Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions on two counts of first-degree burglary and two counts of second-degree assault, holding that there was no error.After the jury announced its verdicts in this case Defendant exercised his right to poll the jury. While the record showed that the jury was composed of twelve members, the transcript of the jury polling contained only eleven responses. On appeal, Defendant argued that the evidence was insufficient to prove that he was afforded his constitutional right to a unanimous, twelve-person jury. The court of appeals affirmed. The Supreme Court affirmed, holding (1) sufficient evidentiary support in the record established that Defendant was found guilty by a twelve-member jury; and (2) Defendant was not entitled to relief for any error in the jury polling because it was not a structural error, and Defendant did not satisfy the plain error doctrine. View "State v. Bey" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the dismissal of Appellants' claims for defense and indemnification of a federal lawsuit from the State under the State Tort Claims Act, Minn. Stat. 3.736, subd. 9, holding that Appellants were not eligible for defense and indemnification under the Act.After the Mille Lacs Band of Ojibwe sued Appellants - Mille Lacs County Attorney Joseph Walsh and Mille Lacs County Sheriff Don Lorge - in federal court Appellants sought indemnification and defense from the State. At issue was whether Appellants were "employees of the state" under the Act when the undertook the conduct that was the subject of the federal lawsuit. The district court dismissed the complaint for failure to state a claim, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) for purposes of defense and indemnification under the Act, county sheriffs generally do not act on behalf to the State when they enforce state criminal laws, and county attorneys generally do not act on behalf of the State when they prosecute state; and (2) Appellants were not acting on behalf of the State in an official capacity for purposes of defense and indemnification under the Act. View "Walsh v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's denial of Appellant's postconviction petition in which she argued that her restitution order should be reduced, holding that there was no error or abuse of discretion.Appellant was convicted of medical assistance fraud for submitting fraudulent Medicaid claims to the Minnesota Department of Human Services through a company she owned and operated. The district court convicted Appellant of racketeering and ordered her to pay a $2.64 million restitution award. In her postconviction motion Appellant argued that her restitution award should be reduced because DHS's economic loss had to account for the economic benefit it received from her offense. The district court denied relief. The Supreme Court affirmed, holding (1) Minn. Stat. 611A.045, subd. 1(a)(1) requires a district court to consider the value of any economic benefits a defendant conferred on a victim when calculating a restitution award; and (2) the district court did not abuse its discretion when it calculated DHS's economic loss. View "State v. Currin" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and aggravated robbery, holding that Defendant was not entitled to relief on any of his claims of error.For the aggravated robbery, the district court imposed a ninety-six-month sentence, reflecting an upward durational departure, and for the first-degree murder the court imposed a consecutive sentence of life without the possibility of release. Defendant later filed a motion to correct his sentence, which the district court denied. The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant's claims under Minn. Stat. 609.135 failed on the merits and that the law of the case doctrine barred Defendant's challenges to his sentence; and (2) Defendant forfeited appellate review of his remaining claim. View "Smith v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals and remanded this case, holding that, for property to be commandeered, the government must exercise exclusive control over or obtain exclusive possession of the property such that the government could physically use it for an emergency management purpose.Appellant brought this suit arguing that his hospitality businesses were commandeered when the Governor issued emergency executive orders in response to the COVID-19 pandemic that imposed capacity limits for dining beginning in March 2020. As the owner of the commandeered property, Appellant argued, he was entitled to just compensation for the government's use under Minn. Stat. 12.34. The district court dismissed the commandeering claim, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the government exercises exclusive physical control or exclusive possession of private property when only the government may exercise control or possession of the property and the owner is denied all control over or possession of the property; and (2) remand to the district court for further proceedings was required in this case. View "Buzzell v. Walz" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers' Compensation Court of Appeals (WCCA) affirming the decision of the compensation judge finding that Respondent sustained an occupational disease of hearing loss and ordering Relator to pay medical benefits under Minn. Stat. 176.135, subd. 5, holding that further proceedings were required.Respondent developed hearing loss after a career of handling occupational safety and health compliance and monitoring workplace noise levels. Respondent filed a claim for workers' compensation benefits against Relator, his most recent employer. The compensation judge ruled in favor of Respondent and denied his claim for permanent partial disability (PPD) benefits. The WCCA affirmed and clarified that the PPD issue was moot because of a Pierringer settlement between Respondent and one of his former employers. The Supreme Court remanded the case, holding (1) the occupational disease finding was supported by the evidence; (2) the award of medical benefits was appropriate under Minn. Stat. 176.135, subd. 5; and (3) the compensation judge did not properly apply the Pierringer settlement precedent, potentially prejudicing Relator's interests. View "Sershen v. Metropolitan Council" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct a sentence, holding that any alleged procedural error was harmless and that the district court was not required to hold a sentencing hearing.Appellant was serving a sentence of life in prison for first-degree murder when he filed a motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9. In his motion, Appellant argued that his sentence was unlawful because he was not present during the pronouncement of his sentence, because the court failed to provide him an opportunity to personally address the court before it imposed a sentence, and because the court violated Minn. Stat. 609.035, subd. 1. The district court held (1) Appellant was correctly convicted of both first- and second-degree murder in violation of Minn. Stat. 609.04, and (2) Appellant's remaining claims were procedurally barred. The Supreme Court affirmed, holding that Appellant was not entitled to relief on his claims of error. View "Greer v. State" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for interference with privacy after concluding that his guilty plea was accurate, holding that Defendant's guilty plea was not accurate because the plain language of Minn. Stat. 609.746, subd. 1(b) did not apply to his conduct.Defendant admitted to using his cell phone to record a women while she was naked in her bed without obtaining her consent and knowing that she likely would not have consented. At issue was whether Minn. Stat. 609.746, subd. 1(b), the statute Defendant pleaded guilty to violating, covered his conduct. The Supreme Court answered the question in the negative, holding that Defendant's conduct was not prohibited by the plain language of section 609.746, subd. 1(b)(2). View "State v. McReynolds" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State of Minnesota Department of Natural Resources (DNR) and dismissing Plaintiff's complaint alleging a violation of the Minnesota Whistleblower Act, Minn. Stat. 181.932, subd. 1(1), holding that there was no error.After Plaintiff, a former regional director with DNR, was terminated she brought this action alleging that her reporting of suspected illegal activity at a hotel where she was staying for a work-related conference caused her termination. The district court granted summary judgment for DNR. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Plaintiff failed to establish a genuine issue of material fact for trial over whether her alleged protected activity was a motivating factor in the decision of the DNR to terminate Plaintiff; and (2) therefore, summary judgment was properly granted. View "Hanson v. State, Department of Natural Resources" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree murder, second-degree intentional murder, and first-degree arson, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that he was entitled to relief based on limitations that the district court placed on the presence of the public in the courtroom in response to the COVID-19 pandemic and that his motion for a hearing under Schwartz v. Minneapolis Suburban Bus Co., 104 N.W.2d 301 (Minn. 1960), and Minn. R. Crim. P. 26.03, subd. 20(6) should have been granted. The Supreme Court affirmed, holding (1) this Court will not exercise its limited discretion under the plain-error doctrine to grant relief based on objected-to limitations that the district court placed on the presence of the public in the trial courtroom due to the COVID-19 pandemic; and (2) the district court did not abuse its discretion by denying Defendant's request for a Schwartz hearing. View "Pulczinski v. State" on Justia Law