Justia Minnesota Supreme Court Opinion Summaries

In 2020, Jaye William Snyder was charged with third- and fourth-degree criminal sexual conduct following an assault on an impaired victim. Snyder was convicted of third-degree criminal sexual conduct and was given a 140-month prison sentence. Due to a previous conviction of the same offense in 2016, he was also placed on lifetime conditional release after his prison term, as mandated by Minnesota Statutes § 609.3455, subdivision 7(b). Snyder appealed, arguing that the lifetime conditional release made his offense punishable by life imprisonment, which should have required the State to charge him by indictment rather than a criminal complaint, as per Minnesota Rule of Criminal Procedure 17.01, subdivision 1. However, the Minnesota Supreme Court held that their precedent in State v. Ronquist, which limited the indictment requirement to offenses punishable by life imprisonment before a sentencing enhancement is applied, remained good law and applied to Snyder's case. The court held that a lifetime conditional release did not invoke the indictment requirement of Rule 17.01, subdivision 1, and affirmed the decision of the lower court. View "State of Minnesota vs. Snyder" on Justia Law

In Minnesota, a district court removed Brian Lipschultz as a trustee from the Otto Bremer Trust. This decision was based on his violation of Minnesota Statutes section 501C.0706(b)(1), which allows for the removal of a trustee for a “serious breach of trust.” The breaches included Lipschultz's misuse of trust resources for personal purposes, offensive behavior during a stock dispute, manipulation of a grantee, and failure to disclose his successor. Lipschultz appealed this decision, arguing that the district court and court of appeals applied an incorrect legal standard for removal and that they abused their discretion in removing him under section 501C.0706(b)(1). However, the Minnesota Supreme Court affirmed the decision of the court of appeals, stating that the district court did not abuse its broad discretion when it determined that Lipschultz committed “a serious breach of trust” under section 501C.0706(b)(1). The court concluded that Lipschultz breached the duty of loyalty and the duty of information, demonstrating a pattern of placing his personal priorities over the duties he owed to the Trust. View "In the Matter of the Otto Bremer Trust" on Justia Law

In Minnesota, a group of voters sought to prevent former President Donald Trump from appearing on the 2024 presidential primary and general election ballots, arguing that Section 3 of the Fourteenth Amendment of the U.S. Constitution, which disqualifies anyone from holding office who has engaged in insurrection or rebellion against the U.S., rendered him ineligible. The Minnesota Supreme Court held that it would not be an error to place Trump's name on the 2024 Republican Party presidential nomination primary ballot. The court reasoned that the nomination primary is an internal party election, and the state law does not prohibit a major political party from placing an ineligible candidate on the primary ballot. However, the court did not decide on the issue of Trump's name on the general election ballot, stating that the matter was not yet ripe for adjudication as it was not "about to occur" under the relevant state law. The court did not foreclose the possibility of petitioners bringing such a claim at a later date. View "Growe v. Simon" on Justia Law

The Minnesota Supreme Court reversed a decision by the Court of Appeals, ruling that the district court did not abuse its discretion in certifying an order as a final partial judgment under Minnesota Rule of Civil Procedure 54.02. The case arose from a dispute between the City of Elk River and Bolton & Menk, Inc. over a large construction contract for a wastewater treatment plant improvement project. The City sued Bolton for alleged breach of contract and professional negligence. Bolton responded by filing a third-party complaint against three other parties involved in the contract. The district court dismissed Bolton's third-party complaint and Bolton sought to have the dismissal order certified as a final judgment for immediate appeal. The district court granted this certification, but the Court of Appeals dismissed Bolton's appeal, determining that the district court had abused its discretion in certifying the order as a final judgment. The Minnesota Supreme Court disagreed, finding that the district court had offered valid reasons for its certification, including that the third-party claims presented distinct issues from the principal claims and that the case was in its early stages at the time of certification. The Supreme Court therefore reversed the decision of the Court of Appeals and remanded the case for further proceedings. View "City of Elk River vs. Bolton & Menk, Inc." on Justia Law

In the case of Elsa E. Segura, the Minnesota Supreme Court examined whether the State presented sufficient evidence to sustain Segura's convictions for first-degree premeditated murder and attempted first-degree premeditated murder, under an aiding-and-abetting theory of criminal liability. The court also reviewed whether Segura was entitled to a new trial based on alleged prosecutorial misconduct and erroneous jury instructions.The State of Minnesota accused Segura of aiding and abetting in the kidnap and murder of Monique Baugh and the attempted murder of Baugh's boyfriend, J.M.-M., by luring Baugh to a fake house showing, where the principal perpetrators kidnapped her. Segura admitted to scheduling the house showing, but claimed she thought she was aiding in a drug business, not a kidnap-murder scheme.The Supreme Court found that although there was sufficient evidence to sustain Segura's convictions for kidnapping to commit great bodily harm or terrorize and felony murder while committing a kidnapping, there was insufficient evidence to sustain her convictions for first-degree premeditated murder and attempted first-degree premeditated murder. The court concluded that the jury instructions materially misstated the law and were not harmless beyond a reasonable doubt. Therefore, the court reversed Segura's convictions for kidnapping and felony murder and remanded the case for further proceedings consistent with its opinion. View "State vs. Segura" on Justia Law

In this case, the Supreme Court of Minnesota was tasked to interpret the statutory definition of a "dangerous weapon" as used in the case of Ayyoob Dawood Abdus-Salam, who was charged with two counts of second-degree riot for his alleged organization of two intersection "takeovers." During these events, several vehicles and large groups of pedestrians intentionally blocked off predetermined urban intersections, allowing drivers to perform dangerous stunts while crowds watched and filmed.The Supreme Court of Minnesota held that the term "likely" as used in the manner-of-use definition for "dangerous weapon" under Minn. Stat. § 609.02, subd. 6 (2022), is unambiguous and means "probable or reasonably expected." Furthermore, the court found that the district court erred when it dismissed two second-degree riot charges against Abdus-Salam for lack of probable cause, as sufficient facts in the record precluded granting a motion for a judgment of acquittal if proved at trial. The Supreme Court thus affirmed the decision of the court of appeals, ruling that because a reasonable jury could conclude from the facts alleged by the State that the vehicles used in the "takeovers" were dangerous weapons, the charges should not have been dismissed. View "State vs. Abdus-Salam" on Justia Law

In the case before the Supreme Court of Minnesota, the appellant, Larry Jonnell Gilbert, was convicted of possession of a firearm by an ineligible person. Gilbert then sought postconviction relief, alleging that the State's DNA expert gave false testimony at trial. The district court granted Gilbert a new trial without explicitly addressing whether Gilbert's claim was procedurally barred under the rule from State v. Knaffla, which states that all matters raised in a direct appeal and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief. The state appealed this decision and the court of appeals reversed it.The Supreme Court of Minnesota held that a district court abuses its discretion by granting a petition for postconviction relief without explicitly determining whether the claim is procedurally barred and offering a sufficient explanation to support a determination that the claim is not procedurally barred. Applying this to the facts of the case, the Supreme Court of Minnesota found that the district court abused its discretion by not explicitly determining whether Gilbert's claim was procedurally barred under Knaffla before granting postconviction relief. Therefore, the court affirmed the decision of the court of appeals, but on different grounds.Regarding the merits of Gilbert's claim about alleged false expert testimony, the court expressed no opinion, as it determined that Gilbert's postconviction claim was procedurally barred under Knaffla. View "Gilbert vs. State" on Justia Law

In a dispute with the Department of Human Services (DHS) in Minnesota, Nobility Home Health Care, Inc. (Nobility) was found to have violated Minnesota Statutes section 256B.064 and Minnesota Rule 9505.2165 by failing to maintain health service records as required by law and by submitting claims for services for which underlying health service records were inadequate. The Minnesota Supreme Court held that such conduct constitutes "abuse" under the statute, even if there was no intent to deceive the DHS. However, the court declined to interpret or apply the phrase "improperly paid... as a result of" abuse in the statute, which governs the grounds for monetary recovery. The court reversed the decision of the court of appeals and remanded the case to the DHS for further analysis of this issue. The court's decision means that DHS's demand for an overpayment for Nobility’s first-time paperwork errors may not be reversed unless the DHS also establishes that the provider was improperly paid because of that abuse. View "In the Matter of SIRS Appeal by Nobility Home Health Care, Inc" on Justia Law

In Minnesota, a man convicted of taking pornographic photographs of a child was ordered by a district court to pay restitution for therapy costs and lost wages incurred by the child's mother. The appellant argued that the mother, as a secondary victim, was only eligible for restitution for losses suffered directly by the child. The State contended that under Minnesota Statutes section 611A.01, family members of the direct victim are part of a singular class of victims because when a child suffers, their parents suffer as well. The Minnesota Supreme Court agreed with the State's argument and affirmed the lower court's decision. It held that Minnesota Statutes section 611A.01(b) creates a singular class of victims that includes the direct victims of a crime and, if the direct victim is a minor, those family members of the minor who incur a personal loss or harm as a direct result of the crime. View "State of Minnesota vs. Allison" on Justia Law

In a case heard by the Supreme Court of Minnesota, the defendant, Christian Portillo, was charged with two counts of second-degree criminal sexual conduct. During the trial, the prosecutor elicited testimony from the State’s witnesses regarding evidence that the district court had previously ruled as inadmissible. The defendant's motion for a mistrial was denied by the district court. During the closing-argument rebuttal, the prosecutor told the jury that the defendant no longer held the presumption of innocence based on the evidence presented during the trial. The defendant did not object to this statement. The jury found the defendant guilty of one count of second-degree criminal sexual conduct.The defendant appealed, arguing that he was denied a fair trial due to prosecutorial errors committed by the State. The court of appeals affirmed the district court's decision, concluding that the prosecutor's misstatement of the law did not affect the defendant's substantial rights.Upon review, the Supreme Court of Minnesota reversed the decision of the court of appeals. The Supreme Court found that the prosecutor’s misstatement of the law during the closing-argument rebuttal was a plain error that affected the defendant’s substantial rights. The court held that the defendant is entitled to a new trial as the error must be addressed to ensure the fairness and integrity of the judicial proceedings. View "State of Minnesota vs. Portillo" on Justia Law