Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court held that certain congressional districts were unconstitutional for purposes of the 2022 primary and general elections, enjoined their use in these elections, and adopted the congressional district boundaries as set forth in Appendices A and B to this order.Two sets of plaintiffs initiated actions in, respectively, Carver County District Court and Ramsey District Court alleging that the current congressional and legislative election districts were unconstitutionally malapportioned in light of the 2020 census. The Chief Justice appointed a panel to hear and decided the consolidated action and any other challenges to the congressional and legislative districts. The Supreme Court held that the existing congressional districts were unconstitutional and adopted the congressional district boundaries as set out in Appendices A and B to this order. View "Wattson v. Simon" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's fifth petition for postconviction relief, holding that the district court did not abuse its discretion in denying postconviction relief.After a jury trial, Defendant was found guilty of first-degree murder and sentenced to life in prison. At issue was Defendant's fifth postconviction petition for relief alleging a newly discovered evidence claim. The district court concluded that Defendant failed to satisfy the newly discovered evidence exception in Minn. Stat. 590.01, subd. 4(b)(2) and denied the petition. The Supreme Court affirmed, holding that the district court (1) properly excluded certain recordings of jail calls and an affidavit as inadmissible hearsay; and (2) did not abuse its discretion in denying Defendant's request for a new trial. View "Bobo v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's judgment concluding that Tennis Sanitation, LLC breached the contract between the parties and that, as a result of the breach, Vermillion State Bank suffered $1.92 million in damages, holding that the court of appeals did not err.Tennis repudiated an alleged oral contract it negotiated with Vermillion for its purchase of certain assets, including garbage trucks and customer routes, of a trash collection business in bankruptcy. After Tennis's repudiation, Vermillion sold the assets to another company at a significantly lower price. Vermillion then sued Tennis for breach of contract. The district court entered judgment for Vermillion. The court of appeals affirmed. The Supreme Court affirmed, holding that hybrid contract involving goods and non-goods should be interpreted based on the predominant purpose of the contract. View "Vermillion State Bank v. Tennis Sanitation, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the district court's dismissing of Plaintiff's breach of fiduciary duty claim against Defendant, an attorney, holding that the court of appeals erred in its analysis for determining whether experts were required in this case.Plaintiff brought a breach of fiduciary duty claim against Defendant, alleging that Defendant took unfair of the parties' professional relationship and that their business dealings were unfair to Plaintiff. The district court granted Defendant's motion for summary judgment. The court of appeals affirmed on the grounds that Plaintiff did not provide the expert-disclosure affidavits as required by Minn. Stat. 544.42. The Supreme Court reversed, holding (1) section 544.42 applies to breach of fiduciary duty claims; but (2) the court of appeals erred in its analysis for determining whether experts were required in this case. View "Mittelstaedt v. Henney" on Justia Law

The Supreme Court affirmed the decision of the tax court concluding that three clinics - Perham Clinic, Ottertail Clinic, and New York Mills Clinic - were not subject to property tax because they clinics were exempt under Minn. Stat. 447.31, subd. 6, holding that there was no error.The exemption at issue is provided for hospital districts. At issue on appeal was whether to classify the three medical clinics that were owned and operated by Perham Hospital District as taxable or exempt. Otter Tail County classified the clinics as commercial and thus subject to property tax, concluding that the tax exemption at issue was available to hospitals and not to clinics. After a trial, the tax court concluded that the clinics were exempt from tax under Minn. Stat. 447.31, subd. 6. The Supreme Court affirmed, holding that the tax court did not clearly err in finding that the District used the clinics to improve and run Perham Hospital during the tax years at issue. View "Perham Hospital District v. County of Otter Tail" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the district court declaring that the unanimity requirement in Minn. Stat. 638.02, subd. 1 violates Minn. Const. art. V, 7, holding that the statutory provisions at issue are not unconstitutional.Defendant was convicted of first-degree manslaughter and later filed an application for a pardon absolute. The application was denied because the Board of Pardons members did not unanimously agree that Defendant was entitled to a pardon. Defendant then filed this action for declaratory and injunctive relief. The district court concluded that the unanimity requirement violates Article V, Section 7 but does not violate Article III, Section 1 of the Minnesota Constitution. The Supreme Court reversed in part, holding that the unanimity requirement does not violate either Article V, Section 7 or Article III, Section 1. View "Shefa v. Ellison" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying as time-barred Defendant's second petition for postconviction relief, holding that even if the facts alleged in the petition were proven at an evidentiary hearing, Defendant still would not be entitled to relief.Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed both Defendant's conviction on direct appeal and the denial of his first postconviction motion. In his second postconviction petition, Defendant argued the the district court lacked subject matter jurisdiction, that he had discovered new evidence, prosecutorial misconduct, and ineffective assistance of counsel. The district court denied the petition. The Supreme Court affirmed, holding that Defendant's claims either failed on the merits or were time barred. View "Martin v. State" on Justia Law

The Supreme Court held that the unanimity requirement in Minn. Stat. 638.02m, subd. 1 does violate either Minn. Const. art. V, 7 or Minn. Const. art. III, 1.Defendant was convicted of first-degree manslaughter. When Defendant later filed an application for a pardon absolute, the members of the Board of Pardons denied it. Attorney General Keith Ellison and Governor Tim Walz voted to grant the application, and Chief Justice Lorie Gildea voted to deny it. Defendant's application was ultimately denied. Defendant then filed an action for declaratory and injunctive relief. The district court held (1) the unanimity requirement violates article V, section 7, which gives the governor sufficient and separate power to grant pardons; and (2) the unanimity requirement violates article III, section 1 because the state Constitution explicitly provides for the chief justice's participation in the pardon process. The Supreme Court reversed in part and affirmed in part, holding that the statutory provisions did not violate article V, section 7 or article III, section 1 of the Minnesota Constitution. View "Shefa v. Ellison" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Defendant's prior conviction counted as a felony in his criminal history score under Minn. Stat. 152.025, subd. 4(a), holding that there was no error.In 2019, Defendant was convicted and sentenced for domestic assault. Defendant's criminal history included a 2005 petty misdemeanor for marijuana possession and a 2007 fifth-degree controlled substance conviction. At issue on appeal was whether Defendant's 2007 conviction should count as a gross misdemeanor or as a felony in calculating Defendant's criminal history score. The district court concluded that Defendant's petty misdemeanor was a prior conviction under chapter 152 and so his 2007 conviction was properly counted as a felony. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant's 2005 petty misdemeanor qualified as a prior conviction under section 152,025, subd.4(a). View "State v. Morgan" on Justia Law

The Supreme Court reversed Defendant's conviction of illegal possession of ammunition, holding that the district court erred by denying Defendant's motion to suppress.During a traffic stop, law enforcement officers questioned Defendant, who was a passenger in the stopped vehicle, regarding the conditions of his pretrial release. After Defendant was arrested for violating a condition of his pretrial release, a pat-down search revealed ammunition in Defendant's pocket. Defendant filed a motion to suppress, arguing that the officer’s questions about the conditions of his pretrial release improperly expanded the scope of the traffic stop. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) violation of a condition of pretrial release does not constitute criminal activity allowing a law enforcement officer to expand the scope of a traffic stop; and (2) the officer's questioning of Defendant about the conditions of his pretrial release exceeded the permissible scope of a traffic stop. View "State v. Sargent" on Justia Law