Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court held that, for double jeopardy purposes, the unit of prosecution for a violation of Minn. Stat. 243.166, subd. 3(a), which requires a predatory offender to register "with the corrections agent as soon as the agent is assigned to the person," is the assignment of a corrections agent, thus affirming in part and reversing in part the decision of the court of appeals.Defendant was convicted and sentenced on seven separate occasions between 2004 and 2018 for failing to register under subdivision 3(a). In August 2019, Defendant refused to sign required paperwork presented by his new corrections agent. In September 2019, Defendant again refused to sign the paperwork presented by a special agent of the Minnesota Bureau of Criminal Apprehension assigned by Defendant's corrections agent. The State charged Defendant with two counts of failing to register under subdivision 3(a). Defendant moved to dismiss the charges on double jeopardy grounds. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Defendant's earlier convictions did not bar prosecution of the August 2019 offense; but (2) the September 2019 offense was barred. View "State v. Larson" on Justia Law

The Supreme Court reversed the decision of the court of appeals in this appeal involving a dispute between a homeowner and an insurance company over prejudgment interest, holding that Minnesota standard fire insurance policy, Minn. Stat. 65A/01, entitled Homeowner to prejudgment interest in an amount that may result in a total recovery that exceeded the policy limit.Homeowner sought coverage from Insurer after fires damaged his home. Insurer denied coverage, leading Homeowner to bring this lawsuit. A jury found for Homeowner. The district court award awarded Homeowner prejudgment interest in a limited amount, finding that Homeowner's total recovery for his personal property loss could not permissibly exceed the policy coverage limit. The court of appeals affirmed. The Supreme Court reversed and remanded the case to the district court to recalculate prejudgment interest, holding that, consistent with past precedent interpreting the standard fire policy, prejudgment interest can lawfully begin accruing before ascertainment of the loss when the insurer denies all liability. View "Else v. Auto-Owners Insurance Co." on Justia Law

The Supreme Court affirmed the denial of Appellant's petition for postconviction relief arguing that the district court committed reversible error by denying his pretrial motion to suppress his statements to law enforcement officers, holding that the district court did not abuse its discretion by denying Appellant's request for postconviction relief.Appellant was convicted of second-degree murder and first-degree arson and sentenced to a total of 528 months in prison. Appellant later filed for postconviction relief, asserting that the district court committed reversible error by denying his pretrial motion to suppress statements he made to law enforcement officers. The district court denied relief on the grounds that Appellant was not subjected to custodial interrogation at the time he made his statements. The court of appeals affirmed on different grounds. The Supreme Court affirmed on the grounds cited by the district court, holding that Defendant could not invoke his Fifth Amendment right to counsel because no custodial interrogation took place. View "Charette v. State" on Justia Law

The Supreme Court approved a plan proposed by Petitioner to correct an error on the November 8, 2022 general election ballot in this petition brought by the Ramsey County Elections Manager under Minn. Stat. 204B.44(a) with minor modifications.Due to a clerical error, Ramsey County ballots incorrectly listed Beverly Peterson, and not Scott Hesselgrave, as the Republican Party candidate for Minnesota House District 67A. Petitioner sought an order authorizing correction of the ballot for House District 67A, distribution of the corrected ballot, and procedures for counting these voters' ballots. The Supreme Court held that it was authorized to correct the ballot error and the Petitioner proposed an appropriate plan to remedy the error. View "In re 2022 General Election Ballot" on Justia Law

The Supreme Court denied this petition asking that the Court order removal of Torrey Westrom from the November 8, 2022 general election ballot as a candidate for Senate District 12, holding that Petitioner was not entitled to relief.Petitioner alleged that Westrom, the current state senator for District 12, was not eligible for reelection to that office because he could satisfy the residency requirement of the Minnesota Constitution. Specifically, Petitioner alleged that Westrom will not have resided in Senate District 12 for the required six-month period prior to the general election. A referee concluded that Petitioners failed to prove that Westrom was ineligible to run for state legislative office in District 12 in the November general election. The Supreme Court denied the petition and granted the Attorney General's request to be dismissed from the matter, holding that Petitioners' objections failed. View "Fischer v. Simon" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming in part and reversing and remanding in part the judgment of the district court denying Energy Policy Advocates' motion to compel and dismissing its civil action against seeking production of certain documents under the Data Practices Act, holding that this Court formally recognizes the common-interest doctrine in Minnesota.Energy Policy submitted document requests under the Data Practices Act, Minn. Stat. 130.01 through 13.90, related to climate-change litigation to the Office of the Attorney General. At issue on appeal was the existence and scope of the applicability of the attorney-client privilege to internal communication among attorneys in public law agencies, the common-interest doctrine, and the section of the Data Practices Act governing Attorney General data. The Supreme Court held (1) the common-interest doctrine is formally recognized in Minnesota; (2) the attorney-client privilege may apply to protect the confidentiality of internal communications among attorneys in public law agencies; and (3) the Legislature's classification of Attorney General data under Minn. Stat. 13.65, subdivision 1 as "private data on individuals" even when the data do not pertain to "individuals" is upheld. View "Energy Policy Advocates v. Ellison" on Justia Law

The Supreme Court affirmed the decision of the court of appeals applying the statutory definition of "public waters" in Minn. Stat. 103G.005, subd. 15, to determine whether the upper reach of Limbo Creek was a public water, holding that the court of appeals did not err.At issue was the upper reach of Limbo Creek in Renville County and whether it was a public water for purposes of environmental review under Minn. Stat. 116D.01-.11. Specifically in question was whether the classification of waters as "public water" was based on the statutory definition of "public waters" in Minn. Stat. 103G.005, subd. 15, or the "public waters inventory" maintained by the Department of Natural Resources. The Supreme Court affirmed the court of appeals' reliance on the statutory definition of "public waters" to determine in this case whether the upper reach of Limbo Creek was a public water, holding that court of appeals did not err. View "In re Petition of MCEA" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to Marvel, LLC in this negligence action, holding that an exculpatory clause purporting to release Marvel from "any and all claims" related to use of its inflatable amusement play area did not release Marvel from liability for its own negligence.Before seven-year-old Carter Justice attended a birthday party at an inflatable amusement play area owned by Marvel his mother signed a waiver of liability naming Justice. While there, Justice fell and hit his head on concrete floor, leading to several injuries. Justice sued Marvel when he turned eighteen. The district court granted summary judgment for Marvel, and the court of appeals affirmed. The Supreme Court reversed, holding that the waiver, strictly construed, did not release Marvel from liability for its own negligence. View "Justice v. Marvel, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the district court rejecting Wife's action against Husband seeking half of his retirement account or, alternatively, an equitable portion of the account, holding that the parties' omission of their largest asset from the dissolution decree made it impossible for the district court to determine whether the settlement was equitable.After the parties' marriage was dissolved through a joint petition for marriage dissolution Wife filed this action seeking half of Husband's retirement account. In objecting, Husband argued that he and Wife had intentionally omitted his retirement account from their joint petition pursuant to an unwritten side agreement. The district court concluded that the relief Wife sought was beyond the scope of a ** proper enforcement of clarification order and was time-barred to the extent it sought to reopen the decree. The court of appeals affirmed. The Supreme Court reversed, holding (1) district courts have the power to address omitted assets that fall outside the scope of the grounds set forth in Minn. Stat. 518.145, subd. 2 for reopening a dissolution decree; and (2) the parties' omission from the decree of their largest asset rendered it impossible for the district court to determine whether the settlement was equitable. View "In re Marriage of Pooley" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the order of the district court granting summary judgment to Defendants - mental healthcare providers - and dismissing Plaintiff's wrongful death action, holding that genuine issues of material fact existed.For three months, Brian Short received outpatient treatment for anxiety and depression. Thereafter, he shot and killed his wife, his three children, and himself. Plaintiff brought this wrongful death action. The district court granted summary judgment for Defendants, concluding that they did not have a duty to protect or control Brian or his wife and children absent a custodial relationship or foreseeability of harm. The court of appeals reversed, holding (1) Defendants owed a duty of care to Brian, and (2) genuine issues of material fact existed as to whether Defendants' conduct created a foreseeable risk to Brian's wife and children. The Supreme Court (1) affirmed as to Brian, holding that a mental healthcare provider owes a duty of reasonable care to its patient that is not negated by a lack of total control over the patient; and (2) reversed as to Brian's wife and children, holding that harm to the family members was outside the scope of the duty of care and unforeseeable as a matter of law. View "Smits v. Park Nicollet Health Services" on Justia Law