Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the tax court denying summary judgment to Rainbow Early Education Center, an early childhood center, on its claim for a tax exclusion as a seminary of learning under Minn. Const. art. X, 1 and Minn. Stat. 272.02, subd. 5, holding that the tax court did not correctly apply the standard set forth in State v. Northwestern Preparatory School, 83 N.W.2d 242 (Minn. 1957).Rainbow petitioned for a property tax exemption, claiming status as a seminary of learning. Because prior decisions concerning the meaning of the phrase "seminaries of learning" centered on secondary or postsecondary institutions Rainbow cited licensure, facilities, programming, and rating by a government-administered best practices program in support of its claim that it was entitled to a property tax exemption . The tax court granted summary judgment to the County. The Supreme Court reversed, holding (1) an institution is an exempt seminary of learning when it has an educational purpose, provides a broad general education, and does so in a thorough and comprehensive manner; and (2) Rainbow presented uncontroverted evidence of each element. View "Under the Rainbow Early Education Center v. County of Goodhue" on Justia Law

The Supreme Court reversed the decision of the tax court finding that the Data Practices Act, Minn. Stat. 13.01-.90, prohibited Hennepin County from disclosing certain nonpublic data contained within its expert appraisal report and ordering portions of the County's expert report containing those data to be excluded at trial, holding that the tax court erred.At issue in the underlying property tax trial involving G&I IX OIC LLC was an expert report containing nonpublic data about comparable rental properties to establish the market value of G&I's office tower. The tax court determined that the County could not use the nonpublic data at trial without first securing the court's approval. The Supreme Court reversed, holding that the tax-code provision of Minn. Stat., subdivision 3, governed in this case and permitted the County to use its expert appraisal report, which were included in nonpublic data in "assessor's records" at trial. View "Tax Court v. County of Hennepin" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the court of appeals reversing the district court's issuance of an alternative writ of mandamus to compel the Minneapolis Mayor and the Minneapolis City Council to comply and fund a minimum number of police officers, holding that the City Council was meeting its uncontested clear legal duty to fund at least 731 sworn police officers.A group of north Minneapolis residents sought a writ of mandamus to compel the Mayor and City Council to employ and fund at least 0.0017 sworn police officers per resident. The district court concluded that the Minneapolis City Charter created a clear legal duty to employ and fund 0.0017 officers per resident and that Defendants had failed to meet this duty. The court of appeals reversed, holding (1) the Mayor did not have a clear legal duty to employ a minimum number of officers, and (2) the City Council was satisfying its clear legal duty to fund 0.0017 officers per resident. The Supreme Court reversed and remanded in part, holding (1) the Mayor had a clear legal duty to employ 0.0017 sworn police officers per Minneapolis resident; and (2) the City Council was meeting its clear legal duty in this case. View "Spann v. Minneapolis City Council" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of threats of violence in violation of Minn. Stat. 609.713, subd. 1, holding that Defendant's constitutional right to a speedy trial was not violated in this case.At issue was whether trial delays caused by judicial orders issued in response to the COVID-19 global pandemic weighed against the State in the evaluation of whether Defendant's constitutional right to a speedy trial had been violated. The Supreme Court answered the question in the negative and affirmed Defendant's conviction, holding (1) trial delays caused by statewide orders issued in response to the COVID-19 global pandemic statewide orders do not weigh against the State; and (2) the State brought Defendant to trial quickly enough so as not to violate his constitutional right to a speedy trial. View "State v. Paige" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the order of the district court granting summary judgment in favor of the County of Anoka in this case concerning the proper interpretation of Minn. Stat. 103D.311, which governs the appointment of watershed district managers, holding that several of the district court's conclusions were erroneous.The City of Circle Pines brought this action alleging that the County followed an improper procedure in reappointing Patricia Preiner, a resident of the City of Columbus, to the Rice Creek Watershed District board of managers. The district court granted summary judgment for the County, ruling that section 103D.311 unambiguously allowed the County the discretion to appoint a manager from any city that neglected to submit a list of nominees. The Supreme Court reversed, holding (1) section 103D.311 is ambiguous; (2) the statute requires the aggregate list of city nominees to have three nominees to be valid; and (3) the requirement under the statute that counties appoint managers from city nominees applies unless those nominees cannot fairly represent the various hydrologic areas in the watershed district. View "City of Circle Pines v. County of Anoka" on Justia Law

In this sexual assault case, the Supreme Court granted a writ of prohibition sought by Hope Coalition to prohibit the district court from requiring it to disclose records concerning the alleged victim's counseling to the district court for in camera review, holding that the district court's actions were unreasonable.Hope Coalition invoked the sexual-assault-counselor privilege under Minn. Stat. 595.02, subdivision 1(k) to prevent Defendant's motion in his criminal prosecution seeking disclosure of records concerning the alleged victim's counseling. The district court concluded that compliance with the subpoena to produce the records protected by the sexual-assault-counselor privilege for in camera review was reasonable without addressing that privilege. The Supreme Court reversed, holding (1) the plain language of the statute creates a privilege for sexual assault counselors that cannot be pierced in a criminal proceeding without the victim's consent; and (2) the district court's denial of Hope Coalition's motion to quash the subpoena seeking the records at issue was unauthorized by law. View "State v. Conrad" on Justia Law

The Supreme Court affirmed Defendant's sentence for aiding an offender as an accomplice after the fact for her role in concealing evidence of a murder that her husband committed, holding that the sentence did not exceed the statutory maximum.Defendant pleaded guilty to aiding an offender to avoid arrest and being an accomplice after the fact. After a sentencing hearing, the district court sentenced Defendant to forty-eight months in prison. The Supreme Court affirmed, holding that the district court did not err in sentencing Defendant to forty-eight months in prison for being an accomplice after the fact. View "State v. Miller" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the decision of the district court to deny Defendant's motion to withdraw his guilty plea, holding that Defendant did not meet his burden of proving that his plea was invalid.Defendant pleaded guilty to the charge of violating a domestic abuse no contact order. On appeal, Defendant argued that a manifest injustice occurred that required a plea withdrawal due to his failure personally to admit his previous convictions during his plea colloquy, which made his plea inaccurate. The court of appeals agreed and reversed. The Supreme Court reversed, holding (1) Defendant did not meet his burden to establish a manifest injustice requiring a plea withdrawal or that his plea was otherwise invalid; and (2) therefore, the court of appeals committed reversible error in reversing Defendant's conviction on the basis that his guilty plea was invalid. View "State v. Epps" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the State presented sufficient evidence to support the conviction and that the sentence imposed upon Defendant was not unconstitutionally cruel.After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and sentence, holding (1) there was sufficient evidence in the record to support the conviction; and (2) a mandatory sentence of life without the possibility of release is not unconstitutionally cruel under Minn. Const. art. I, section 5 when imposed on a twenty-one-year-old defendant who has been convicted of first-degree premeditated murder. View "State v. Hassan" on Justia Law

The Supreme Court affirmed the order of the court of appeals remanding this case to the district court to have two jurors who testified in private during a post-trial Schwartz hearing questioned again in a public hearing, holding that the court of appeals properly concluded that the district court erred when it closed the first part of the Schwartz hearing to the public.After a jury trial, Defendant was found guilty of second-degree murder. Thereafter, one of the jurors suggested that she might have introduced extraneous information during deliberations. The district court held a Schwartz hearing to determine the effect of this information on the verdict but divided the hearing into two parts because of jurors' scheduling conflicts. The court of appeals ruled that the district court erred when it closed the first part of the Schwarz hearing to the public. The Supreme Court affirmed, holding (1) a post-trial Schwartz hearing is more analogous to a pretrial suppression hearing; and (2) the appropriate remedy was to remand to conduct a public Schwartz hearing. View "State v. Jackson" on Justia Law