Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and his sentence of life in prison without the possibility of release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confrontation when it admitted the victim's dying declarations into evidence during the jury trial, and this Court reaffirms that dying declarations are an exception to the Confrontation Clause; (2) the district court did not violate Defendant's Fifth Amendment right to counsel by denying Defendant's motion to suppress his statements to police officers because Defendant validly waived his invoked right to counsel; and (3) there was no reasonable possibility that the admission of Spreigl evidence related to a prior assault charge into evidence significantly affected the verdict. View "State v. Buchan" on Justia Law

The Supreme Court held that an action taken by the Minnesota Pollution Control Agency (MPCA) in issuing a National Pollutant Discharge Elimination System/State Disposal System permit was arbitrary and capricious and that the permit did not comply with a Minnesota rule addressing wastewater discharges to groundwater, Minn. R. 7060.0600, subp. 2.At issue was the MPCA's issuance of the permit for a Poly Met Mining, Inc. project. The court of appeals reversed in part, concluding that the MPCA failed properly to consider whether the federal Clean Water Act (CWA) applied to future discharges from Poly Met's facility to groundwater. The Supreme Court remanded the cause, holding (1) remand was required because there were suggestions that the MPCA did not properly consider whether the permit complies with the CWA and that the MPCA did not genuinely engage in reasoned decision-making; (2) remand was required for consideration of whether a variance was available to allow the planned discharge to the unsaturated zone within the containment system; and (3) the prohibition on injecting polluted water directly to the groundwater saturated zone for long-term storage did not apply in this case. View "In the Matter of the Denial of Contested Case Hearing Requests & Issuance of National Pollutant Discharge Elimination System" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Defendant's motion for a new trial, holding that the record was insufficient to determine whether Defendant's right to a public trial was violated due to restrictions put in place by the district court arising from the COVID-19 pandemic.In December 2019, Defendant was charged with first-degree aggravated robbery. Because of the restrictions placed on trials due to the pandemic the county submitted a trial plan that excluded all spectators from the courtroom but included a one-way video feed that would broadcast the trial in an adjacent courtroom. The trial court overruled Defendant's objection, and the trial proceeded. After Defendant was convicted he moved for a new trial. The court of appeals denied the motion. The Supreme Court reversed, holding that additional findings were required on the decision to close the courtroom before it could be determined whether Defendant's public trial right was violated. View "State v. Bell" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress statements recorded on a body-worn camera, holding that the district court did not abuse its discretion in determining that the statements should be suppressed.In response to a domestic disturbance 911 call law enforcement officers found A.H. locked out of her apartment while Defendant was inside, and A.H. told the officers that Defendant had assaulted her both in the present and in the past. These statements were recorded by an officer's body-worn camera. Defendant was subsequently charged with one count of misdemeanor domestic assault. The district court granted Defendant's motion to suppress the body-worn camera recording on the grounds that their admission would violate Defendant's constitutional right to confrontation. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in determining that A.H.'s statements did not qualify as excited utterances under Minn. R. Evid. 802(2); and (2) properly suppressed the statements as inadmissible hearsay. View "State v. Tapper" on Justia Law

The Supreme Court reversed Defendant's conviction of first-degree premeditated murder and second-degree intentional murder following a jury trial, holding that the district court erred in entering a conviction for the lesser-included offense of second-degree intentional murder.After the trial, the district court entered judgment of convictions for both first-degree and second-degree murder but only imposed a sentence for the first-degree murder conviction. The Supreme Court held (1) the evidence was sufficient to prove the element of premeditation for the first-degree murder offense; (2) assuming, without deciding, that the district court erred by failing to identify a certain individual as an accomplice, the failure did not affect Defendant's substantial rights; (3) the district court did not commit any other reversible error in managing the trial and the jury instructions; and (4) the entry of a judgment of conviction for the second-degree intentional murder offense violated Minn. Stat. 609.04, subd. 1. View "State v. Gilleylen" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's second petition for postconviction relief, holding that Appellant was not entitled to relief on his allegations of error.After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and the denial of Appellant's initial petition for postconviction relief. Thereafter, Appellant filed another postconviction petition. The postconviction court summarily denied the petition and denied Appellant's motion to compel discovery. On appeal, Appellant argued, among other things, that his appellate counsel provided ineffective assistance. The Supreme Court affirmed, holding that Appellant was conclusively entitled to no relief. View "Allwine v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court ruling that an alternative residuary clause in a will devising half of the testator's estate to his heirs-at-law and the other half to his wife's heirs-at-law failed as a matter of law, holding that the devise failed as a matter of law.The testator's will in this case named his wife, if she survived him, as the primary beneficiary of the residue of his estate with an alternate residuary clause devising one-half of the estate to his wife's "heirs-at-law." The couple's marriage was later dissolved, after which the testator died without having revised his will. When Appellant, the personal representative of the testator's estate, petitioned for formal probate of the will he identified only the testator's siblings as heirs and devisees. Respondents, the wife's parents, claimed that they were wrongfully omitted as devisees in the petition. The district court ruled that any purported devise to Respondents failed as a matter of law. The court of appeals reversed. The Supreme Court reversed, holding that a gift to a spouse's heirs, none of whom are identified by name, fails if the marriage dissolves after execution of the will. View "In re Tomczik" on Justia Law

The Supreme Court affirmed the determination of the court of appeals, but on different grounds, determining that two amendments to the grantor's trust were validly executed and that the district court had properly reformed the trust, holding that the district court properly struck the part of the second trust amendment that was ambiguous and unenforceable.The Grantor in this case validly executed the trust, which was properly witnessed and notarized, and then executed two amendments that significantly increased the amount that Respondent would inherit. After the Grantor died, Appellant moved to invalidate the amendments. The district court granted the motion in part and struck a portion of the second trust amendment due to ambiguity but upheld the remaining terms of the amendment, including the increased amount inherited by Respondent. The court of appeals affirmed, holding that the amendments were validly executed and properly reformed under Minn. Stat. 501C.0415. The Supreme Court affirmed on other grounds, holding (1) the second trust amendment was validly executed; and (2) the district court properly upheld the portions of the second trust amendment governing asset distribution. View "In re Trust of Moreland" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding the district court's award of attorney fees based on conduct that occurred outside the context of litigation, holding that the district court exceeded the scope of its inherent authority when it awarded attorney fees.In this case arising from a post-dissolution, mediated settlement agreement between Appellant and Respondent regarding the treatment of a college savings account. The agreement required that the account be awarded to the parties' daughter when she turned twenty-one years old, but when their daughter reached that age Appellant took no action to transfer the account. Ultimately, after intervention on the part of the district court, the transfer became effective. Respondent moved for conduct-based attorney fees under Minn. Stat. 518.14. The district court granted the motion.. The court of appeals affirmed. The Supreme Court reversed, holding that the district court exceeded the scope of its inherent authority in awarding attorney fees because the award was not necessary to the performance of a judicial function. View "Buckner v. Robichaud" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9, holding that Appellant's sentence of life imprisonment was mandated by Minn. Stat. 609.185(1).Appellant pleaded guilty to an amended count for first-degree intentional murder while committing a kidnapping and second-degree intentional murder. The district court ultimately convicted Appellant of first-degree premeditated murder and dismissed the second-degree murder count. In this action arising from Defendant's third motion to correct his sentence Defendant argued that the district court violated his due process right by sentencing him to a longer sentence than that recommended in the sentencing worksheet completed for the charge of second-degree murder. The district court concluded that the failure to file a sentencing worksheet for the charge of first-degree murder does not cause a defendant's sentence to be unauthorized or a defendant's due process rights to be violated. The Supreme Court affirmed, holding that there was no error. View "Johnson v. State" on Justia Law