Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree felony murder and his sentence of life imprisonment as well as the denial of his petition for postconviction relief, holding that sufficient evidence supported the conviction and that Defendant's constitutional and ineffective assistance of counsel challenges failed.After he was convicted Defendant filed a direct appeal. The Supreme Court stayed the appeal to allow Defendant to pursue postconviction relief. The district court denied the petition following an evidentiary hearing. The Supreme Court lifted the stay, consolidated Defendant's appeal, and affirmed, holding (1) the evidence was sufficient to support the conviction; (2) Defendant's arguments related to a witness's identification testimony failed; (3) Defendant's right to a speedy trial was not violated; and (4) Defendant's claims of ineffective assistance of counsel were without merit. View "State v. Jones" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that decisions made under Minn. Stat. 43A.33 are quasi-judicial administrative decisions subject to certiorari review by the court but reversed its holding that the Bureau of Mediation Services was a proper party to the appeal, holding that the Bureau was not a proper party to the certiorari appeal.When the Minnesota Department of Corrections sought certiorari review of an arbitrator's decision granting Appellant's appeal from the discharge of his employment at the Minnesota Department of Corrections, Appellant challenged the court of appeals' jurisdiction to hear the appeal, arguing that review must be undertaken by the district court. The court of appeals upheld the arbitrator's decision. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant and the Department were not parties to an arbitration agreement that invoked the judicial review procedures of the Uniform Arbitration Act; (2) the decision of an arbitrator appointed according to section 43A.33 is a quasi-judicial determination of an inferior tribunal reviewable via writ of certiorari at the court of appeals; and (3) the Bureau was not a proper party to this appeal because it had no legal or equitable interest in the outcome. View "Minn. Department of Corrections v. Knutson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's fourth postconviction petition alleging alleging a claim of newly-discovered evidence, holding that the district court did not abuse its discretion.Appellant was convicted of six counts of aiding and abetting first-degree murder for the benefit of a gang and sentenced to life in prison without the possibility of release. In his fourth postconviction petition, Defendant asserted a successive claim of newly discovered evidence based on three affidavits. The district court denied the petition, determining that the claims were time-barred. The Supreme Court affirmed, holding that the district court properly concluded that Appellant's fourth petition for postconviction relief was untimely. View "Caldwell v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a mandatory five-year conditional release term in connection with Defendant's conviction of fourth-degree assault of a secure treatment facility employee of the Minnesota Sex Offender Treatment Program (MSOP), holding that there was a rational basis for the sentencing disparity at issue in this case.After he was convicted, Defendant filed a petition for postconviction relief arguing that Minn. Stat. 609.2231, subd. 3a(e) required the district court to impose different sentences for the same conduct based on the defendant's civil commitment status, and therefore, his sentence violated his equal protection rights under the United States and Minnesota Constitutions. The district court denied postconviction relief, and the court of appeals affirmed. The Supreme Court affirmed, holding that the disparate sentence survived rational basis review. View "State v. Lee" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court applying the endangerment standard of the child-custody modification statute, Minn. Stat. 518.18(d)(iv), to a noncustodial parent's motion for joint legal custody of the parties' child based on their prior stipulation to apply the statutory best-interests standard set forth in Minn. Stat. 518.18(d)(i), holding that the district court erred.The noncustodial parent's modification motion in this case was expressly predicated on section 518.18(d)(i), which provides that the statutory best-interests standard set forth at Minn. Stat. 518.17 applies if the parties previously agreed in a court-approved writing to the application of that standard. The district court denied the motion for custody modification without holding an evidentiary hearing. The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred by requiring the noncustodial parent to establish a prima facie case for a change in custody based on the statutory endangerment standard in section 518.18(d)(iv). View "Woolsey v. Woolsey" on Justia Law

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