Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court amending a spousal maintenance award granting in favor of Respondent, Appellant's former wife, holding that the district court abused its discretion in deciding it could not consider the principal of certain cash gifts as an available source of income for spousal maintenance.After almost five years of dissolution-related court proceedings, Appellant moved to eliminate or amend a spousal maintenance award granted in favor of Respondent on the ground that there had been a substantial change of circumstances making the initial award "unreasonable and unfair." The motion stemmed, in part, from two cash gifts given to Appellant by her parents after the divorce totaling $500,000. The district court concluded that the spousal maintenance statute prohibited it from considering the principal of the cash gifts as a financial resource available for Appellant's self-support. The court of appeals affirmed. The Supreme Court reversed, holding that post-dissolution gifts received by a maintenance recipient are a financial resource a district court may consider under the spousal maintenance statute. View "Honke v. Honke" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of theft under a principal theory of criminal liability and of being an indelible person in possession of a firearm, holding that the district court erred when it failed to conduct a Confrontation Clause analysis surrounding the testimonial statement of a nontestifying co-conspirator, but the error was harmless.On appeal, Defendant argued that the district court violated his right to confrontation by admitting his co-conspirator's statements to the police when Defendant had no opportunity to cross-examine his co-conspirator. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the district court violated Defendant's right to confrontation when it admitted the disputed statements into evidence at trial; but (2) the violation of the Confrontation Clause was harmless beyond a reasonable doubt. View "State v. Sutter" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court finding Defendant guilty of violating a domestic abuse no contact order (DANCO), holding that the State did not violate Defendant's rights under the Minnesota Uniform Mandatory Disposition of Detainers Act (UMDDA).Defendant made a proper request for a final disposition under the UMDDA, and the State dismissed the charges pending against him. Nearly one year later, the State refiled the charges and brought Defendant to trial. The Supreme Court affirmed the resulting conviction, holding (1) once the State dismissed the pending complaint, Defendant no longer enjoyed a right to disposition of that complaint under the UMDDA; (2) the delay between Defendant's speedy trial request and his trial did not violate his constitutional right to a speedy trial; and (3) the district court did not abuse its discretion by declining to dismiss the State's complaint under Minn. R. Crim. P. 30.02. View "State v. Mikell" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) vacating factual findings made by the workers' compensation judge regarding the reasonableness and necessity of an employee's medical treatment for work-related injuries, holding that the WCCA erred.Respondent received a Gillette-style injury to her neck and upper spine. Respondent was later notified by her former employer, Appellant, that it would no longer approve reimbursement for certain injections. A compensation judge determined that the injections were neither necessary nor reasonable. The WCCA reversed, concluding that the decision of the compensation judge was not supported by substantial evidence in the record. The Supreme Court reversed, holding that the WCCA erred in (1) vacating the workers' compensation judge's factual findings; and (2) directing the compensation judge to consider whether Respondent's case presented rare circumstances warranting an exception from the treatment parameters. View "Leuthard v. Independent School District 912" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction of violating Minn. Stat. 260C.425, subd. 1(a), holding that section 260C.425, subd. 1 does not require the State to prove that a child is actually in need of protection or services.Under section 260C.425, subd. 1, it is a gross misdemeanor for a person to encourage, cause, or contribute to the need for protection or services. Defendant was convicted under the statute after he sent a note to a ten-year-old girl telling her to meet him at the railroad tracks. The court of appeals reversed, concluding that that the evidence was insufficient to prove that the girl was actually in need of protection or services. The Supreme Court reversed, holding that the court of appeals erred in concluding that the State must prove that actual services were needed. View "State v. Boss" on Justia Law

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