Justia Minnesota Supreme Court Opinion Summaries

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

In this dispute among four siblings over the ownership of 200 acres of farmland the Supreme Court reversed the judgment of the court of appeals reversing the order of the district court that the farmland be distributed to Neal Johnson and Thomas Johnson, holding that the court of appeals failed to apply well-settled common law.This dispute stemmed from the last will and testament of the aunt of the four siblings in this case - Neal, Thomas, Sylvia Perron, and Lee Johnson. The aunt, Hazel Bach, devised the farmland to Neal and Thomas based on certain conditions that were resolved in an agreement between the parties. Although Lee, acting as co-personal representative, refused to honor the agreement, the district court ordered that the farmland be distributed to Neal and Thomas. The court of appeals reversed. The Supreme Court reversed, holding that Neal and Thomas were entitled to the 200 acres under Bach's will. View "In re Estate of Bach" on Justia Law

The Supreme Court reversed the judgment of the court of appeals construing a letter that Defendants submitted to the district court under Minn. R. Gen. Proc. 115.11 as a permissible tolling motion under Minn. R. Civ. App. P. 104.01, subd. 2 and accepting jurisdiction, holding that a request for permission to file a motion to reconsider pursuant to Rule 115.11 does not toll the time for appeal.In this dispute between commercial property owners over the allegedly fraudulent behavior of one of the owners during the refinancing of the property Defendants moved for summary judgment, arguing that Plaintiffs' claims were untimely and lacked merit. The district court granted the motion and dismissed the complaint with prejudice. Thereafter, Defendants filed the letter at issue seeking to correct an erroneous reference in the order. The district court issued an amended summary judgment order without directly responding to the letter. Defendants appealed, arguing that the appeal was untimely. The court of appeals accepted jurisdiction. The Supreme Court reversed, holding that the appeal was untimely, and therefore, the court of appeals erred by accepting jurisdiction. View "Stern 1011 First Street South, LLC v. Gere" on Justia Law

The Supreme Court affirmed the order of the court of appeals dismissing Appellant's appeal from the district court's denial of his petition to create a constructive trust, holding that the court of appeals did not err by dismissing the appeal for lack of appellate jurisdiction.Joseph Figliuzzi, who created a trust for holding wetland credits, sought to hold the credits in his own name rather than in the trust. After Figliuzzi died, Appellant brought this action seeking to confirm that the trust owned the subject credits and to establish a constructive trust over the disputed credits. The district court denied relief, concluding that Figliuzzi owned the credits at the time of his death. The court of appeals dismissed Appellant's ensuing appeal for lack of jurisdiction. The Supreme Court affirmed, holding (1) because the order being appealed from lacked finality, it could not be appealed under Minn. R. Civ. App. P. 103.03(g); and (2) the district court's order was not a denial of injunctive relief. View "In re Estate of Joseph Rocco Figliuzzi" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's complaint alleging that Defendant violated the Minnesota Bond Allocation Act, Minn. Stat. 474A.01-.21, holding that Plaintiff alleged a violation of the Act sufficient to support her common-law and statutory claims.Plaintiff, who leased and lived in one of Defendant's rent-restricted housing units, brought this putative class action alleging that Defendant violated the Act, which imposes rent limits on residential rental projects financed with tax-exempt municipal bonds. The district court dismissed the complaint for failure to state a claim upon which relief can be granted, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff stated a viable action, and therefore, the district court erred in dismissing her complaint. View "Thompson v. St. Anthony Leased Housing Associates II, LP" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for four counts of possession of pornographic work involving minors, holding that, assuming that Defendant had a reasonable expectation of privacy in his online cloud storage account, the government's search of his account was lawful under the private search doctrine.At issue in this case was the conduct of law enforcement officers who discovered digital child pornography files stores in Defendant's cloud storage account with Dropbox. Defendant moved to suppress the evidence acquired from his Dropbox account, arguing that the search violated his Fourth Amendment rights. The district court denied the motion to suppress. The court of appeals affirmed. The Supreme Court affirmed, holding that the warrantless search of Defendant's online cloud storage account did not violate the Fourth Amendment. View "State v. Pauli" on Justia Law