Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed in part the decision of the court of appeals affirming in part and reversing in part the judgment of the district court granting the Attorney General's motion to compel responses to a civil investigative demand, holding that the demand must be narrowed and that the court of appeals erred in limiting the scope of the demand.The Attorney General issued the demand at issue under Minn. Stat. 8.31 to Madison Equities, Inc. and nine of its subsidiary and related companies (collectively, Madison Group) to investigate allegations of wage theft. The Madison Group sought a protective order from the district court, arguing that the demand was overbroad. The Attorney General, in turn, moved to compel responses to the demand. The district court denied the Madison Group's motion and granted the Attorney General's motion. On appeal, the court of appeals limited the demand to information related to security guards from only four of the Madison Group entities. The Supreme Court reversed in part and remanded the case, holding that the court of appeals (1) correctly determined that the definition of "worker" in the demand must be narrowed; and (2) erred in limiting the scope of the demand to certain of the companies. View "Madison Equities, Inc. v. Office of Attorney General" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court ordering Defendant to pay a total of $87,500 in restitution to two victims, holding that the district court did not consider Defendant's ability to pay as required by Minn. Stat. 611A.045, subd. 1.In the instant case, neither the parties nor the county probation office provided meaningful information to the district court about Defendant's income, resources, and obligations. Further, the record did not reflect that the district court considered Defendant's ability to pay. The Supreme Court reversed the restitution order, holding (1) a district court must expressly state, either orally or in writing, that it has considered a defendant’s income, resources, and obligations when ordering restitution; and (2) the record must include sufficient evidence about the defendant’s income, resources, and obligations to allow a district court to consider the defendant’s ability to pay. View "State v. Wigham" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of obtaining public assistance to which he was not entitled through willfully false statements, holding that there was no error in the proceedings below.At issue on appeal was the correction interpretation of Minn. Stat. 256.98, subd. 1, which prohibits wrongfully obtaining public assistance. Defendant was found guilty of violating the statute. On appeal, Defendant argued that the language of the statute required the State to prove that he intended to defeat the purposes of all of the public assistance programs enumerated within the statute. The Supreme Court affirmed, holding (1) the plain language of section 256.98 does not require a defendant to act with an "intent to defeat the purposes of" every listed public assistance program listed in the statute; and (2) there was sufficient evidence to prove that Defendant acted with the intent to defeat the purposes of two of the listed programs. View "State v. Irby" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of prohibition sought by Polaris, Inc. to prevent disclosure of a report in the underlying product-liability lawsuit brought by Colby Thompson, holding that Polaris failed to demonstrate that it was entitled to the writ.Under federal consumer safety processes and policies Polaris was subject to a government safety investigation and potential enforcement action. To conduct an audit into its safety process and policies, Polaris retained outside counsel, who provided a thirty-two page report that included recommendations to improve compliance performance. In the underlying litigation with Thompson, Polaris inadvertently disclosed the audit report during discovery and then sought to claw the document back, asserting that it was protected by the attorney-client privilege. The district court denied the claw-back request but did permit redactions of the report's legal advice. Polaris' request for a writ of prohibition followed. The Supreme Court affirmed the denial of the writ, holding that the district court did not clearly err by finding that the predominant purpose of the report was business advice and was therefore discoverable. View "In re Polaris, Inc. v. Polaris, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's presentence motion to withdraw his guilty plea, holding that there was no error.During his plea hearing, Defendant admitted that he offered to sell thirteen grams of heroin but that only 8.906 grams of heroin were delivered to the buyer. Defendant subsequently moved to withdraw his guilty plea, arguing that the factual basis for his guilty plea was inaccurate because he did not admit that ten or more grams of heroin were delivered to the buyer in this case. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, under Minn. Stat. 152.021, subd. 1(3), individuals sell ten or more grams of heroin when they offer to sell ten or more grams of heroin, even if the individual delivers less than ten grams of heroin to the buyer. View "State v. Fugalli" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming in part and reversing in part Defendant's convictions, holding that Minn. Stat. 634.093 requires a defendant's confession to be corroborated by independent evidence reasonably tending to prove that the specific offense charged was committed.Defendant confessed to committing multiple acts of criminal sexual conduct against his minor stepdaughter. One such incident allegedly occurred when the two were scouting for deer. A jury found Defendant guilty of five counts of criminal sexual conduct, including one count based on the deer-scouting incident. The court of appeals reversed the deer-scouting incident conviction based on a lack of independent evidence corroborating Defendant's confession to that specific incident. The Supreme Court affirmed, holding that the State failed to introduce sufficient evidence to corroborate Defendant's confession to the deer-scouting incident. View "State v. Holl" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing this insurance dispute for failure to state a claim, holding that resident-relative exclusions do not frustrate the purpose behind the abolition of interfamilial tort immunities.Appellants' son was seriously injured by a pet dog at his grandparents' residents. Appellants, on behalf of their son, filed a declaratory judgment action against Respondent after Respondent denied their claim for homeowner's insurance benefits on the basis a resident-relative exclusion in the relevant policy. In their complaint, Appellants claimed that resident-relative exclusions, inter alia, frustrate the purpose of the abolition of interfamilial tort immunities. The district court dismissed the complaint for failure to state a claim, and the court of appeals affirmed. The Supreme Court affirmed, holding that the resident-relative exclusion in the homeowner's insurance policy at issue was enforceable. View "Poitra v. Short" on Justia Law

The Supreme Court affirmed the judgment of the district court construing Defendant's motion to correct his sentence as an untimely third postconviction petition, holding that the district court did not err.After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life without the possibility of release. The Supreme Court affirmed. Defendant subsequently filed two petitions for postconviction relief, which the district court denied. Thereafter, Defendant filed a motion to correct his sentence. The district court construed the motion as a third postconviction petition and dismissed it as untimely. The Supreme Court affirmed, holding that the district court (1) did not err in treating Defendant's motion as a third postconviction petition; and (2) did not err in summarily denying the petition. View "Bolstad v. State" on Justia Law

The Supreme Court affirmed the district court's decision summarily denying Defendant's second petition for postconviction relief, holding that the district court did not err in denying Defendant's petition for postconviction relief without holding an evidentiary hearing.Defendant was convicted of first-degree premeditated murder on an accomplice-liability theory. In her second petition for postconviction relief Defendant asserted that statements made in an affidavit by her co-defendant were newly discovered evidence that cast doubt on her guilt. The district court denied relief, concluding that the statements were not newly discovered evidence. The Supreme Court affirmed, holding that the facts in Defendant's affidavit were not "newly discovered," and therefore, Defendant's claim was untimely. View "Onyelobi v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court's grant of summary judgment to Respondents and dismissing Appellant's wrongful death action on grounds of common law official immunity and vicarious official immunity, holding that the court of appeals erred.Four-year-old Eric Dean was killed by his father's girlfriend following at least seven separate reports from different sources of suspected abuse of Eric. Appellant brought this action against Pope County and three child protection workers (collectively, Respondents) alleging that the child protection workers' negligence in performing their duties under the Reporting of Maltreatment of Minors Act (RMMA), Minn. Stat. 626.556, was the proximate cause of Eric's death. The district court granted summary judgment for Respondents on immunity grounds. The court of appeals affirmed. The Supreme Court reversed, holding (1) the RMMA abrogated the defense of official immunity as to duties undertaken to comply with subdivisions 10 and 11 of section 626.556 or related rules and provisions of law; (2) statutory discretionary function immunity under Minn. Stat. 466.03, subd. 6 did not apply in this case; and (3) a genuine issue of material fact existed precluding summary judgment. View "Jepsen v. County of Pope" on Justia Law