Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court reversing a transfer penalty imposed by the Commissioner of the Minnesota Department of Human Services on David Pfoser, a disabled Medicaid recipient who resided in a long-term care facility, after he transferred partial proceeds from the sale of a house into a pooled special-needs trust, holding that Pfoser made a satisfactory showing that he intended to receive valuable consideration for his transfer of assets.State and federal law impose a penalty on recipients, like Pfoser, of Medical Assistance for Long-Term Care benefits if they transfer assets for less than fair market value, but no penalty is imposed if the recipient makes a satisfactory showing that he intended to dispose of the assets either at fair market value or for other valuable consideration. See Minn. Stat. 256B.0595, subd. 4(a)(4). The Commissioner affirmed the transfer penalty imposed on Pfoser. The district court reversed, concluding that Pfoser received adequate compensation in the form of his vested equitable interest in the trust assets. The Supreme Court affirmed, holding that substantial evidence did not support the Commissioner's decision to uphold the penalty. View "Pfoser v. Harpstead" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court finding that Minn. Stat. 617.261 was unconstitutional under the First Amendment, holding that the statute does not violate the First Amendment because it survives strict scrutiny.Defendant was charged with a felony-level violation of Minn. Stat. 617.261, the statute that criminalizes the nonconsensual dissemination of private sexual images. Defendant moved to dismiss the charge on constitutional grounds. The district court denied the motion, concluding that the conduct regulated by the statute is entirely unprotected obscene speech and that any degree of overbreadth was insubstantial. The court of appeals reversed, concluding that the statute is unconstitutionally overbroad because it criminalizes a substantial amount of protected speech. The Supreme Court reversed, holding (1) section 617.261 prohibits more than obscenity; but (2) the restriction does not violate the First Amendment because it is justified by a compelling government interest and is narrowly tailored to serve that interest. View "State v. Casillas" on Justia Law

The Supreme Court affirmed the order of the tax court dismissing Relator's appeal of an tax order sent by the Department of Revenue by regular mail, holding that sending a tax order by regular mail provides constitutionally sufficient notice.The Department sent Relator a tax order assessing sales and use taxes covering a three-year period. The order was sent by regular mail, as authorized by Minn. Stat. 270C.33, subd. 8. Relator appealed, asserting that he only became aware of the tax liability when his bank account was levied on by the Commissioner. The tax court granted the Commissioner's motion to dismiss. The Supreme Court affirmed, holding that Relator's notice was constitutionally sufficient. View "Olson v. Commissioner of Revenue" on Justia Law

The Supreme Court held that a letter contesting a notice of zoning violation was not a "request" as defined by Minn. Stat. 15.99, subd. (1)(c) and therefore did not entitle respondent property owners to the benefit of the automatic approval provision in Minn. Stat. 15.99, subd. (2)(a).The automatic approval provision requires agencies to, within sixty days, approve or deny a written zoning request. Failure to deny such a request within sixty days is deemed an approval of the request. Respondents received notice of a zoning violation from the City of Shorewood after installing a dock and contested the zoning violation in a written letter to the city planning commission. The City did not respond. Thereafter, Respondents were charged by criminal complaint with two misdemeanor violations of the city code. The district court granted Respondents' pretrial motion to dismiss, concluding that Respondents' letter was a "request" under Minn. Stat. 15.99, subd. 1(c), and therefore, Respondents' request for zoning action was automatically approved by operation of law. The Supreme Court reversed, holding that the letter was not a "request" under the statute. View "State v. Sanschagrin" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that a distress flare launcher might qualify as a firearm under Minn. Stat. 624.713, subd. 1 if used or intended to be used as a weapon, holding that a distress flare launcher is not a firearm under the statute.Defendant was charged with possession of a firearm by an ineligible person for possessing a distress flare launcher. The district court granted Defendant's motion to dismiss, concluding that there was insufficient probable cause to support the charge. The court of appeals reversed, concluding that a distress flare launcher could be a "firearm" under section 624.713, subd. 1 if the fact-finder were to conclude that Defendant used or intended to use it as a weapon. The Supreme Court reversed, holding (1) the term "firearm" is limited to weapons, meaning instruments designed for attack or defense; and (2) accordingly, the distress flare launcher in this case was not a weapon and could not be a firearm under the statute. View "State v. Glover" on Justia Law

The Supreme Court dismissed the petition filed by Petitioners asking the Supreme Court to temporarily restrain the State Canvassing Board from certifying the results of the November 3, 2020 general election held in Minnesota and to require a full recount of the federal and state offices on the ballot, holding that the petition must be dismissed.Petitioners asserted three claims in their petition. Counts I and II rested on challenges to consent decrees entered by the district court that suspended the witness requirement for absentee and mail ballots for the 2020 general election. Count III challenged the processes used in some counties for conducting the post-election review. The Supreme Court dismissed the petition, holding (1) Counts I and II were barred by laches; and (2) because Petitioners did not file proof that the petition was served in compliance with Minn. Stat. 204B.44, Count III must be dismissed. View "Kistner v. Simon" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct his sentence of life imprisonment for first-degree premeditated murder, holding that the court did not abuse its discretion in denying Defendant's motion to correct his sentence.The district court convicted Defendant of first-degree premeditated murder and sentenced him to life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant later filed his motion to correct his sentence, arguing that his conviction violated Minn. Stat. 611.02, under which when "there exists a reasonable doubt as to which of two or more degrees the defendant is guilty" a defendant shall be convicted only of the lowest degree offense. The district court denied the motion without a hearing. The Supreme Court affirmed, holding that the district court did not abuse its discretion in concluding that Defendant's conviction did not violate section 611.02. View "Steward v. State" on Justia Law

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