Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals concluding that the factual findings of the Minnesota Pollution Control Agency were "insufficient to facilitate judicial review" of a permitting decision, holding that the Agency is not required under the Clean Air Act, 42 U.S.C. 7401-7671q, and its applicable regulations to investigate allegations of "sham" permitting when a source first applies for a synthetic minor source permit.At issue was whether the Agency was required to investigate allegations of sham permitting when consider whether to approve the air-emissions permit of PolyMet Mining, Inc. for a proposed mine. Respondents challenged the Agency's decision to issue the synthetic minor source permit, asserting that the Agency failed to conduct an adequate investigation into whether PolyMet intended to operate within the limits of the permit or whether it was instead seeking a sham permit. The court of appeals concluded that the Agency's short response to the concerns of Respondents was not the "hard look" required under the Minnesota Administrative Procedure Act, Minn. Stat. 14.69. The Supreme Court reversed, holding that the applicable federal regulations and guidance contemplate retrospective enforcement after the applicant has obtained a synthetic minor source permit and do not mandate prospective investigation. View "In re Issuance of Air Emissions Permit No. 13700345-101 for PolyMet Mining, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the determination of the district court that the Freeborn County Board of Commissioners acted arbitrarily when it set the 2019 salary of the Freeborn County Sheriff at $97,020, holding that the district court did not clearly err.In the salary appeal, the district court concluded that the Board acted arbitrarily and without sufficiently taking into account the responsibilities and duties of the sheriff's office because the testifying commissioners did not explain why they decided on a salary of $97,020. The court of appeals reversed, concluding that the district court's findings and conclusions were clearly erroneous. The Supreme Court reversed, holding that the district court did not clearly err in setting aside the Board's salary decision because there was reasonable support in the record for the court's determination that the Board's salary decision was arbitrary. View "In re Year 2019 Salary of Freeborn County Sheriff" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's denial of Appellant's petition for postconviction relief after determining that his stay of adjudication and discharge from probation was not a conviction, holding that Appellant's stay of adjudication was not a conviction.Pursuant to a plea agreement, Appellant pleaded guilty to domestic assault-intentional infliction of bodily harm. The district court accepted Appellant's plea of guilty and stayed adjudication under the parties' agreement. After Appellant successfully completed and was discharged from probation he received notice that he was scheduled for immigration removal proceedings. Appellant filed a petition for postconviction relief seeking to withdraw his guilty plea on grounds that he received ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356 (2010). The postconviction court concluded that Appellant had not been convicted of a crime and was therefore not eligible for postconviction relief. The Supreme Court affirmed, holding (1) the plain meaning of the phrase "a person convicted of a crime" in Minn. Stat. 590.01, subd. 1 means a person who has a conviction under Minnesota law; and (2) Appellant's stay of adjudication did not meet this definition. View "Johnston v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the court of appeals concluding that Officer Eric Reetz was not entitled to defense and indemnification from his employer, the City of Saint Paul, when Reetz was sued for allegedly failing to detect a knife at a homeless shelter while working off duty as a private security guard, holding that the court of appeals erred.The City concluded that it was not obligated to defend and indemnify Reetz under Minn. Stat. 466.07 under the circumstances of this case. The court of appeals reversed. The Supreme Court reversed, holding (1) as a matter of law, Reetz was not "acting in the performance of the duties of the position" of a police officer when he allegedly failed to detect a knife that was banned only by the shelter's policies; and (2) therefore, the City was not required to defend and indemnify Reetz. View "Reetz v. City of Saint Paul" on Justia Law

The Supreme Court held that groundwater is a Class 1 water under Minnesota law and therefore subject to secondary drinking water standards promulgated by the United States Environmental Protection Agency (EPA).In 2018, the Minnesota Pollution Control Agency (MPCA) issued a National Pollutant Discharge Elimination System/State Disposal System permit to United States Steel Corporation (U.S. Steel) governing U.S. Steel's Minntac Tailings Basin Area in Mountain Iron and setting a groundwater sulfate limit of 250 mg/L at the facility's boundary that U.S. Steel must meet by 2025. On appeal, U.S. Steel argued that the MPCA did not have the authority to impose the sulfate standard in the permit because the EPA's secondary drinking water standards apply only to bodies of water classified as Class 1 waters and that groundwater is not classified as Class 1. The court of appeals agreed and reversed the MPCA's decision. The Supreme Court reversed, holding (1) groundwater is a Class 1 water under Minnesota law; and (2) therefore, the MPCA correctly exercised its authority by applying the Class 1 secondary drinking water standards to the permit. View "In re Reissuance of NPDES/SDS Permit to United States Steel Corp." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court holding that the adoption of a comprehensive plan is not a proper subject of a claim under the Minnesota Environmental Rights Act (MERA), Minn. Stat. 116B.01-.13, holding that adoption of a comprehensive plan can be the subject of a MERA claim and that Appellants' allegations were sufficient to state a claim under MERA.This appeal centered a claim challenging the City of Minneapolis's 2040 Comprehensive Plan, alleging that the City's adoption of the Plan violated the state's environmental law. The district court dismissed the complaint, concluding that because comprehensive plans are specifically exempt from environmental review under Minn. R. 4410.4600, comprehensive plans are also exempt from judicial review under MERA. The court of appeals affirmed. The Supreme Court reversed, holding (1) rule 4410.4600 does not exempt comprehensive plans from environmental review under MERA; and (2) the facts alleged in the complaint, if true, state a claim upon which relief can be granted. View "State by Smart Growth Minneapolis v. City of Minneapolis" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting the City of Plainview's motion to dismiss Donald Hall's contract and statutory claims, holding that the City had a contractual obligation to pay accrued paid time off (PTO) to Hall.After the City terminated Hall's employment as manager of the City's municipal liquor store it refused to pay Hall accrued PTO due to Hall's failure to provide sufficient notice per the requirements of the City's personnel policies and procedures manual. Hall sued the City for breach of contract and violation of Minn. Stat. 181.13. The district court dismissed Hall's contract and statutory claims. The Supreme Court remanded the case, holding (1) disclaimer provisions in the City's employee handbook stating that the handbook's policies should not be construed as a contract did not unambiguously allow the City to refuse to pay accrued PTO in accordance with the employer policy set forth in the handbook; and (2) Minn. Stat. 181.13(a) does not create an independent substantive right to payment of accrued PTO in the absence of a contract between the employer and employee. View "Hall v. City of Plainview" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's complaint alleging that he witnessed Defendant's workers violate safety protocols resulting in contamination of his home, holding that Minn. Stat. 541.051 barred Plaintiff's claims.Plaintiff hired Defendant to remove a broken boiler that was insulated with asbestos and his asbestos pipe insulation. On March 12, 2014, a report confirmed Plaintiff's allegation that Defendant's workers tracked asbestos through Plaintiff's home. Plaintiff, however, did not sue Defendant until April 20, 2018. The district court dismissed the complaint on the grounds that the two-year statute of limitations in section 541.051 barred Plaintiff's claims. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff's damages arose out of the defective and unsafe condition of an improvement to real property, and therefore, the two-year statute of limitations in section 541.051, subdivision 1(a) barred Plaintiff's claims. View "Moore v. Robinson Environmental, Inc." on Justia Law

In this case alleging that Minnesota State Colleges and Universities (MnSCU) failed to maintain and produce certain government data the Supreme Court reversed the decision of the court of appeals holding that Plaintiff's complaint under the Minnesota Government Data Practices Act was insufficiently pleaded and affirmed the court's holding that the Minnesota Official Records Act did not authorize a private cause of action, holding that the allegations of Plaintiff's complaint were sufficient.In his complaint, Appellant alleged that the actions of MnSCU violated both the Data Practices Act and the Official Records Act. The district court dismissed both claims, concluding that Appellant could not pursue judicial remedies under the Data Practices Act after obtaining an administrative remedy under the that and that the Official Records Act does not authorize a private cause of action. The court of appeals affirmed but decided the Data Practices Act issue on the alternate ground that the complaint was insufficiently pleaded. The Supreme Court reversed in part, holding (1) Appellant's complaint was sufficiently pleaded; and (2) the Official Records Act does not authorize a private cause of action. View "Halva v. Minnesota State Colleges & Universities" on Justia Law

The Supreme Court affirmed as modified as modified the decision of the court of appeals reversing the judgment of the district court denying Maria Molloy's motion to intervene in Pamela Spera's proceeding seeking enforcement of a divorce decree that dissolved her marriage to Rodney Miller, holding that Molloy had a right to intervene as to the valuation of Miller's retirement accounts.In the enforcement proceeding, Spera sought to have the retirement accounts she and Miller each held divided according to the terms of the divorce decree. Before Miller passed away, he named his four daughters - including K.M.M., the child he had with Molloy - as beneficiaries on his retirement accounts. Molloy sought to intervene in Spera's enforcement proceeding as a matter of right to assert K.M.M.'s interest in Miller's retirement accounts. The district court denied intervention. The court of appeals reversed, concluding that the four requirements under Minn. R. Civ. P. 24.01 for intervention were met. The Supreme Court affirmed as modified, holding that Molloy's right to intervene was limited specifically to the valuation of Miller's retirement accounts. View "Miller v. Molloy" on Justia Law