Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the district court's grant of summary judgment to Respondent on Appellant's adverse possession claim, holding that a claim of adverse possession to a portion of a separately assessed parcel requires the adverse claimant to pay taxes for at least five consecutive years unless a statutory exemption under Minn. Stat. 541.02 paragraph 3 applies.Appellant asserted adverse possession over a portion of two separately assessed parcels owned by Respondent. The district court ruled against Appellant's claim for both parcels. The court of appeals affirmed the court's grant of summary judgment to Defendant on Appellant's adverse possession claim for the west parcel but reversed the grant of summary judgment to Respondent as to the east parcel on the grounds that the percentage claimed did not trigger the tax payment requirement in section 541.02. Appellant appealed the court of appeals' decision that his adverse possession claim to fifty-two percent of the west parcel failed, arguing that the statute requires tax payment only for a claim to an entire separately assessed parcel. The Supreme Court affirmed, holding that the plain language of section 541.02 requires tax payment on a portion of a parcel. View "St. Paul Park Refining Co. LLC v. Domeier" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's request for counsel and his pro se petition for post conviction relief, holding that the district court did not abuse its discretion.Appellant was found guilty of first-degree intentional felony murder. Appellant later filed a pro se petition for postconviction relief and requested appointment of counsel, alleging error in the jury instructions, abuse of prosecutorial discretion, and ineffective assistance of counsel. After a hearing, the district court denied relief. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying Appellant's postconviction claim that the judge who presided over his trial committed reversible error by not instructing the jury on the lesser-included offense of second-degree unintentional felony murder; (2) the district court did not err in rejecting Appellant's claim of abuse of prosecutorial discretion; and (3) Appellant's claim of ineffective assistance of counsel failed under the first Strickland prong. View "Eason v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court temporarily enjoining the Secretary of State from taking steps to enforce or require compliance with voter-assistance and ballot-collection limits, holding that the district court correctly found that a likelihood of success on the merits was shown on the claim that the voter-assistance limit in Minn. Stat. 204C.15, subd. 1, for ballot marking, was preempted but otherwise erred.At issue was the limits in Minnesota Statutes on the number of voters that an individual may assist in marking a ballot and the number of completed absentee ballots the an individual may collect and deliver. In a complaint, two Democratic committees brought a number of challenges to the limits. The district court concluded that the Democratic committees were likely to succeed on the merits of the claims and had demonstrated that a temporary injunction was warranted. The Supreme Court affirmed the district court's decision on the preemption claim as to the limit on the number of voters that may be assisted in marking a ballot but otherwise reversed, holding that the district court abused its discretion in finding that a likelihood of success on the merits was shown on Plaintiffs' remaining claims. View "DSCC v. Simon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of giving a fictitious name to a peace officer in violation of Minn. Stat. 609.506, subd. 1, holding that a fictitious name includes a partial legal name for purposes of section 609.506, subd. 1.On appeal, Defendant argued that the evidence introduced at trial was insufficient to prove that he gave the peace officer a fictitious name because he gave police a name that was part of his full name. The court of appeals affirmed, holding that "the statute criminalizes giving an investigating police officer any name or name variant that would tend to mislead the officer away from one's true identity in official records." The Supreme Court affirmed, holding (1) the plain meaning of "fictitious name" in section 609.506, subd. 1 means names that are false and includes names that use only parts of a full legal name; and (2) there was sufficient evidence to support Defendant's conviction. View "State v. Thompson" on Justia Law

The Supreme Court reversed the opinion of the court of appeals affirming the judgment of the district court denying Appellant's petition for a writ of mandamus to order the Dakota County Sheriff to issue Defendant a permit to carry a firearm, holding that Appellant satisfied all the requirements for a writ of mandamus.In 1998, Appellant was adjudicated delinquent for theft of a motor vehicle. In 2014, the Legislature removed that offense from the definition of "crime of violence" in Minn. Stat. 624.712, subd. 5. In 2017, Appellant applied to the Dakota County Sheriff's Office for a permit to carry a firearm. The Sheriff issued Appellant a permit. When the Sheriff learned of Appellant's 1998 juvenile adjudication, however, he voided Appellant's permit. Appellant petitioned for a writ of mandamus directing the sheriff to issue a permit. The district court denied the petition. The court of appeals affirmed. The Supreme Court reversed and issued a writ of prohibition, holding that the 2014 amendment applied to Defendant, and therefore, Defendant was entitled to a permit. View "Tapia v. Leslie" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the jury's award of damages to Tamara Laechelt in this eminent domain action, holding that evidence of construction-related interference that arises after the date of taking is admissible to establish the value of the remainder property.A panel of commissions determined the amount of compensation Laechelt should be awarded for the County's acquisition of temporary and permanent easements from Laechelt. The County appealed the award and moved to exclude evidence of construction-related interference because the interference occurred after the date of the taking. The district court denied the motion and subsequently denied the County's motion for a new trial. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not err by denying the County a new trial. View "County of Hennepin v. Laechelt" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief without holding an evidentiary hearing, holding that, even if the facts alleged in the petition were proven by a preponderance of the evidence, Defendant was conclusively entitled to no relief.Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. In his postconviction petition, Defendant alleged that both his trial counsel and his appellate counsel provided ineffective assistance. The district court summarily denied Defendant's claims of ineffective assistance, concluding that Defendant failed to allege facts that, if proven by a fair preponderance of the evidence, would entitle him to postconviction relief. The Supreme Court affirmed, holding that Defendant was conclusively entitled to no relief, and therefore, the district court did not abuse its discretion by summarily denying Defendant's claims. View "Chavez-Nelson v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals concluding that personal care assistants were entitled to access a list of contact information for personal care assistants who provide home-based services to participants in state programs, holding that the personal care assistants were not entitled to the list.Respondents were a group of personal care assistants who were denied access to the list to gather support for their attempt to decertify a public union as their exclusive representative. Respondents sued the pertinent government agencies under a provision of the Public Employment Labor Relations Act, Minn. Stat. 179A.54, subd. 9 (the PERLA provision). The district court ordered disclosure of the list, determining that personal care assistants are state employees for purposes of the Minnesota Government Data Practices Act, Minn. Stat. 13.01-.90, rendering their "personnel data" publicly accessible. The court of appeals held that Respondents were not entitled to the list under the PERLA provision but were entitled to the list under the Minnesota Government Data Practices Act, Minn. Stat. 13.01-.90. The Supreme Court reversed in part, holding that Respondents were not entitled to the list under either the PERLA provision or the Data Practices Act. View "Greene v. Minnesota Bureau of Mediation Services" on Justia Law

The Supreme Court held that a health care provider who did not intervene in an employee's pending workers' compensation proceeding after receiving adequate notice of the right to intervene cannot initiate a collateral attack on the compensation award under Minn. Stat. 176.271, .291 or Minn. R. 1420.1850, subp. 3B.Scott Koehnen was injured during the course and scope of his employment for Flagship Marine Company. Koehnen received chiropractic treatment from Keith Johnson. Johnson submitted his charges to the workers' compensation insurer for Koehnen's employer, but both the employer and insurer (collectively, Flagship Marine) denied liability for Koehnen's injury. When Koehnen filed a claim petition seeking workers' compensation benefits his attorney sent a notice informing Johnson of his right to intervene. Johnson, however, did not move to intervene, and the proceeding continued without him. Koehnen and Flagship Marine subsequently entered into a settlement agreement. The compensation judge approved the stipulation for settlement and issued an award on stipulation. Johnson later filed a petition for payment of medical expenses pursuant to section 176.271, .291.The compensation judge dismissed the petition, and the Workers' Compensation Court of Appeals affirmed. The Supreme Court affirmed, holding that because Johnson chose not to intervene his petition was correctly dismissed. View "Koehnen v. Flagship Marine Co." on Justia Law

The Supreme Court affirmed the judgment of the tax court determining that Minnesota could tax an apportioned share of the income from the sale of a business as unitary business income, holding that the gain from the sale is business income of a unitary business.YAM Special Holdings, Inc. sold a majority interest in its Go Daddy business and reported the gain from the sale as income not subject to Minnesota tax. The Commissioner of Revenue assessed tax on an apportioned share of the income. On appeal, the tax court concluded that the income from the sale was business income subject to Minnesota tax. The Supreme Court affirmed, holding that the income generated from the transaction was business income of a unitary business, and therefore, Minnesota may tax that income through apportionment. View "YAM Special Holdings, Inc. v. Commissioner of Revenue" on Justia Law