding (1) the mootness exception applied in this case; and (2) The Department did not violate Appellant's substantive due process rights or the rule of law set forth in State ex rel. Marlowe v. Fabian, 755 N.W.2d 792 (Minn. App. 2008). View "State, ex rel. Young v. Schnell" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of third-degree criminal sexual conduct, holding that a person is mentally incapacitated under Minn. Stat. 609.341, subd. 7 when that person is "under the influence of alcohol...administered to that person without the person's consent." Defendant raped the victim when she was voluntarily intoxicated. At issue was whether a person can be mentally incapacitated under section 609.341, subd. 7 when the person voluntarily ingests alcohol, or whether the alcohol must be administered to the person without her agreement. The Supreme Court remanded this case for a new trial, holding that a person is mentally incapacitated under the statute when that person is "under the influence of alcohol...administered to that person without the person's agreement." View "State v. Khalil" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the tax court concluding that Menard, Inc. was not entitled to an offset on its sales tax liability under Minn. Stat. 297A.81, holding that the tax court correctly concluded that Menard was not eligible for a sales tax offset.Under section 297A.81, a taxpayer can reduce current tax liabilities by the amount of sales taxes attributable to uncollectible debts owed to the taxpayer. Menard claimed a sales tax offset based on uncollectible debts resulting from customer purchases made on Menard's private label credit card offered by Capital One, N.A. The Commissioner of Revenue concluded that Menard was ineligible to claim an offset and assessed additional sales tax. The tax court affirmed, concluding that unpaid debts from customer transactions made on Menard's private label credit card were owed to Capital One, not Menard. The Supreme Court affirmed, holding (1) the unpaid customer transactions were not debts owed to Menard; and (2) Menard was not a guarantor of the cardholders' debts. View "Menard, Inc. v. Commissioner of Revenue" on Justia Law

Posted in: Tax Law
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The Supreme Court reversed the decision of the court of appeals concluding that the factual findings of the Minnesota Pollution Control Agency were "insufficient to facilitate judicial review" of a permitting decision, holding that the Agency is not required under the Clean Air Act, 42 U.S.C. 7401-7671q, and its applicable regulations to investigate allegations of "sham" permitting when a source first applies for a synthetic minor source permit.At issue was whether the Agency was required to investigate allegations of sham permitting when consider whether to approve the air-emissions permit of PolyMet Mining, Inc. for a proposed mine. Respondents challenged the Agency's decision to issue the synthetic minor source permit, asserting that the Agency failed to conduct an adequate investigation into whether PolyMet intended to operate within the limits of the permit or whether it was instead seeking a sham permit. The court of appeals concluded that the Agency's short response to the concerns of Respondents was not the "hard look" required under the Minnesota Administrative Procedure Act, Minn. Stat. 14.69. The Supreme Court reversed, holding that the applicable federal regulations and guidance contemplate retrospective enforcement after the applicant has obtained a synthetic minor source permit and do not mandate prospective investigation. View "In re Issuance of Air Emissions Permit No. 13700345-101 for PolyMet Mining, Inc." on Justia Law

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The Supreme Court reversed the judgment of the court of appeals reversing the determination of the district court that the Freeborn County Board of Commissioners acted arbitrarily when it set the 2019 salary of the Freeborn County Sheriff at $97,020, holding that the district court did not clearly err.In the salary appeal, the district court concluded that the Board acted arbitrarily and without sufficiently taking into account the responsibilities and duties of the sheriff's office because the testifying commissioners did not explain why they decided on a salary of $97,020. The court of appeals reversed, concluding that the district court's findings and conclusions were clearly erroneous. The Supreme Court reversed, holding that the district court did not clearly err in setting aside the Board's salary decision because there was reasonable support in the record for the court's determination that the Board's salary decision was arbitrary. View "In re Year 2019 Salary of Freeborn County Sheriff" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the district court's denial of Appellant's petition for postconviction relief after determining that his stay of adjudication and discharge from probation was not a conviction, holding that Appellant's stay of adjudication was not a conviction.Pursuant to a plea agreement, Appellant pleaded guilty to domestic assault-intentional infliction of bodily harm. The district court accepted Appellant's plea of guilty and stayed adjudication under the parties' agreement. After Appellant successfully completed and was discharged from probation he received notice that he was scheduled for immigration removal proceedings. Appellant filed a petition for postconviction relief seeking to withdraw his guilty plea on grounds that he received ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356 (2010). The postconviction court concluded that Appellant had not been convicted of a crime and was therefore not eligible for postconviction relief. The Supreme Court affirmed, holding (1) the plain meaning of the phrase "a person convicted of a crime" in Minn. Stat. 590.01, subd. 1 means a person who has a conviction under Minnesota law; and (2) Appellant's stay of adjudication did not meet this definition. View "Johnston v. State" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the court of appeals concluding that Officer Eric Reetz was not entitled to defense and indemnification from his employer, the City of Saint Paul, when Reetz was sued for allegedly failing to detect a knife at a homeless shelter while working off duty as a private security guard, holding that the court of appeals erred.The City concluded that it was not obligated to defend and indemnify Reetz under Minn. Stat. 466.07 under the circumstances of this case. The court of appeals reversed. The Supreme Court reversed, holding (1) as a matter of law, Reetz was not "acting in the performance of the duties of the position" of a police officer when he allegedly failed to detect a knife that was banned only by the shelter's policies; and (2) therefore, the City was not required to defend and indemnify Reetz. View "Reetz v. City of Saint Paul" on Justia Law

Posted in: Personal Injury
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The Supreme Court held that groundwater is a Class 1 water under Minnesota law and therefore subject to secondary drinking water standards promulgated by the United States Environmental Protection Agency (EPA).In 2018, the Minnesota Pollution Control Agency (MPCA) issued a National Pollutant Discharge Elimination System/State Disposal System permit to United States Steel Corporation (U.S. Steel) governing U.S. Steel's Minntac Tailings Basin Area in Mountain Iron and setting a groundwater sulfate limit of 250 mg/L at the facility's boundary that U.S. Steel must meet by 2025. On appeal, U.S. Steel argued that the MPCA did not have the authority to impose the sulfate standard in the permit because the EPA's secondary drinking water standards apply only to bodies of water classified as Class 1 waters and that groundwater is not classified as Class 1. The court of appeals agreed and reversed the MPCA's decision. The Supreme Court reversed, holding (1) groundwater is a Class 1 water under Minnesota law; and (2) therefore, the MPCA correctly exercised its authority by applying the Class 1 secondary drinking water standards to the permit. View "In re Reissuance of NPDES/SDS Permit to United States Steel Corp." on Justia Law