Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State of Minnesota Department of Natural Resources (DNR) and dismissing Plaintiff's complaint alleging a violation of the Minnesota Whistleblower Act, Minn. Stat. 181.932, subd. 1(1), holding that there was no error.After Plaintiff, a former regional director with DNR, was terminated she brought this action alleging that her reporting of suspected illegal activity at a hotel where she was staying for a work-related conference caused her termination. The district court granted summary judgment for DNR. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Plaintiff failed to establish a genuine issue of material fact for trial over whether her alleged protected activity was a motivating factor in the decision of the DNR to terminate Plaintiff; and (2) therefore, summary judgment was properly granted. View "Hanson v. State, Department of Natural Resources" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree murder, second-degree intentional murder, and first-degree arson, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that he was entitled to relief based on limitations that the district court placed on the presence of the public in the courtroom in response to the COVID-19 pandemic and that his motion for a hearing under Schwartz v. Minneapolis Suburban Bus Co., 104 N.W.2d 301 (Minn. 1960), and Minn. R. Crim. P. 26.03, subd. 20(6) should have been granted. The Supreme Court affirmed, holding (1) this Court will not exercise its limited discretion under the plain-error doctrine to grant relief based on objected-to limitations that the district court placed on the presence of the public in the trial courtroom due to the COVID-19 pandemic; and (2) the district court did not abuse its discretion by denying Defendant's request for a Schwartz hearing. View "Pulczinski v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting the motion for judgment on the pleadings filed by Defendant, Grant Park Association, and dismissing Plaintiff's action alleging that Defendant violated the Minnesota Common Interest Ownership Act of 1993, Minn. Stat. 515B.1-101 to .4-118, holding that the district court erred.After Defendant failed to respond to Plaintiff's request for the postal and e-mail addresses of all members of the Association Plaintiff brought this action alleging that Defendant violated the Act and the Association's bylaws by not turning over the records. The district court granted Defendant's motion for judgment for the pleadings. The court of appeals reversed. The Supreme Court affirmed, holding (1) an association must disclose all records that fall under the categories listed in Minn. Stat. 515B.3-118, including records of membership kept by the association; (2) Defendant's bylaws required the same level of disclosure as the Act; and (3) Plaintiff adequately pleaded his claims to survive a motion for judgment on the pleadings. View "Harkins v. Grant Park Ass'n" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing the petitions for writs of mandamus filed by Minnesota Voters Alliance, et al. (collectively, the Alliance), holding that the Alliance failed to show the violation of a duty clearly established by law.In the mandamus petitions, the Alliance alleged that Ramsey County, Olmsted County, and other entities violated their statutory obligations for appointing members to absentee ballot board during the 2020 general election. Specifically, Alliance argued that the statutory requirements for election judges also apply to deputy county auditors. The district court dismissed the petitions, and the court of appeals affirmed. The Supreme Court affirmed, holding that the district court properly dismissed the Alliance's mandamus petitions. View "Minnesota Voters Alliance v. County of Ramsey" on Justia Law

The Supreme Court affirmed the nonprecedential opinion of the court of appeals instructing the district court to consider whether Rebecca Bender presented newly discovered evidence warranting relief from a child support order, holding that the district court should have determined whether Bender's proffered evidence warranted relief.Years after marriage dissolution and child support proceedings between Bender and Peter Bernhard, Bender filed a motion to modify the child support termination order based on "newly discovered evidence" under Minn. Stat. 518.145, subd. 2(2) and Minn. R. Civ. P. 60.02. The district court denied the motion. The court of appeals reversed and remanded the case. The Supreme Court affirmed, holding (1) as may be just, a district court has discretion under section 518.145 to consider newly discovered evidence that arises after the court's underlying decision; and (2) the district court abused its discretion in finding that Bender's newly discovered evidence was not "new." View "Bender v. Bernhard" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court finding Defendant guilty of four counts of violence under Minn. Stat. 609.713, subd. 1, holding that section 609.713, subd. 1 does not violate the First Amendment.After he was charged, Defendant filed a motion to dismiss, claiming that the portion of section 609.713, subd. 1 that applies to threats of violence made "in a reckless disregard of the risk of causing such terror" was unconstitutionally overbroad. The district court denied the motion and found Defendant guilty. The court of appeals affirmed, concluding that even if the statute prohibited some protected speech, it was not facially overbroad under the First Amendment. The Supreme Court affirmed, holding (1) specific intent is not required to make a communication a true threat; (2) the statute punishes only reckless speech that is a true threat; and (3) because few situations of reckless but protected threats would be swept up in criminal prosecutions, the statute is not facially overbroad. View "State v. Mrozinski" on Justia Law

The Supreme Court affirmed the judgment of the tax court ruling on certain motions filed by Taxpayer and rejecting Taxpayer's statutory claim that its property was unequally assessed, holding that the tax court did not abuse its discretion in ruling on the motions, and Taxpayer failed to present evidence to support the unequal assessment claim.On appeal, Taxpayer challenged the tax court's denial of its motion to compel Washington County to produce information about other similar properties, its motion to amend the pleadings to add unequal assessment and disparate treatment claims, and its motion to compel the county assessor to testify. Taxpayer further appealed the tax court's rejection of Taxpayer's unequal assessment claim. The Supreme Court affirmed, holding (1) the tax court's denial of Taxpayer's motions was not an abuse of discretion; and (2) the tax court did not err in rejecting the unequal assessment claim. View "Chambers Self-Storage Oakdale, LLC v. County of Washington" on Justia Law

The Supreme Court held that certain congressional districts were unconstitutional for purposes of the 2022 primary and general elections, enjoined their use in these elections, and adopted the congressional district boundaries as set forth in Appendices A and B to this order.Two sets of plaintiffs initiated actions in, respectively, Carver County District Court and Ramsey District Court alleging that the current congressional and legislative election districts were unconstitutionally malapportioned in light of the 2020 census. The Chief Justice appointed a panel to hear and decided the consolidated action and any other challenges to the congressional and legislative districts. The Supreme Court held that the existing congressional districts were unconstitutional and adopted the congressional district boundaries as set out in Appendices A and B to this order. View "Wattson v. Simon" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's fifth petition for postconviction relief, holding that the district court did not abuse its discretion in denying postconviction relief.After a jury trial, Defendant was found guilty of first-degree murder and sentenced to life in prison. At issue was Defendant's fifth postconviction petition for relief alleging a newly discovered evidence claim. The district court concluded that Defendant failed to satisfy the newly discovered evidence exception in Minn. Stat. 590.01, subd. 4(b)(2) and denied the petition. The Supreme Court affirmed, holding that the district court (1) properly excluded certain recordings of jail calls and an affidavit as inadmissible hearsay; and (2) did not abuse its discretion in denying Defendant's request for a new trial. View "Bobo v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's judgment concluding that Tennis Sanitation, LLC breached the contract between the parties and that, as a result of the breach, Vermillion State Bank suffered $1.92 million in damages, holding that the court of appeals did not err.Tennis repudiated an alleged oral contract it negotiated with Vermillion for its purchase of certain assets, including garbage trucks and customer routes, of a trash collection business in bankruptcy. After Tennis's repudiation, Vermillion sold the assets to another company at a significantly lower price. Vermillion then sued Tennis for breach of contract. The district court entered judgment for Vermillion. The court of appeals affirmed. The Supreme Court affirmed, holding that hybrid contract involving goods and non-goods should be interpreted based on the predominant purpose of the contract. View "Vermillion State Bank v. Tennis Sanitation, LLC" on Justia Law