Justia Minnesota Supreme Court Opinion Summaries

A charter school was accused of manipulating attendance records to receive excess state aid. The Minnesota Department of Education (the Department) audited the school based on these allegations and found significant discrepancies, leading to a retroactive reduction in aid by over $1.3 million. The school appealed the audit results administratively, but the Department upheld its decision.The school then appealed to the Minnesota Court of Appeals, arguing that the Department should have investigated the allegations under a statute dealing with violations of law (Minn. Stat. § 127A.42) rather than the statute used for auditing aid distributions (Minn. Stat. § 127A.41). The Court of Appeals affirmed the Department's decision, stating that the Department had the authority to conduct the audit under the statute it used.The Minnesota Supreme Court reviewed the case to determine whether the Department was required to investigate under the statute related to violations of law. The court held that the Department had the statutory authority to audit the school under Minn. Stat. § 127A.41 and was not required to investigate under Minn. Stat. § 127A.42, even though the allegations involved potentially illegal activity. The court affirmed the decision of the Court of Appeals, concluding that the Department's actions were within its legal authority. View "Minnesota Internship Center vs. Minnesota Department of Education" on Justia Law

The case involves a challenge to the Re-Enfranchisement Act, which allows individuals convicted of felony-level offenses to vote once they are no longer incarcerated. The plaintiffs, individual taxpayers and the Minnesota Voters Alliance, argued that the Act violates the Minnesota Constitution by restoring only the right to vote rather than all civil rights. They also claimed that using public funds to educate and notify people about the new voting provision is unlawful if the Act itself is unconstitutional.The district court denied the petition, concluding that the plaintiffs lacked standing. The court determined that taxpayer standing requires a challenge to an illegal expenditure or waste of tax money, which the plaintiffs failed to demonstrate. The court also found that the Minnesota Voters Alliance lacked associational standing because its members did not have standing.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court clarified that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. The court held that the plaintiffs could not manufacture standing by pointing to incidental expenditures related to implementing the law. Since the plaintiffs' challenge was primarily against the substantive law itself and not the expenditures, they lacked the necessary standing. Consequently, the Minnesota Voters Alliance also lacked associational standing. The court did not address the merits of the case due to the lack of standing. View "Minnesota Voters Alliance vs. Hunt" on Justia Law

A Wisconsin-based corporation, Uline, Inc., sells industrial and packaging products and employs sales representatives who visit customers in Minnesota. Uline did not pay Minnesota income or franchise taxes for 2014 and 2015, claiming exemption under 15 U.S.C. § 381, which protects certain out-of-state business activities from state taxation. The Minnesota Commissioner of Revenue audited Uline and assessed taxes for those years, arguing that Uline's activities in Minnesota went beyond mere solicitation of orders.The Minnesota Tax Court upheld the tax assessment, finding that Uline's sales representatives engaged in activities beyond solicitation, specifically the preparation of "Market News Notes," which included detailed market research and competitor information. Uline appealed, arguing that these activities were either protected solicitation or de minimis and thus not subject to state taxation.The Minnesota Supreme Court reviewed the case to determine whether Uline's activities created a sufficient nexus with Minnesota to justify the imposition of state taxes. The court found that the preparation of Market News Notes by Uline's sales team went beyond the solicitation of orders because it involved detailed market research that served independent business functions. The court also determined that these activities were not de minimis, as they were regular and systematic, with over 1,600 Market News Notes prepared during the two years in question.The Minnesota Supreme Court affirmed the tax court's decision, holding that Uline's activities in Minnesota were not protected from state income or franchise taxation under 15 U.S.C. § 381 and were not de minimis. Therefore, Uline was subject to Minnesota state taxes for the years 2014 and 2015. View "Uline, Inc. vs. Commissioner of Revenue" on Justia Law

The case involves the fatal shooting of Abdi Abdi on September 10, 2021, in Moorhead, Minnesota. The shooter exited a Chrysler 200, chased Abdi, and shot him multiple times, resulting in Abdi's death. At the time of the shooting, Ibrahim Abdiaziz Isaac, the appellant, was driving on Interstate 94, approximately 100 miles away. The State's theory was that Isaac knew about the shooter's plan to kill Abdi and aided by purchasing the Chrysler 200 for the shooter.A grand jury indicted Isaac for first-degree premeditated murder under an aiding-and-abetting theory. Isaac waived his right to a jury trial, opting for a court trial instead. The district court found Isaac guilty and sentenced him to life in prison without the possibility of release. The court based its decision on circumstantial evidence, including cell phone data, surveillance footage, and eyewitness testimony, which suggested that Isaac and the shooter traveled together to purchase the Chrysler 200 and that Isaac filled the car with gas before the shooter used it to commit the murder.The Minnesota Supreme Court reviewed the case. The court applied a two-step standard of review for circumstantial evidence, first identifying the circumstances proved and then determining whether these circumstances were consistent with guilt and inconsistent with any rational hypothesis other than guilt. The court concluded that the State presented insufficient evidence to prove beyond a reasonable doubt that Isaac knew about the shooter's plan to murder Abdi before the murder occurred. The court found that a rational hypothesis existed that Isaac only learned about the plan after the murder, as evidenced by his actions following a phone call from the shooter after the murder had taken place.The Minnesota Supreme Court reversed Isaac's conviction for first-degree premeditated murder under an aiding-and-abetting theory of criminal liability. View "State of Minnesota vs. Isaac" on Justia Law

The appellant, Earley Romero Blevins, was charged with two counts of second-degree assault-fear with a dangerous weapon after brandishing a machete at a woman and two men on a light rail platform in downtown Minneapolis. Blevins claimed he acted in self-defense after one of the men threatened him with a knife. The incident was captured on surveillance video, which showed Blevins swinging the machete for about a minute, causing the woman and the two men to retreat.The district court found Blevins guilty, concluding that he had a reasonable opportunity to retreat but failed to do so, thus his actions were not justified under Minnesota's self-defense statute. The court sentenced him to a presumptive 39-month prison term. The Minnesota Court of Appeals affirmed the district court's decision, agreeing that the evidence supported the finding that Blevins had a reasonable opportunity to retreat.The Minnesota Supreme Court reviewed the case to address whether the judicially created duty to retreat when reasonably possible applies to a person claiming self-defense in committing the felony offense of second-degree assault-fear with a dangerous weapon. The court held that this duty does apply in such cases, specifically when the weapon is designed to cause death or great bodily harm. The court also concluded that the surveillance video evidence disproved Blevins's claim that he lacked a reasonable opportunity to retreat.The Minnesota Supreme Court affirmed the decision of the court of appeals, holding that Blevins had a duty to retreat when reasonably possible before brandishing the machete and that the evidence showed he had such an opportunity. View "State of Minnesota vs. Blevins" on Justia Law

In February 2019, Keegan Brouillette was found guilty by a jury of two counts of felony domestic assault. On June 24, 2019, the district court sentenced him to 15 months in prison but stayed the execution of the sentence for five years, placing him on supervised probation. Brouillette did not appeal his conviction or sentence. In August 2021, after violating probation, the district court revoked his probation and executed the previously imposed 15-month sentence. Brouillette served his sentence and, in July 2022, filed a petition for postconviction relief, alleging prosecutorial misconduct.The district court denied Brouillette’s petition as untimely, ruling that the August 2021 order executing the sentence was not a new sentence and did not restart the two-year deadline for filing a postconviction petition. The court of appeals affirmed this decision, agreeing that the August 2021 order merely executed the previously imposed sentence without modifying it.The Minnesota Supreme Court reviewed the case to determine whether the two-year limitations period for filing a postconviction petition under Minnesota Statutes section 590.01, subdivision 4(a), began with the original sentencing in June 2019 or the execution of the sentence in August 2021. The court held that the execution of a previously imposed sentence does not constitute a new sentence and, therefore, does not restart the two-year limitations period. The court affirmed the lower courts' decisions, concluding that Brouillette’s petition was untimely as it was filed more than two years after the original sentencing in June 2019. View "Brouillette vs. State of Minnesota" on Justia Law

Melissa Zielinski was convicted of first-degree intentional murder and second-degree intentional murder under aiding-and-abetting theories. The case arose from the robbery and fatal shooting of Karl Henderson. Zielinski and her brother, Nicholas, planned to rob Henderson, who was known to keep large sums of money in a safe. During the robbery, Nicholas shot Henderson. Evidence included DNA on the stolen safe, phone location data, and witness testimony.The district court denied Zielinski’s pretrial motion to suppress evidence obtained from her cell phone and her statements to police, finding the search warrants valid and the police questioning lawful. Zielinski was convicted by a jury and sentenced to life without parole for first-degree murder. Her postconviction petition, alleging ineffective assistance of counsel for not challenging the search warrants on particularity grounds, was summarily denied.The Minnesota Supreme Court reviewed the case. It held that any potential Fourth Amendment violation from police questioning was harmless beyond a reasonable doubt due to the overwhelming evidence of guilt. Similarly, any Sixth Amendment violation from limiting cross-examination of Nicholas was also deemed harmless. The court agreed that the district court erred in entering convictions for both first-degree and second-degree murder, as the latter is a lesser-included offense of the former. The court affirmed the first-degree murder conviction, reversed the second-degree murder conviction, and remanded to vacate the latter. The court also upheld the denial of Zielinski’s postconviction relief petition, finding no reasonable probability that the trial outcome would have been different even if the challenged evidence had been excluded. View "State of Minnesota vs. Zielinski" on Justia Law

The case involves the valuation of two commercial properties in a Woodbury shopping center for tax purposes. The taxpayer, Tamarack Village Shopping Center, LP, challenged Washington County’s initial assessments of the properties, arguing that the tax court should have used an effective rent calculation to account for tenant improvement allowances and deducted lease-up costs due to an above-market vacancy rate.The tax court heard testimony from the taxpayer’s real property asset manager, the taxpayer’s expert appraiser, and the County’s expert appraiser. The tax court largely accepted the County’s appraiser’s opinions and rejected the taxpayer’s appraiser’s opinions. The tax court’s final value conclusions increased the properties’ assessed market values over the county assessor’s initial valuations. The taxpayer appealed, contending that the tax court erred in its analysis by not using an effective rent calculation and by not deducting lease-up costs.The Minnesota Supreme Court reviewed the case. The court held that the tax court did not err in declining to use an effective rent calculation because the taxpayer’s tenant improvement allowances were typical of the market. The court also found that the tax court did not clearly err in declining to deduct lease-up costs from the property’s indicated value to account for its above-market vacancy rate, as the taxpayer failed to show that such a deduction was required. The court affirmed the tax court’s decision, upholding the increased assessed market values of the properties. View "Tamarack Village Shopping Center, LP vs. County of Washington" on Justia Law

In this case, the appellant, Deshawn Woolridge Carter, was convicted of first-degree criminal sexual conduct. At the time of the offense, he was under court-ordered conditions following a guilty plea to a felony theft offense, with adjudication stayed. During sentencing, the district court included a custody status point in his criminal history score, which increased the presumptive sentencing range. The appellant argued that because no conviction had been entered for his felony theft offense, he was not on "probation," and the district court had not "entered" his guilty plea.The district court concluded that the appellant was on probation when he committed the current offense, satisfying the requirements of Minnesota Sentencing Guidelines 2.B.2.a. The court included one custody status point in his criminal history score, resulting in a higher presumptive sentencing range. The court of appeals affirmed this decision, holding that the guidelines unambiguously authorized the assignment of a custody status point for an offense committed while on probation under a stay of adjudication.The Minnesota Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the term "probation" in the guidelines includes court-ordered conditions under a stay of adjudication following a guilty plea. Additionally, the phrase "entry of a guilty plea" refers to the act of pleading guilty on the record, not the court's acceptance and recording of the plea. Therefore, the district court did not err in assigning a custody status point to the appellant's criminal history score. View "State of Minnesota vs. Carter" on Justia Law

The case involves Frank James Bigbear, who was charged with third-degree criminal sexual conduct for sexually assaulting a 14-year-old victim, I.M. The State of Minnesota presented multiple witnesses, including the victim, and introduced over 10 exhibits at trial. Among the evidence was a video recording of I.M.'s interview with an investigator and a social worker, which was admitted over Bigbear's hearsay objection. The jury found Bigbear guilty after a three-day trial.Bigbear appealed the conviction, arguing that the admission of the recorded interview was reversible error. The Minnesota Court of Appeals agreed that the video recording did not meet the requirements of Rules 801(d)(1)(B) and 807 of the Minnesota Rules of Evidence. However, the court concluded that the error was harmless, reasoning that the jury could have reached the same verdict based on other evidence presented.The Minnesota Supreme Court reviewed whether the Court of Appeals conducted an incorrect harmless-error analysis. The Supreme Court agreed that the lower court used an improper standard by focusing solely on whether other evidence was sufficient to support the verdict, rather than whether the erroneously admitted evidence substantially influenced the jury's decision. After applying the correct harmless-error standard, the Supreme Court concluded that the erroneous admission of the video was harmless. The court noted that the evidence against Bigbear was overwhelming, including consistent testimonies from the victim and eyewitnesses. Therefore, the Supreme Court affirmed the decision of the Court of Appeals to uphold Bigbear's conviction. View "State of Minnesota vs. Bigbear" on Justia Law