Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the district court's dismissing of Plaintiff's breach of fiduciary duty claim against Defendant, an attorney, holding that the court of appeals erred in its analysis for determining whether experts were required in this case.Plaintiff brought a breach of fiduciary duty claim against Defendant, alleging that Defendant took unfair of the parties' professional relationship and that their business dealings were unfair to Plaintiff. The district court granted Defendant's motion for summary judgment. The court of appeals affirmed on the grounds that Plaintiff did not provide the expert-disclosure affidavits as required by Minn. Stat. 544.42. The Supreme Court reversed, holding (1) section 544.42 applies to breach of fiduciary duty claims; but (2) the court of appeals erred in its analysis for determining whether experts were required in this case. View "Mittelstaedt v. Henney" on Justia Law

The Supreme Court affirmed the decision of the tax court concluding that three clinics - Perham Clinic, Ottertail Clinic, and New York Mills Clinic - were not subject to property tax because they clinics were exempt under Minn. Stat. 447.31, subd. 6, holding that there was no error.The exemption at issue is provided for hospital districts. At issue on appeal was whether to classify the three medical clinics that were owned and operated by Perham Hospital District as taxable or exempt. Otter Tail County classified the clinics as commercial and thus subject to property tax, concluding that the tax exemption at issue was available to hospitals and not to clinics. After a trial, the tax court concluded that the clinics were exempt from tax under Minn. Stat. 447.31, subd. 6. The Supreme Court affirmed, holding that the tax court did not clearly err in finding that the District used the clinics to improve and run Perham Hospital during the tax years at issue. View "Perham Hospital District v. County of Otter Tail" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the district court declaring that the unanimity requirement in Minn. Stat. 638.02, subd. 1 violates Minn. Const. art. V, 7, holding that the statutory provisions at issue are not unconstitutional.Defendant was convicted of first-degree manslaughter and later filed an application for a pardon absolute. The application was denied because the Board of Pardons members did not unanimously agree that Defendant was entitled to a pardon. Defendant then filed this action for declaratory and injunctive relief. The district court concluded that the unanimity requirement violates Article V, Section 7 but does not violate Article III, Section 1 of the Minnesota Constitution. The Supreme Court reversed in part, holding that the unanimity requirement does not violate either Article V, Section 7 or Article III, Section 1. View "Shefa v. Ellison" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying as time-barred Defendant's second petition for postconviction relief, holding that even if the facts alleged in the petition were proven at an evidentiary hearing, Defendant still would not be entitled to relief.Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed both Defendant's conviction on direct appeal and the denial of his first postconviction motion. In his second postconviction petition, Defendant argued the the district court lacked subject matter jurisdiction, that he had discovered new evidence, prosecutorial misconduct, and ineffective assistance of counsel. The district court denied the petition. The Supreme Court affirmed, holding that Defendant's claims either failed on the merits or were time barred. View "Martin v. State" on Justia Law

The Supreme Court held that the unanimity requirement in Minn. Stat. 638.02m, subd. 1 does violate either Minn. Const. art. V, 7 or Minn. Const. art. III, 1.Defendant was convicted of first-degree manslaughter. When Defendant later filed an application for a pardon absolute, the members of the Board of Pardons denied it. Attorney General Keith Ellison and Governor Tim Walz voted to grant the application, and Chief Justice Lorie Gildea voted to deny it. Defendant's application was ultimately denied. Defendant then filed an action for declaratory and injunctive relief. The district court held (1) the unanimity requirement violates article V, section 7, which gives the governor sufficient and separate power to grant pardons; and (2) the unanimity requirement violates article III, section 1 because the state Constitution explicitly provides for the chief justice's participation in the pardon process. The Supreme Court reversed in part and affirmed in part, holding that the statutory provisions did not violate article V, section 7 or article III, section 1 of the Minnesota Constitution. View "Shefa v. Ellison" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Defendant's prior conviction counted as a felony in his criminal history score under Minn. Stat. 152.025, subd. 4(a), holding that there was no error.In 2019, Defendant was convicted and sentenced for domestic assault. Defendant's criminal history included a 2005 petty misdemeanor for marijuana possession and a 2007 fifth-degree controlled substance conviction. At issue on appeal was whether Defendant's 2007 conviction should count as a gross misdemeanor or as a felony in calculating Defendant's criminal history score. The district court concluded that Defendant's petty misdemeanor was a prior conviction under chapter 152 and so his 2007 conviction was properly counted as a felony. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant's 2005 petty misdemeanor qualified as a prior conviction under section 152,025, subd.4(a). View "State v. Morgan" on Justia Law

The Supreme Court reversed Defendant's conviction of illegal possession of ammunition, holding that the district court erred by denying Defendant's motion to suppress.During a traffic stop, law enforcement officers questioned Defendant, who was a passenger in the stopped vehicle, regarding the conditions of his pretrial release. After Defendant was arrested for violating a condition of his pretrial release, a pat-down search revealed ammunition in Defendant's pocket. Defendant filed a motion to suppress, arguing that the officer’s questions about the conditions of his pretrial release improperly expanded the scope of the traffic stop. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) violation of a condition of pretrial release does not constitute criminal activity allowing a law enforcement officer to expand the scope of a traffic stop; and (2) the officer's questioning of Defendant about the conditions of his pretrial release exceeded the permissible scope of a traffic stop. View "State v. Sargent" on Justia Law

The Supreme Court reversed in part the decision of the court of appeals affirming in part and reversing in part the judgment of the district court granting the Attorney General's motion to compel responses to a civil investigative demand, holding that the demand must be narrowed and that the court of appeals erred in limiting the scope of the demand.The Attorney General issued the demand at issue under Minn. Stat. 8.31 to Madison Equities, Inc. and nine of its subsidiary and related companies (collectively, Madison Group) to investigate allegations of wage theft. The Madison Group sought a protective order from the district court, arguing that the demand was overbroad. The Attorney General, in turn, moved to compel responses to the demand. The district court denied the Madison Group's motion and granted the Attorney General's motion. On appeal, the court of appeals limited the demand to information related to security guards from only four of the Madison Group entities. The Supreme Court reversed in part and remanded the case, holding that the court of appeals (1) correctly determined that the definition of "worker" in the demand must be narrowed; and (2) erred in limiting the scope of the demand to certain of the companies. View "Madison Equities, Inc. v. Office of Attorney General" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court ordering Defendant to pay a total of $87,500 in restitution to two victims, holding that the district court did not consider Defendant's ability to pay as required by Minn. Stat. 611A.045, subd. 1.In the instant case, neither the parties nor the county probation office provided meaningful information to the district court about Defendant's income, resources, and obligations. Further, the record did not reflect that the district court considered Defendant's ability to pay. The Supreme Court reversed the restitution order, holding (1) a district court must expressly state, either orally or in writing, that it has considered a defendant’s income, resources, and obligations when ordering restitution; and (2) the record must include sufficient evidence about the defendant’s income, resources, and obligations to allow a district court to consider the defendant’s ability to pay. View "State v. Wigham" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of obtaining public assistance to which he was not entitled through willfully false statements, holding that there was no error in the proceedings below.At issue on appeal was the correction interpretation of Minn. Stat. 256.98, subd. 1, which prohibits wrongfully obtaining public assistance. Defendant was found guilty of violating the statute. On appeal, Defendant argued that the language of the statute required the State to prove that he intended to defeat the purposes of all of the public assistance programs enumerated within the statute. The Supreme Court affirmed, holding (1) the plain language of section 256.98 does not require a defendant to act with an "intent to defeat the purposes of" every listed public assistance program listed in the statute; and (2) there was sufficient evidence to prove that Defendant acted with the intent to defeat the purposes of two of the listed programs. View "State v. Irby" on Justia Law