Justia Minnesota Supreme Court Opinion Summaries

The defendant was charged with multiple counts, including first-degree and third-degree criminal sexual conduct, domestic assault, and threats of violence. During jury deliberations, a juror was exposed to COVID-19, raising concerns that continued deliberations might pressure the jury to reach a verdict. After discussing the situation with counsel, the district court decided to end deliberations, take any unanimous verdicts, and declare a mistrial on any deadlocked counts. The defendant’s attorney, at the defendant’s request, asked for a complete mistrial on all counts. The jury ultimately reported no unanimous verdicts, and the district court declared a mistrial on all counts.Following the mistrial, the State refiled the charges. The defendant moved to dismiss, arguing that a retrial would violate the Double Jeopardy Clauses of the United States and Minnesota Constitutions. The Hennepin County District Court denied the motion, finding that double jeopardy did not bar retrial. The Minnesota Court of Appeals affirmed, holding that because the defendant requested the mistrial, double jeopardy would only bar retrial if the government had intentionally provoked the request, which was not the case here.The Supreme Court of Minnesota reviewed the case and affirmed the decision of the court of appeals. The court held that when a defendant requests and receives a mistrial, double jeopardy does not bar retrial unless the government intentionally induced or provoked the request. The court found no evidence that the district court or prosecution provoked the defendant’s mistrial request. The court also rejected arguments that the defendant had withdrawn his request or preserved an objection to the mistrial. As a result, the court concluded that double jeopardy did not attach, and the defendant may be retried. View "State v. Lerma" on Justia Law

In 1998, Joel Underwood, III, pleaded guilty to third-degree assault, which is classified as a crime of violence under Minnesota law. He was convicted and placed on probation. In 2000, after completing probation, a Dakota County district court issued an order restoring his civil rights and stating that he was prohibited from possessing a firearm for 10 years, which was consistent with the law at that time. In 2003, the Minnesota Legislature amended the relevant statute to impose a lifetime ban on firearm possession for individuals convicted of a crime of violence. Underwood was not specifically notified of this change. In 2021, he was found in possession of a firearm and charged under the amended statute.After being charged, Underwood waived his right to a jury trial and pleaded guilty to being an ineligible person in possession of a firearm. During the plea, he admitted to knowingly possessing a firearm and to his prior conviction but stated he did not know he was still ineligible to possess a firearm. The Anoka County District Court accepted his plea and sentenced him to the mandatory minimum. Underwood later petitioned for postconviction relief, arguing that his conviction violated due process because he relied on the 2000 discharge order and that his plea was invalid since he did not admit knowledge of his ineligibility. The postconviction court denied relief, and the Minnesota Court of Appeals affirmed, holding that there was no due process violation and that knowledge of ineligibility was not required for conviction.The Minnesota Supreme Court reviewed the case and affirmed the Court of Appeals. The court held that when a court order accurately reflects the law at the time but the law is later amended, the State does not violate due process by prosecuting under the amended statute. The court also held that the offense of ineligible person in possession of a firearm does not require proof that the defendant knew of their ineligibility, only that they knowingly possessed a firearm and had a prior conviction for a crime of violence. View "Underwood v. State" on Justia Law

A multinational science and technology company operated in approximately 90 countries, with a significant portion of its sales outside the United States. For the tax years 2013, 2014, and 2015, the company conducted some business in Minnesota, requiring its income to be apportioned for state tax purposes. The company used forward exchange contracts (FECs) as a hedging tool to manage foreign currency risk, generating substantial gross receipts from these transactions, though the net income from FECs was relatively small compared to overall gross receipts.After the company filed its Minnesota corporate franchise tax returns using the general apportionment method, which included gross receipts from FECs, the Minnesota Department of Revenue audited the returns. The Department determined that including gross receipts from FECs in the apportionment formula distorted the company’s Minnesota tax liability. The Commissioner of Revenue applied an alternative apportionment method under Minnesota Statutes section 290.20, which excluded gross receipts but included net income from FECs. The company appealed, and the Minnesota Tax Court upheld the Commissioner’s approach, finding that FEC transactions were qualitatively different from the company’s main business activities and that including their gross receipts caused a substantial quantitative distortion in the apportionment formula.The Supreme Court of Minnesota reviewed the case, applying a deferential standard to the tax court’s factual findings and de novo review to legal conclusions. The court held that the tax court did not err in finding that the Commissioner met his burden under section 290.20 to show that the general apportionment method did not fairly reflect the company’s Minnesota activities, and that the alternative formula—excluding gross receipts but including net income from FECs—fairly represented those activities. The Supreme Court affirmed the tax court’s decision. View "E. I. duPont de Nemours and Company & Subsidiaries v. Commissioner of Revenue" on Justia Law

Melvin Bilbro was charged after killing Shanna Daniels in her North Saint Paul apartment and setting the apartment on fire. Evidence at trial established that Bilbro and Daniels had a significant romantic and sexual relationship, as shown by their frequent text messages, terms of endearment, and testimony from acquaintances. On the night of the murder, Daniels was found dead with multiple stab wounds, and the fire in her apartment was determined to be intentionally set. Investigators found blood evidence linking Bilbro to the scene, and Daniels’s dog was discovered in Bilbro’s apartment. Bilbro denied involvement and claimed he was not in a relationship with Daniels.The State charged Bilbro with first-degree domestic-abuse murder, second-degree intentional murder, and first-degree arson. Bilbro waived his right to a jury trial on guilt but reserved the right to a jury for any facts supporting an aggravated sentence. The trial proceeded in Ramsey County District Court as a bench trial. The State presented evidence of Bilbro’s prior acts of domestic abuse against a former girlfriend, A.B., including physical assaults and an attempted murder for which Bilbro had previously been convicted. The district court found Bilbro guilty on all counts and sentenced him to life in prison for first-degree domestic-abuse murder and a consecutive 57-month sentence for arson, finding that the arson was committed to conceal the murder.On direct appeal, Bilbro argued that the evidence was insufficient to prove a significant romantic relationship with Daniels or a past pattern of domestic abuse, and that his Sixth Amendment right to a jury was violated when the court, rather than a jury, found facts authorizing the consecutive arson sentence under Minn. Stat. § 609.035. The Minnesota Supreme Court held that the evidence was sufficient to support the murder conviction and that the Sixth Amendment right to a jury under Blakely v. Washington does not apply to the threshold question of whether a sentence may be imposed for an offense under Minn. Stat. § 609.035. The court affirmed the district court’s judgment. View "Ramsey County v. Bilbro" on Justia Law

Police officers responded to a report that a man in a yellow and black coat was pointing a handgun at people at a Minneapolis light rail station. They found the suspect inside a nearby pizza restaurant, where several other people, including 16-year-old C.T.B., were standing nearby. An officer, based on his experience that weapons can be passed among individuals in a group, conducted a pat-frisk of C.T.B. and found a handgun in his possession. C.T.B. was charged with unlawful possession of a firearm by a minor and moved to suppress the handgun, arguing that the officers lacked reasonable, articulable suspicion to frisk him.The Hennepin County District Court denied the motion to suppress, finding that C.T.B.’s proximity to the original suspect and the officer’s experience justified the frisk. After a stipulated facts trial, the court found C.T.B. guilty and stayed adjudication. The Minnesota Court of Appeals affirmed, reasoning that the totality of the circumstances—including the possibility that the original suspect had handed off the firearm—made the frisk of C.T.B. objectively reasonable.The Minnesota Supreme Court reviewed the case and held that the officers did not have reasonable, articulable suspicion that C.T.B. was armed and dangerous when they conducted the pat-frisk. The court clarified that mere proximity to a suspect in an alleged crime, even when combined with general knowledge that weapons can be passed among group members, is not sufficient to justify a warrantless pat-frisk under Terry v. Ohio. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "In the Matter of the Welfare of: C.T.B" on Justia Law

After a car accident in January 2017, Lee Scheurer was injured and Ann Maland was found to be at fault. Scheurer submitted a written notice of claim to Maland’s insurer in September 2017 and later made a settlement offer in July 2020. The parties could not agree on damages, and Scheurer filed a negligence lawsuit against Maland in November 2020. After Maland’s death, her estate was represented by a special administrator. The case proceeded to a jury trial, which awarded Scheurer $292,340 in damages. The district court subsequently reduced the award to $194,631 to account for collateral source payments, such as insurance, and awarded Scheurer $53,320 in preverdict interest.The Minnesota District Court determined that preverdict interest began accruing when Scheurer commenced the action, not when he served his notice of claim, because he did not file the lawsuit within two years of the notice. The court also held that preverdict interest should be calculated on the reduced judgment amount after deducting collateral sources. Scheurer appealed, arguing that interest should accrue from the notice of claim and be calculated on the full jury verdict. The Minnesota Court of Appeals affirmed the district court on the accrual issue but reversed on the calculation issue, holding that interest should be calculated on the jury verdict before collateral source reductions.The Minnesota Supreme Court reviewed both issues. It held that, under Minnesota Statutes section 549.09, subdivision 1(b), the requirement that an action be commenced within two years of a written notice of claim for interest to accrue from the notice applies even if a written settlement offer is made. The court also held that preverdict interest is to be calculated on the judgment after collateral source deductions, not on the full jury verdict. The decision of the court of appeals was affirmed in part and reversed in part, reinstating the district court’s calculation of interest. View "Scheurer vs. Shrewsbury" on Justia Law

A man was involved in a single-vehicle accident in Minnesota, after which law enforcement discovered a self-assembled pistol in his car that lacked a serial number. He admitted to possessing the firearm and not having a permit to carry it. The firearm, a Glock 19-style pistol, was constructed from parts purchased in 2021, before new federal regulations required serial numbers on certain parts kits. He was charged with felony possession of a firearm without a serial number under Minnesota law, as well as carrying a pistol without a permit.The Anoka County District Court granted the defendant’s motion to dismiss the charge related to the serial number, finding that while he knowingly possessed a firearm without a serial number, the relevant Minnesota statute was unconstitutionally vague as applied. The State appealed. The Minnesota Court of Appeals reversed the district court, holding that the statute plainly applied to any firearm lacking a serial number, regardless of whether federal law required one, and remanded the case for further proceedings.The Supreme Court of Minnesota reviewed the case. It held that Minnesota Statutes section 609.667(3) criminalizes possession of a firearm without a serial number only if federal law requires that the firearm have a serial number. The court reasoned that Minnesota has no independent serial number regime and that the statute’s reference to federal law means only firearms required by federal law to have serial numbers are covered. Because the defendant’s firearm was not required by federal law to have a serial number, the Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court. View "State v. Vagle" on Justia Law

An employee who worked as a packaging operator began experiencing left shoulder pain, which she attributed to her work activities. After seeking medical treatment, including surgery, her employer and its workers’ compensation insurer initially accepted her claim as work-related but later denied it based on an independent medical examination. While the workers’ compensation claim was pending, the employee’s health insurer paid for her medical expenses as required by Minnesota law when compensability is disputed. The employee then filed a workers’ compensation claim seeking a determination that her injury was compensable and that her employer should cover her medical expenses. The health insurer was notified of its right to intervene in the proceedings but did not do so within the statutory deadline.A compensation judge found the employee’s injury was work-related and compensable, but concluded that the employee could not bring a direct claim for medical expenses already paid by her health insurer, reasoning that only medical providers, not insurers, could be the subject of such claims. The judge also ruled that the health insurer’s failure to intervene extinguished its right to reimbursement. The Workers’ Compensation Court of Appeals (WCCA) reversed, holding that the employee could bring a direct claim for the medical expenses paid by the health insurer and that the employer and its insurer must reimburse the health insurer, despite its failure to intervene.The Minnesota Supreme Court reviewed the case. It held that, consistent with its recent decision in Johnson v. Concrete Treatments, Inc., an employee may bring a direct claim under the Workers’ Compensation Act for medical expenses related to a compensable work injury, even if those expenses were paid by a health insurer before compensability was determined. However, the Court also held that the WCCA erred in reviving the health insurer’s independent intervenor interest, which was extinguished by its failure to timely intervene. The Court affirmed in part and reversed in part. View "Brunner vs. Post Consumer Brands" on Justia Law

In 2014, Diamond Lee Jamal Griffin was convicted in Hennepin County District Court of first-degree intentional felony murder while committing or attempting to commit aggravated robbery, stemming from the fatal shooting of Francisco Benitez-Hernandez in Minneapolis in July 2013. Griffin appealed, and the Minnesota Supreme Court affirmed his conviction, concluding that the evidence supported a reasonable inference that Griffin shot Benitez-Hernandez with intent to kill. Griffin's subsequent petitions for postconviction relief were also denied.Griffin filed a preliminary application for relief under a 2023 Minnesota law that allows individuals convicted of certain felony murder offenses under an aiding-and-abetting theory to have their sentences vacated if they can show they neither caused the death nor intentionally aided in causing the death. The Hennepin County District Court denied Griffin's application, concluding that there was no reasonable probability that Griffin was entitled to relief under the new law, based on the application, supporting materials, and previous court decisions.The Minnesota Supreme Court reviewed the case and addressed two primary issues: the appropriate standard of review for appeals under the new law and whether the district court abused its discretion in denying Griffin's application. The court concluded that the standard of review is abuse of discretion, given the text of the law and its treatment of the application as a postconviction proceeding. The court then determined that the district court did not abuse its discretion in denying Griffin's application, as the established facts and prior court decisions supported the conclusion that Griffin caused the death of Benitez-Hernandez. The Minnesota Supreme Court affirmed the district court's decision. View "State of Minnesota vs. Griffin" on Justia Law

Fletcher Properties, Inc. and other appellants own multi-tenant residential properties in Minneapolis. The City of Minneapolis enacted an ordinance prohibiting property owners from refusing to rent to individuals based on requirements of public assistance programs, including Section 8 housing vouchers. Fletcher challenged the ordinance, claiming it violated the Minnesota Constitution’s Takings Clause and was preempted by the Minnesota Human Rights Act (MHRA).The district court initially ruled in favor of Fletcher, finding the ordinance violated due process and equal protection clauses. The court of appeals reversed this decision, and the Minnesota Supreme Court affirmed, remanding the case to address the remaining claims. On remand, the district court granted summary judgment for the City, rejecting Fletcher’s takings and preemption claims. The court of appeals affirmed this decision, leading to the current appeal.The Minnesota Supreme Court reviewed the case and held that the ordinance does not constitute a physical or regulatory taking under the Minnesota Constitution. The court applied the Penn Central factors, concluding that the economic impact of the ordinance, interference with investment-backed expectations, and the character of the government action did not support a finding of a regulatory taking. The court also determined that the ordinance does not effect a physical taking as landlords voluntarily rent their properties and are not compelled to continue doing so.Additionally, the court held that the ordinance is not preempted by the MHRA. The court found no conflict between the ordinance and the MHRA, as the MHRA does not grant landlords an affirmative right to reject voucher holders. The court also concluded that the MHRA does not occupy the field of housing discrimination based on public assistance, allowing for local regulation.The Minnesota Supreme Court affirmed the decision of the court of appeals, upholding the ordinance. View "Fletcher Properties, Inc. vs. City of Minneapolis" on Justia Law