Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court held that the district court did not abuse its discretion when it summarily denied Appellant's eighth petition for postconviction relief as untimely.Appellant was convicted of first-degree premeditated murder under an aiding and abetting theory of liability. In his eighth petition for postconviction relief, Appellant invoked the time-bar exception for newly discovered evidence, relying on an affidavit of one of his codefendants. The district court summarily denied the petition as untimely based on its determination that the statements in the affidavit were not newly discovered. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Appellant's postconviction petition. View "El-Shabazz v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion under Minn. R. Civ. P. 60.02 to vacate the denial of his first postconviction petition and the district court's denial of his second postconviction petition, holding that the district court did not abuse its discretion by denying Appellant's motion and second petition.Defendant was found guilty of first-degree premeditated murder, first-degree aggravated robbery and other crimes. The district court imposed a life sentence without the possibility of parole. The Supreme Court affirmed on appeal and also affirmed the denials of Defendant's first postconviction petition and his motion to correct his sentence. At issue on this appeal was the district court's denial of his motion to vacate the denial of his first postconviction petition and the denial of his second postconviction petition. The Supreme Court affirmed, holding that Defendant's claims were time-barred under the postconviction statute. View "Blue Earth County v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Appellant's petition to withdraw his guilty plea under Minn. R. Crim. P. 15.05, subd. 1, holding that Appellant demonstrated that withdrawal was necessary to correct a manifest injustice.Appellant pleaded guilty to one count of first-degree felony murder during the commission of an aggravated robbery. The district court sentenced him to life imprisonment with the possibility of release after thirty years. Appellant subsequently filed his petition to withdraw his guilty plea, alleging that the plea colloquy did not establish an adequate factual basis for felony murder during the commission of an aggravated robbery. The postconviction court denied the petition. The Supreme Court vacated the judgment plea and remanded the case for trial on the charges pending when Defendant pleaded guilty, holding that there were insufficient facts to show that Appellant's conduct fell within the charge to which he pleaded guilty and that he must be allowed to withdraw his plea to avoid a manifest injustice under Minn. R. Crim. P. 15.05, subd. 1. View "Bonnell v. State" on Justia Law

The Supreme Court affirmed the ruling of Workers' Compensation Court of Appeals (WCCA) that Respondent was entitled to workers' compensation benefits, holding that Respondent was not entitled to relief on his claims on appeal.A licensed psychologist diagnosed Respondent, a former deputy sheriff for Carlton County, with post-traumatic stress disorder (PTSD). A compensation judge ruled that Respondent was not entitled to workers' compensation benefits because a subsequent psychological evaluation requested by the County resulted in a diagnosis of major depressive disorder but not PTSD. The WCCA reversed, holding (1) under Minn. Stat. 176.011, subd. 15(e), deputy sheriffs are entitled to a presumption that PTSD is an occupational disease if they present a diagnosis of PTSD, regardless of whether their employer offers a competing diagnosis; and (2) Respondent was entitled to the benefit of the presumption that he had a compensable occupational disease, and the County failed to rebut the presumption. View "Juntunen v. Carlton County" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder, attempted first-degree premeditated murder, and kidnapping, holding that any error in the proceedings below was harmless.Specifically, the Supreme Court held (1) any error on the part of the district court in failing to hold a hearing on the foundational reliability of cell-site location information (CSLI) evidence was harmless, and the district court was not required to hold a hearing to determine whether the CSLI evidence was generally accepted in the relevant community; (2) the district court did not err in trying Defendant's and his codefendant's cases together; and (3) Defendant was not prejudiced by the district court's denial of his request for an additional peremptory challenge. View "State v. Berry" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder, attempted first-degree murder, and kidnapping, holding that there was no error in the proceedings below.On appeal, Defendant argued, among other things, that the district court erroneously joined his and his codefendant's cases for trial and by denying subsequent severance motions. The Supreme Court affirmed his convictions, holding (1) the district court did not improperly join Defendant's and his codefendant's cases for trial and did not erroneously refuse to sever the cases once the trial was underway; (2) the prosecutor did not commit misconduct during closing arguments; and (3) Defendant was not entitled to relief as to the claims he raised in a pro se supplemental brief. View "State v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the district court's decision to grant summary judgment in favor of Cornelius Emily and Earnest Rhoney, Department of Corrections officers, and dismiss Plaintiff's claims of cruel and unusual punishment, holding that Plaintiff's 42 U.S.C. 1983 claim survived summary judgment.Plaintiff, who was incarcerated in the Stillwater correctional facility, suffered serious injury in both of his wrists when Officers Emily and Rhoney improperly applied overtightened handcuffs on Plaintiff for three and one-half hours. Plaintiff brought this action seeking damages. The district court granted summary judgment, concluding that the officers did not act maliciously or sadistically. The court of appeals reversed. The Supreme Court affirmed, holding (1) the conduct of the officers should be assessed under the deliberate indifference standard applicable to conditions of confinement and medical care; and (2) qualified immunity did not bar Plaintiff's deliberate indifference claim. View "Welters v. Minn. Dep't of Corrections" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court denying Defendant's third and fourth petitions for postconviction relief without holding an evidentiary hearing, holding that there was no error.After a jury trial, the district court entered judgment finding Defendant guilty of one count of first-degree premeditated murder and sentenced him to life in prison without the possibility of release. At issue were Defendant's third and fourth petitions for postconviction relief, in which Defendant alleged newly discovered evidence. The postconviction court denied both petitions. The Supreme Court affirmed, holding (1) none of the pieces of evidence proffered by Defendant satisfied the newly discovered evidence exception in Minn. Stat. 590, subd. 4(b)(2); and (2) Defendant failed to satisfy Minn. Stat. 490.01, subd. 4(b)(5)'s interests of justice exception, and his claims were therefore time-barred. View "Anderson v. State" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the rulings of the compensation judge finding that C. Jeremy Lagasse was entitled to contingent fees under Minn. Stat. 176.081, subd. 1(c) and that Larry Horton was entitled to partial reimbursement of fees under Minn. Stat. 176.081, subd. 7, holding that the WCCA incorrectly applied subdivision 1(c) in its standard of review.Horton, who was injured during his employment with Aspen Waste Systems and sought permanent partial disability (PPD) benefits through Aspen's insurer (Insurer), retained Lagasse to represent him in the matter. The compensation judge determined that Lagasse was entitled to contingent fees and that Horton was entitled to partial reimbursement of fees. The WCCA reversed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the WCCA incorrectly applied subdivision 1(c); and (2) the compensation judge and the WCCA incorrectly applied subdivision 7. View "Lagasse v. Horton" on Justia Law

In this insurance coverage dispute the Supreme Court held that State Farm Fire and Casualty Company was not required to cover repair costs to masonry under either Minn. Stat. 65A.10, subd. 1 or the State Farm policy at issue.Before the Supreme Court was the interpretation and application of Minn. Stat. 65A.10, subd. 1, which generally requires replacement cost insurance to cover the cost of repairing damaged property in accordance with state or local authorities' minimum code. Specifically in question was whether State Farm must cover the cost of repairing cracks in masonry that preexisted a storm that damaged the property of St. Matthews. Because the cracks violated the City of St. Paul's building code, the City would not allow St. Matthews to replace the drywall without also repairing the masonry. The district court granted summary judgment to State Farm, determining that because the storm did not damage the masonry, which led to the code upgrade requirements, no coverage existed. The Supreme Court affirmed, holding that, while State Farm was responsible for providing replacement cost coverage to the damaged drywall, it was not required to cover repair costs to the masonry. View "St. Matthews Church of God & Christ v. State Farm Fire & Casualty Co." on Justia Law