Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction for exposing her child, T.D., to methamphetamine, holding that the State's evidence was sufficient to prove that T.D. was subjected to a risk of harm from methamphetamine.While conducting a search of a home, police found a small purse containing methamphetamine beyond a mattress upon which Defendant's child slept. The State charged Defendant with a violation of Minn. Stat. 152.137 subd. 2(d) for "exposing" her child to methamphetamine. The jury found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that the jury could reasonably have concluded that Defendant subjected her child to risk of harm from the methamphetamine in the purse. View "State v. Friese" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the requirement that Defendant register as a predatory offender based on her conviction for aiding an offender to avoid arrest, holding that Defendant was not subject to the predatory offender registration requirement.Defendant helped her husband flee to Ohio after he committed a crime. Defendant was charged with, among other crimes, aiding an offender to avoid arrest. Defendant pled guilty to aiding an offender to avoid arrest and, at the plea hearing, was ordered to register as a predatory offender. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's conviction and charged offenses did not arise from the same set of circumstances; and (2) therefore, the predatory registration statute did not apply to Defendant's conviction. View "State v. Berry" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the decision of the district court granting the Commissioner of Correction's motion to dismiss Plaintiff's action seeking declaratory and injunctive relief, holding that some of the facts alleged in the complaint stated a claim upon which relief could be granted.Defendant pleaded guilty with several crimes. After Defendant began serving his sentence the Commissioner denied his application for the Challenge Incarceration Program on the grounds that persons required to register as predatory offenders are not eligible for that program. Defendant then brought this action alleging that the predatory offender registration statute and some of its collateral consequences denied him due process as applied to his charged, but not convicted, enumerated offense of kidnapping. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in dismissing Defendant's claim of substantive and procedural due process violations based on his alleged fundamental right to parent his child. View "Werlich v. Schnell" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that the Minnesota Public Utilities Commission erred by approving affiliated-interest agreements under Minn. Stat. 216B.48, subdivision 3 without first considering whether environmental review was necessary, holding that the Commission was not required to conduct review under Minn. Stat. Ch. 116D before approving affiliated-interest agreements that govern construction and operation of a Wisconsin power plant by a Minnesota utility.At issue was whether chapter 116D - the Minnesota Environmental Protection Act (MEPA) - requires the Commission to conduct an environmental review before deciding to approve affiliated-interest agreements that will govern the construction and operation of a power plant in a neighboring state. The Commission in this case that its jurisdiction was limited to power plants proposed to be built in Minnesota, and therefore, the power plant in this case was not subject to Minnesota's permitting and environmental review regulations. The court of appeals reversed. The Supreme Court reversed, holding that MEPA did not apply. View "In re Minnesota Power's Petition for Approval of the EnergyForward Resource Package" on Justia Law

The Supreme Court reversed the decision of the court of appeals denying Appellants' petition for a writ of mandamus after the district court denied Appellants' motion to transfer venue or, an the alternative, their motion asserting forum non conveniens, holding that the term "several" as used in the context of venue motions means "separate."In this medical malpractice case, Appellants, the two defendants, filed a motion for a change of venue under Minn. Stat. 542.10, which allows "several defendants residing in different counties" to compel the transfer of venue when the majority of them wish to transfer venue. In denying the motion, the district court concluded that the two defendants did not constitute several defendants under the statute. The court of appeals agreed and denied Appellants' petition for a writ of mandamus. The Supreme Court reversed, holding that the word "several" in section 54.10 means "separate." View "Manselle v. Krogstad" on Justia Law

In this insurance dispute, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing the district court's determination that the insurance policy at issue covered all of the claimed property damage and that a Miller-Shugart settlement agreement was reasonable and unenforceable against Insurer, holding that the policy did not cover all of the claimed property damage.The court of appeals concluded that the settlement agreement was "unreasonable as a matter of law and unenforceable" against the insurer because the agreement failed to allocate between covered and uncovered claims. The Supreme Court reversed in part, holding (1) the policies in this case covered some, but not all, of the property damage claimed by the insured; and (2) determining the reasonableness of an unallocated Miller-Shugart settlement agreement involves a two-step inquiry set forth in this opinion. View "King's Cove Marina, LLC v. Lambert Commercial Construction LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction, holding that the State's discovery motion at Defendant's first court appearance seeking to photograph transitory scratches on Defendant's arms was not a critical stage of the criminal proceeding that required the presence of defense counsel.At Defendant's first appearance on criminal sexual conduct charges the State made a discovery motion to take photographs of transitory scratch marks on Defendant's arms. At issue was whether the discovery motion was a critical stage of the proceedings entitling Defendant to have counsel present. The court of appeals concluded that the discovery hearing on the "otherwise-valid" discovery request to noninvasively photograph scratches was not a critical stage of the proceedings. The Supreme Court affirmed, holding that there was no violation of Defendant's Sixth Amendment right to counsel under the circumstances of this case. View "State v. Zaldivar-Proenza" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of third-degree depraved mind murder under Minn. Stat. 609.195(a), holding that Defendant failed to show that an erroneous jury instruction affected his substantial rights.Defendant had an alcohol concentration of more than twice the legal limit when he drove his snowmobile at nearly sixty miles an hour across a frozen lake, fatally injuring an eight-year-old boy. When instructing the jury, the district court used the model jury instruction for third-degree depraved mind murder, which tells jurors that the underlying act must be "committed in a reckless or wanton manner with the knowledge that someone may be killed." Defendant challenged the instruction on appeal. The Supreme Court affirmed, holding (1) the instruction at issue materially misstated the law; but (2) Defendant failed to establish that the error affected his substantial rights. View "State v. Coleman" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court determining that the interior of a private motor vehicle is not a public place when it is not regularly held open to the public, holding that the court of appeals did not err.At issue was whether the driver of a motor vehicle is in a public place for purposes of Minn. Stat. 624.7142, subd. 1(4), which prohibits a person who is under the influence of alcohol from carrying a pistol in a public place. The district court dismissed the count charging Defendant with a violation of the statute. The court of appeals reversed and reinstated the charge. The Supreme Court affirmed, holding that the Legislature intended to prohibit an impaired person from carrying a pistol on public streets even when that person is inside a motor vehicle. View "State v. Serbus" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the judgment of the district court denying Plaintiff's claim in conciliation court against Defendants seeking replevin of her dog Oliver on the grounds that Plaintiff had abandoned Oliver, holding that, under Minn. Stat. 345.75, Plaintiff did not abandon her dog.At issue was whether section 345.75, which governs the abandonment of tangible personal property, abrogates by implication the common law governing the abandoning of tangible personal property. The court of appeals held that section 345.75 abrogated the common law of abandonment of tangible personal property by necessary implication. The Supreme Court affirmed in part and reversed in part, holding (1) section 345.75 does not abrogate by implication the common law of abandonment of tangible personal property; and (2) Plaintiff did not abandon her dog under the statue, and the district court erred in concluding that Plaintiff abandoned her dog under the common law. View "Zephier v. Agate" on Justia Law