Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the district court denying Appellant's fourth petition for postconviction relief, holding that the district court did not abuse its discretion in summarily denying Appellant's petition.After the Supreme Court reversed Appellant's first conviction on direct appeal, Appellant was convicted of first-degree murder while committing or attempting to commit a kidnapping. The Supreme Court affirmed. In his fourth petition for postconviction relief Appellant challenged his sentence, among other claims. The district court denied the petition without a hearing, holding that Appellant's sentence was lawful and that his remaining claims were untimely. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "Hannon v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals determining that Minn. Stat. 169A.20, subd. 1(7) is a strict liability offense that does not require the State to prove knowledge as an element of the crime, holding that Defendant's conviction was valid.Defendant pleaded guilty to operating a motor vehicle with a schedule I or schedule II controlled substance in his body. Defendant subsequently sought to withdraw his guilty plea under Minn. R. Crim. P. 15.05, subd. 1, arguing that his guilty plea was invalid because he did not admit that he knew or had reason to know that amphetamine was present in his body at the time he was operating his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that strict liability was appropriate because there was a clear legislative intent to dispense with a mens rea requirement. View "State v. Schwartz" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that the United States Supreme Court's decision in Missouri v. McNeely, 569 U.S. 141 (2013), is substantive in the context of a conviction for test refusal, holding that the rule announced in McNeely is procedural and does not apply retroactively to test-refusal convictions on collateral review.In 2010, Defendant was convicted of first-degree test refusal for refusing to submit to a warrantless blood and urine test. In 2016, he filed a petition for postconviction relief, arguing that his conviction was unconstitutional. The district court ultimate determined that Defendant was entitled to postconviction relief, regardless of whether McNeely applied. The court of appeals reversed, holding that McNeely applied retroactively. The Supreme Court reversed and remanded the case, holding that McNeely did not apply retroactively to Defendant's test-refusal conviction, and the district court not properly articulate the pre-McNeely standard for exigent circumstances. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder of Andrew Gokee and attempted first-degree premeditated murder of Hudson Gauthier, holding that the district court did not abuse its discretion when it denied Defendant's request for an accomplice-testimony jury instruction under Minn. Stat. 634.04.During trial, Defendant requested an accomplice-testimony jury instruction, arguing that the jury could reasonably find that Gauthier was an accomplice. The district court concluded that the instruction was precluded as a matter of law because Defendant intended to present evidence identifying Gauthier as an alternative perpetrator. The Supreme Court affirmed, holding (1) there was no evidence that Defendant and Gauthier worked as accomplices to kill Gokee; and (2) Defendant was not entitled to relief on his remaining claims of error. View "State v. Montano" on Justia Law