Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the district court granting Respondents' petition to strike a revised question from the ballot, holding that the district court erred.Respondents filed a petition to correct the language the Minneapolis City Council had approved for a question that was on the ballot for the 2021 city election. The district court granted the petition, and the City Council approved revised ballot language that same day. Respondents then (1) moved to amend the judgment and injunction to encompass the revised ballot language, and (2) filed a petition under Minn. Stat. 204B.44 asking the district court to strike the revised question from the ballot. The district court granted the motion and the petition, concluding that the revised ballot language was misleading. The Supreme Court reversed, holding that the current ballot language met the standard set forth in Breza v. Kiffmeyer, 723 N.W.2d 633 (Minn. 2006). View "Samuels v. City of Minneapolis" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the judgment of the district court in this case arising out of a dispute between the children of Lawrence and Phyllis Schwagerl over the disposition of assets owned by Lawrence's trust before his death, holding that the court of appeals erred in part.The assets in this case included undivided half-interests in more than 700 acres of farm real estate owned by the family, as well as Lawrence and Phillis's residence and surrounding yard. The district court determined (1) the Lawrence Trust agreement created a family trust upon Lawrence's death and that his undivided half-interest in the farm real estate was distributed to that trust, and (2) Phillis waived her right to Lawrence's undivided half-interest in the couple's personal residence at the time of his death by intentionally leaving ownership of that property within the family trust. View "In re Trust of Lawrence B. Schwagerl" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that a law enforcement officer lawfully expanded the scope of the underlying traffic stop in this case, holding the court of appeals did not err.Defendant was convicted of first-degree driving while impaired and possessing an opened bottle or receptacle containing an alcoholic beverage. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence because the officer impermissibly expanded the scope of the underlying traffic stop by asking Defendant if he had consumed any beer from the open case in his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances known to the officer and the legitimate inferences to be drawn from them raised a reasonable articulable suspicion of other criminal activity sufficient to expand the scope of the traffic stop. View "State v. Taylor" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) upholding a compensation judge's order requiring Employer to reimburse Employee for medical cannabis, holding that the WCCA erred.Employee was injured while working for Employer. After multiple rounds of medical intervention proved to be unsuccessful, Employee's doctor certified her for participation in the state's medical cannabis program. Employee sought reimbursement for the cost of the cannabis from Employer. Employer asserted in response that the federal prohibition in the federal Controlled Substances Act (CSA), 21 U.S.C. 801-971, on the possession of cannabis preempted the requirement under Minnesota law that an employer pay for an injured employee's medical treatment when that treatment is medical cannabis. The WCCA declined to address the preemption argument and upheld the compensation judge's order. The Supreme Court reversed, holding (1) the WCCA lacked subject matter jurisdiction to determine the preemption issue; and (2) the CSA preempted the compensation court's order mandating Employer to pay for Employee's medical cannabis. View "Musta v. Mendota Heights Dental Center & Hartford Insurance Group" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's claims for postconviction relief, holding that the district court did not abuse its discretion.After a jury trial, Defendant was convicted of first-degree premeditated murder as a principal and as an aider and abettor and sentenced to life in prison without the possibility of release. Defendant later moved for postconviction relief, alleging that the State committed Brady violations during his criminal trial and other grounds for relief. The district court denied Defendant's petition for postconviction relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant was not entitled to relief on his claims for postconviction relief. View "Thoresen v. State" on Justia Law