Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of two counts of first-degree murder under an aiding and abetting theory of liability and one count of second-degree murder under an aiding and abetting theory, holding that Defendant was not entitled to a new trial.Specifically, the Supreme Court held (1) assuming that the district court’s failure to give the jury an instruction that accomplice testimony must be corroborated was plain error, the error did not affect Defendant's substantial rights; (2) the evidence against Defendant was sufficient to prove his guilt beyond a reasonable doubt; and (3) any flaws in the indictment did not prejudice Defendant's substantial rights. View "State v. Davenport" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's Minnesota Human Rights Act and common-law negligence claims against a university and a hospital for race- and sex-based discrimination, holding that the district court erred in dismissing Plaintiff's employment discrimination claim under the Act and Plaintiff's common-law negligence claims.Plaintiff's claims stemmed from discrimination she allegedly experienced during a practicum program as a graduate student. The district court dismissed Plaintiff's claims under the Act as time barred and dismissed her common-law negligence claims for failure to establish that Defendants owed her a common-law duty separate from the obligations owed under the Act. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiff's employment discrimination claim under the act against Allina Health System was timely, and the district court erred in determining that Plaintiff's lack of compensation from the practicum barred her claim; (2) Plaintiff's remaining statutory discrimination claims against Defendants were time barred; and (3) Plaintiff alleged sufficient facts to maintain her common-law negligence claims. View "Abel v. Abbott Northwestern Hospital" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the district court's dismissal of a medical malpractice action brought against a hospital system based on the alleged negligence of independent contractors involved in providing care for a patient in the emergency rooms of two different hospitals owned by the hospital system, holding that a hospital can be held vicariously liable for the negligence of an independent contractor based on the doctrine of apparent authority.In granting the hospital system's motion to dismiss, the district court ruled that a hospital is not vicariously liable for the acts of non-employees. The court of appeals affirmed. The Supreme Court reversed, holding that a plaintiff states a vicarious liability claim against a hospital for the professional negligence of independent contractors in the hospital's emergency room based on a theory of apparent authority if the hospital held itself out as a provider of emergency medical care and the patient looked to the hospital, rather than a specific doctor, for care and relied on the hospital to select the physical and other medical professionals to provide the necessary services. View "Popovich v. Allina Health System" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that an ordinance adopted by the City of Minneapolis that prohibits certain property owners, property managers, and others from refusing to rent property to prospective tenants in order to avoid the burden of complying with the requirements of Section 8 of the United States Housing Act survives due process and equal protection rational basis scrutiny, holding that the ordinance is constitutional.Plaintiffs, property owners who owned and rented residential properties in the City, alleged, among other things, that the ordinance violated the Due Process Clause and the Equal Protection Clause of the Minnesota Constitution. The district court granted summary judgment in favor of Plaintiffs, concluding that the ordinance violated equal protection and due process protections. The court of appeals reversed on both claims. The Supreme Court affirmed, holding that the Minneapolis ordinance did not violate the Minnesota Constitution's guarantee of substantive due process or equal protection guarantee. View "Fletcher Properties, Inc. v. City of Minneapolis" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's third petition for postconviction relief, holding that Defendant's petition was untimely under Minn. Stat. 590.01, subd. 4(c).Defendant was convicted of first-degree premeditated murder and unlawful possession of a firearm. The Supreme Court affirmed the convictions. After his first and second petitions for postconviction relief were denied, Defendant filed a third petition for postconviction relief. The district court denied the petition without a hearing, concluding that Defendant's attempt to invoke the interests-of-justice exception was untimely under section 590.01, subd. 4(c). The Supreme Court affirmed, holding that the district court correctly denied the petition as untimely. View "Pearson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of malicious punishment of a child - less than substantial bodily harm, in violation of Minn. Stat. 609.377, subd. 2, holding that section 609.377 does not require the State to prove both that a defendant used unreasonable force and that it was in the course of punishment.On appeal, Defendant argued that there was insufficient evidence to support her conviction. The Supreme Court affirmed, holding (1) the malicious punishment of a child statute is subject to only one reasonable interpretation, the interpretation being that the State must prove that a defendant used unreasonable force but need not prove that the force occurred in the course of punishment; and (2) because Defendant's insufficiency of the evidence claim is premised on the erroneous conclusion that the State needs to prove that she used unreasonable force in the course of punishment, Defendant failed to show that the State presented insufficient evidence. View "State v. Altepeter" on Justia Law