Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the rulings of the compensation judge finding that C. Jeremy Lagasse was entitled to contingent fees under Minn. Stat. 176.081, subd. 1(c) and that Larry Horton was entitled to partial reimbursement of fees under Minn. Stat. 176.081, subd. 7, holding that the WCCA incorrectly applied subdivision 1(c) in its standard of review.Horton, who was injured during his employment with Aspen Waste Systems and sought permanent partial disability (PPD) benefits through Aspen's insurer (Insurer), retained Lagasse to represent him in the matter. The compensation judge determined that Lagasse was entitled to contingent fees and that Horton was entitled to partial reimbursement of fees. The WCCA reversed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the WCCA incorrectly applied subdivision 1(c); and (2) the compensation judge and the WCCA incorrectly applied subdivision 7. View "Lagasse v. Horton" on Justia Law

In this insurance coverage dispute the Supreme Court held that State Farm Fire and Casualty Company was not required to cover repair costs to masonry under either Minn. Stat. 65A.10, subd. 1 or the State Farm policy at issue.Before the Supreme Court was the interpretation and application of Minn. Stat. 65A.10, subd. 1, which generally requires replacement cost insurance to cover the cost of repairing damaged property in accordance with state or local authorities' minimum code. Specifically in question was whether State Farm must cover the cost of repairing cracks in masonry that preexisted a storm that damaged the property of St. Matthews. Because the cracks violated the City of St. Paul's building code, the City would not allow St. Matthews to replace the drywall without also repairing the masonry. The district court granted summary judgment to State Farm, determining that because the storm did not damage the masonry, which led to the code upgrade requirements, no coverage existed. The Supreme Court affirmed, holding that, while State Farm was responsible for providing replacement cost coverage to the damaged drywall, it was not required to cover repair costs to the masonry. View "St. Matthews Church of God & Christ v. State Farm Fire & Casualty Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that certification of H.B., who was fifteen years old when he was charged in juvenile court with aiding and abetting second-degree murder and first-degree aggravated robbery, for adult prosecution was proper, holding that certification was required.Delinquency petitions were filed charging H.B. with aiding and abetting first-degree aggravated robbery. The State moved to prosecute H.B. as an adult for the charges, but the district court denied the motion, concluding that the dispositional options available to H.B. did not weigh in favor of certification. The court of appeals reversed and remanded with instructions for the district court to certify H.B. for adult prosecution. The Supreme Court affirmed, holding that the court of appeals correctly found that the district court abused its discretion in determining that the State had not met its burden of proving that retaining H.B. in the juvenile system would not serve public safety. View "In re H.B." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to dismiss the charge of fifth-degree marijuana possession against him for lack of probable cause, holding that the evidence was sufficient to survive a motion to dismiss for lack of probable cause.This case arose when law enforcement officers discovered a plant substance in Defendant's car during a traffic stop. While the State did not test the concentration of THC in the substance before charging gate case, a field test of the substance detected the presence of THC. The district court granted Defendant's motion to dismiss for lack of probable cause. The court of appeals reversed, concluding that chemical testing establishing the THC concentration of substance was not required when there is other sufficient evidence to support a probable cause finding. The Supreme Court affirmed, holding that Defendant's admission that the material in the vehicle was marijuana was sufficient to survive a motion to dismiss the charge of fifth-degree marijuana possession. View "State v. Dixon" on Justia Law

Appellant's petition for postconviction relief and vacating Appellant's conviction and sentence, holding that, in a postconviction proceeding, a district court has the authority under Minn. Stat. 590.04, subd. 1 to order the State to refund restitution that the defendant has paid because of a conviction when that conviction has been invalidated and no retrial will occur.Appellant was convicted of one count of violating Minn. Stat. 609.27, subd. 1(4). Later, subdivision 1(4) was declared facially overbroad and unconstitutional. In her petition for postconviction relief, Appellant asserted that, under Nelson v. Colorado, 581 U.S. __ (2017), she was entitled to a refund of all restitution payments made because of her invalid conviction. The district court vacated her conviction and sentence but denied her request for a refund of restitution on the grounds that it lacked authority to do so. The court of appeals affirmed. The Supreme Court reversed, holding that, in a postconviction proceeding, a district court has the authority to order a refund of restitution when the monetary assessments the defendant paid were imposed solely because of the conviction, the State exacted those assessments, and the conviction was invalidated with no prospect of retrial. View "Byington v. State" on Justia Law

The Supreme Court granted a petition sought by Petitioner seeking an order authorizing Petitioner to send notices about errors on the for the Murray County ballot for the November 8, 2022 general election to all mail ballot voters and to all voters who had already requested an absentee ballot, holding that Petitioner was entitled to relief.The petition asserted that the ballot at issue incorrectly identified the district number for the Minnesota legislative officers as Senate District 22 and House District 22A. Petitioner did not seek to correct the errors on the ballot but sought to send notices regarding the errors and the authority to post the same notice in all Murray County polling places. The Supreme Court granted the petition, holding that Petitioner proposed an appropriate plan to remedy the ballot errors. View "In re Murray County Ballot" on Justia Law

The Supreme Court ordered that Petitioners shall correct the ballot for the November 8, 2022 general election because the general election ballot used by voters in Roseau County and Kittson County omitted information required by Minnesota law.Roseau and Kittson Counties filed petitions under Minn. Stat. 204B.44(a) to correct errors on the November 8, 2022 general election ballot, stating the the ballots in each county failed to include the political party affiliation for federal and state candidates and failed to include the word "incumbent" next to names of currently-serving judicial candidates. The Supreme Court ordered that the counties shall correct the ballot for the November 8, 2022 general election and that Petitioners shall resume delivery of ballots to voters after they receive corrected ballots from their vendors. View "In re Roseau County Ballot for the November 8, 2022 General Election" on Justia Law

The Supreme Court reversed the court of appeals' opinion affirming the district court's conclusion that Minn. Stat. 609.746, subd. 1(e)(2) does not require a defendant to have knowledge of the victim's age when the offense criminalized under this statute is committed, holding that the district court's pretrial ruling was erroneous.Section 609.746, subd. 1(d)(1) makes it a crime secretly to use a device to record or photograph a person in a place where a reasonable person would have an expectation of privacy and is likely to expose their private parts. At issue was subdivision 1(e)(2), which enhances the offense from a gross misdemeanor to a felony of the defendant secretly records a minor under the age of eighteen. Defendant filed a pretrial motion to dismiss the charge against him because the State failed to allege that he knew or had reason to know that the victim was a minor under the age of eighteen when he committed the offense. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that the plain language of section 609.746, subd. 1(e)(2) requires the State to prove that Defendant committed the offense while knowing or having reason to know a person under the age of eighteen was present. View "State v. Galvan-Contreras" on Justia Law

The Supreme Court held that, for double jeopardy purposes, the unit of prosecution for a violation of Minn. Stat. 243.166, subd. 3(a), which requires a predatory offender to register "with the corrections agent as soon as the agent is assigned to the person," is the assignment of a corrections agent, thus affirming in part and reversing in part the decision of the court of appeals.Defendant was convicted and sentenced on seven separate occasions between 2004 and 2018 for failing to register under subdivision 3(a). In August 2019, Defendant refused to sign required paperwork presented by his new corrections agent. In September 2019, Defendant again refused to sign the paperwork presented by a special agent of the Minnesota Bureau of Criminal Apprehension assigned by Defendant's corrections agent. The State charged Defendant with two counts of failing to register under subdivision 3(a). Defendant moved to dismiss the charges on double jeopardy grounds. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Defendant's earlier convictions did not bar prosecution of the August 2019 offense; but (2) the September 2019 offense was barred. View "State v. Larson" on Justia Law

The Supreme Court reversed the decision of the court of appeals in this appeal involving a dispute between a homeowner and an insurance company over prejudgment interest, holding that Minnesota standard fire insurance policy, Minn. Stat. 65A/01, entitled Homeowner to prejudgment interest in an amount that may result in a total recovery that exceeded the policy limit.Homeowner sought coverage from Insurer after fires damaged his home. Insurer denied coverage, leading Homeowner to bring this lawsuit. A jury found for Homeowner. The district court award awarded Homeowner prejudgment interest in a limited amount, finding that Homeowner's total recovery for his personal property loss could not permissibly exceed the policy coverage limit. The court of appeals affirmed. The Supreme Court reversed and remanded the case to the district court to recalculate prejudgment interest, holding that, consistent with past precedent interpreting the standard fire policy, prejudgment interest can lawfully begin accruing before ascertainment of the loss when the insurer denies all liability. View "Else v. Auto-Owners Insurance Co." on Justia Law