Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals concluding that certification of H.B., who was fifteen years old when he was charged in juvenile court with aiding and abetting second-degree murder and first-degree aggravated robbery, for adult prosecution was proper, holding that certification was required.Delinquency petitions were filed charging H.B. with aiding and abetting first-degree aggravated robbery. The State moved to prosecute H.B. as an adult for the charges, but the district court denied the motion, concluding that the dispositional options available to H.B. did not weigh in favor of certification. The court of appeals reversed and remanded with instructions for the district court to certify H.B. for adult prosecution. The Supreme Court affirmed, holding that the court of appeals correctly found that the district court abused its discretion in determining that the State had not met its burden of proving that retaining H.B. in the juvenile system would not serve public safety. View "In re H.B." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to dismiss the charge of fifth-degree marijuana possession against him for lack of probable cause, holding that the evidence was sufficient to survive a motion to dismiss for lack of probable cause.This case arose when law enforcement officers discovered a plant substance in Defendant's car during a traffic stop. While the State did not test the concentration of THC in the substance before charging gate case, a field test of the substance detected the presence of THC. The district court granted Defendant's motion to dismiss for lack of probable cause. The court of appeals reversed, concluding that chemical testing establishing the THC concentration of substance was not required when there is other sufficient evidence to support a probable cause finding. The Supreme Court affirmed, holding that Defendant's admission that the material in the vehicle was marijuana was sufficient to survive a motion to dismiss the charge of fifth-degree marijuana possession. View "State v. Dixon" on Justia Law

Appellant's petition for postconviction relief and vacating Appellant's conviction and sentence, holding that, in a postconviction proceeding, a district court has the authority under Minn. Stat. 590.04, subd. 1 to order the State to refund restitution that the defendant has paid because of a conviction when that conviction has been invalidated and no retrial will occur.Appellant was convicted of one count of violating Minn. Stat. 609.27, subd. 1(4). Later, subdivision 1(4) was declared facially overbroad and unconstitutional. In her petition for postconviction relief, Appellant asserted that, under Nelson v. Colorado, 581 U.S. __ (2017), she was entitled to a refund of all restitution payments made because of her invalid conviction. The district court vacated her conviction and sentence but denied her request for a refund of restitution on the grounds that it lacked authority to do so. The court of appeals affirmed. The Supreme Court reversed, holding that, in a postconviction proceeding, a district court has the authority to order a refund of restitution when the monetary assessments the defendant paid were imposed solely because of the conviction, the State exacted those assessments, and the conviction was invalidated with no prospect of retrial. View "Byington v. State" on Justia Law

The Supreme Court granted a petition sought by Petitioner seeking an order authorizing Petitioner to send notices about errors on the for the Murray County ballot for the November 8, 2022 general election to all mail ballot voters and to all voters who had already requested an absentee ballot, holding that Petitioner was entitled to relief.The petition asserted that the ballot at issue incorrectly identified the district number for the Minnesota legislative officers as Senate District 22 and House District 22A. Petitioner did not seek to correct the errors on the ballot but sought to send notices regarding the errors and the authority to post the same notice in all Murray County polling places. The Supreme Court granted the petition, holding that Petitioner proposed an appropriate plan to remedy the ballot errors. View "In re Murray County Ballot" on Justia Law

The Supreme Court ordered that Petitioners shall correct the ballot for the November 8, 2022 general election because the general election ballot used by voters in Roseau County and Kittson County omitted information required by Minnesota law.Roseau and Kittson Counties filed petitions under Minn. Stat. 204B.44(a) to correct errors on the November 8, 2022 general election ballot, stating the the ballots in each county failed to include the political party affiliation for federal and state candidates and failed to include the word "incumbent" next to names of currently-serving judicial candidates. The Supreme Court ordered that the counties shall correct the ballot for the November 8, 2022 general election and that Petitioners shall resume delivery of ballots to voters after they receive corrected ballots from their vendors. View "In re Roseau County Ballot for the November 8, 2022 General Election" on Justia Law

The Supreme Court reversed the court of appeals' opinion affirming the district court's conclusion that Minn. Stat. 609.746, subd. 1(e)(2) does not require a defendant to have knowledge of the victim's age when the offense criminalized under this statute is committed, holding that the district court's pretrial ruling was erroneous.Section 609.746, subd. 1(d)(1) makes it a crime secretly to use a device to record or photograph a person in a place where a reasonable person would have an expectation of privacy and is likely to expose their private parts. At issue was subdivision 1(e)(2), which enhances the offense from a gross misdemeanor to a felony of the defendant secretly records a minor under the age of eighteen. Defendant filed a pretrial motion to dismiss the charge against him because the State failed to allege that he knew or had reason to know that the victim was a minor under the age of eighteen when he committed the offense. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that the plain language of section 609.746, subd. 1(e)(2) requires the State to prove that Defendant committed the offense while knowing or having reason to know a person under the age of eighteen was present. View "State v. Galvan-Contreras" on Justia Law

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