Justia Minnesota Supreme Court Opinion Summaries
Sheridan v. Commissioner of Revenue
The Supreme Court affirmed the judgment of the Tax Court upholding that constitutionality of the Minnesota sales or use tax for aircraft purchases, holding that Minn. Const. art. X, 5 bars only the application of duplicative personal property taxes to aircraft.Article X, section 5 allows the Legislature to tax aircraft using the airspace over Minnesota "in lieu of all other taxes." Relators purchased aircraft outside of the state, paid the use tax, paid a separate annual tax imposed on aircraft, and then requested a refund of the use tax. When the refunds were denied, Relators sued the Department of Revenue, arguing that the use tax is unconstitutional under Minn. Const. art. X, 5. The Tax Court granted summary judgment for the Commissioner of Revenue. The Supreme Court affirmed, holding (1) the phrase "[a]ny such tax on aircraft shall be in lieu of all other taxes," as used in article X, section 5, prohibits only the application of duplicative personal property taxes on aircraft; and (2) the tax imposed on aircraft by Minn. Stat. 297A.82 does not violate article X, section 5. View "Sheridan v. Commissioner of Revenue" on Justia Law
Posted in:
Constitutional Law, Tax Law
State v. Malone
The Supreme Court reversed the decision of the court of appeals determining that the district court judge presiding in the prosecution of Defendant was not disqualified or prohibited from presiding over Defendant's case, holding that Minn. R. Crim. P. 26.03, subd. 14(3) was violated when the judge continued to preside over Defendant's case.Defendant was charged with violating a domestic abuse no contact order. During trial, Defendant filed a motion to remove the judge for bias, arguing that the judge had claimed knowledge of a disputed fact and had contacted a potential witness regarding the disputed fact. Defendant's motion was denied, and he was convicted. The court of appeals affirmed. The Supreme Court reversed, holding (1) the judge's conduct during a pretrial proceeding reasonably caused the judge's impartiality to be questioned; (2) subdivision 14(3) was therefore violated when the judge continued to preside over Defendant's case; and (3) reversal of Defendant's conviction and a remand for a new hearing were required to pressure the public's confidence in the judicial system. View "State v. Malone" on Justia Law
Posted in:
Criminal Law
In re Civil Commitment of Kenney
The Supreme Court reversed the decision of the court of appeals reversing the decision of the Commitment Appeal Panel (CAP) granting Appellant's petition for provisional discharge, holding that the record evidence reasonably supported the CAP's decision that the Commissioner for the Department of Human Services failed to prove by clear and convincing evidence that the provisional discharge was not appropriate for Appellant under Minn. Stat. 253D.30.Appellant was adjudicated delinquent of multiple sexual offenses against minors and was later convicted of first-degree criminal sexual conduct against a minor. Appellant was indeterminately committed to the Minnesota Sex Offender Program (MSOP) as a sexually dangerous person and was later transferred to MSOP's Community Preparation Services. Appellant later petitioned for a provisional discharge. The Special Review Board (SRB) recommended that Appellant's request for a provisional discharge be granted and the CAP granted the petition. The court of appeals reversed. The Supreme Court reversed, holding that the record as a whole reasonably supported the CAP's findings and that the CAP did not clearly err by granting Appellant's petition for provisional discharge. View "In re Civil Commitment of Kenney" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
State v. Allwine
The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and the decision of the district court denying Defendant's petition for postconviction relief, holding that there was no error.Specifically, the Supreme Court held (1) the evidence presented at trial was sufficient to support the jury's guilty verdict; (2) the State did not commit prosecutorial misconduct; (3) Defendant's trial counsel did not provide ineffective assistance; and (4) Defendant was not entitled to an evidentiary hearing to consider the opinions of two experts to determine whether a new trial was warranted. View "State v. Allwine" on Justia Law
Posted in:
Criminal Law
Johnson v. Darchuks Fabrications, Inc.
The Supreme Court reversed the judgment of the Workers' Compensation Court of Appeals (WCCA) affirming the determination of the compensation judge that Respondent's treatment with opioid medication for a work-related ankle injury that resulted in a pain condition was compensable as a rare case exception, holding that the rare case exception to the treatment parameters did not apply.The opioid medication in this case was non-compliant with the long-term opioid medication parameter promulgated by the Department of Labor & Industry for that form of treatment. At issue was whether the medication was compensable under the workers' compensation laws as a "rare case" exception. The Supreme Court held that the rare case exception did not apply because the circumstances of this case were not exceptional and thus reversed the decision of the WCCA. View "Johnson v. Darchuks Fabrications, Inc." on Justia Law
Posted in:
Labor & Employment Law, Personal Injury
Walmart Inc. v. Winona County
The Supreme Court affirmed the decision of the court of appeals affirmed the orders of the district court dismissing Appellant's constitutional claims asserting discrimination in the tax assessments of its properties, holding that Appellants' claims were time-barred.Appellant, Walmart, Inc., owned real property in two counties (the Counties). In this action, Walmart claimed that for tax purposes the Counties overvalued the properties or unfairly assessed the properties' value as compared with other similarly situated properties. Appellant asserted that the Counties' international discrimination in their tax assessments violated the Equal Protection Clause and Appellant's right to uniformity in taxation. The district court dismissed the claims as time-barred, and the court of appeals affirmed. The Supreme Court affirmed, holding that Appellant's claims were subject to the limitations period of Minn. Stat. Ann. Chapter 278 and were time-barred. View "Walmart Inc. v. Winona County" on Justia Law
State v. Lufkins
The Supreme Court affirmed the judgment of the district court overruling Appellant's objection to the State's peremptory strike of a prospective juror, holding that Appellant did not meet his burden of proving that the State's race-neutral reason for the strike was a pretext for racial discrimination.Appellant was convicted of first- and second-degree criminal sexual conduct. On appeal, Defendant challenged the State's peremptory strike of the only nonwhite person from the jury venire. The court of appeals affirmed, holding that the prosecutor's explanations for striking the venire-person were race-neutral reasons for the peremptory strike. The Supreme Court affirmed, holding that the district court did not err in denying Appellant's Batson challenge to the State's peremptory strike of the juror. View "State v. Lufkins" on Justia Law
Aili v. State
The Supreme Court reversed the decision of the court of appeals reversing the orders of the district courts in four cases summarily denying postconviction petitions as untimely, holding that the petitions in this case were untimely.At issue was when the two-year time limit prescribed in Minn. Stat. 590.01, subd. 4(c) begins to run for postconviction petitions asserting a claim for relief based on a new, retroactive interpretation of the law. The Supreme Court held (1) the two-year time limit in subdivision 4(c) begins to run from the date the United States Supreme Court or a Minnesota appellate court announces an interpretation of law that forms the basis for a claim that the interpretation is a new rule of law that applies retroactively to the petitioner's postconviction petition; (2) application of the two-year time limit to bar Petitioners' postconviction petitions neither implicated separation of powers concerns nor violated constitutional due process protections; and (3) the postconviction petitions in this case were untimely. View "Aili v. State" on Justia Law
Posted in:
Criminal Law
Hagen v. Steven Scott Management, Inc.
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the judgment of the district court granting summary judgment in favor of Defendant on Plaintiff's complaint alleging that Defendant failed to pay her wages in accordance with Minnesota law, holding that Plaintiff presented sufficient evidence to survive summary judgment.Plaintiff worked as an on-site property caretaker at an apartment complex owned by Defendant. Because she also lived in an apartment on the property, Plaintiff was compensated primarily with credits toward her monthly rent. In her complaint, Plaintiff alleged that Defendant's use of rent credits to pay her wages violated Minnesota law and that Defendant failed to pay her for every hour she worked during her on-call shifts. The district court dismissed all three claims, and the court of appeals affirmed. The Supreme Court reversed in part, holding that the district court erred when it granted summary judgment to Defendant. View "Hagen v. Steven Scott Management, Inc." on Justia Law
Posted in:
Labor & Employment Law
State v. McInnis
The Supreme Court affirmed Defendant's convictions of two counts of first-degree premeditated murder for the deaths of an adult and an infant, holding that the district court erred in failing to suppress Defendant's statement to the police, the error was harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) Defendant's statement to police should have been suppressed because Defendant unambiguously invoked his constitutional right to remain silent during the police interrogation, but the failure to do so by the district court was harmless beyond a reasonable doubt; (2) the evidence was sufficient to prove that Defendant had an intent to kill when he fired the gunshot that killed the infant; and (3) the district court did not abuse its discretion by imposing consecutive sentences. View "State v. McInnis" on Justia Law