Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court that non-homestead life estates should not be included in Marvin Schmalz's assets, holding that the term "individual" in Minn. Stat. 256B.056, subd. 4a applies only to the applicant for medical assistance.Esther Schmalz was living at a long-term-care facility when she submitted an application for medical assistance for long-term-care benefits. As part of the assessment of her husband Marvin's assets, Renville County Human Services (RCHS) included Marvin's portion of several non-homestead life estate interests that he and Esther owned. Esther appealed, arguing that the life estates should not be included in the total amount of assets that Marvin may retain. The human services judge concluded that RCHS properly denied Esther's application for medical assistance based on the inclusion of the life estate assets owned by Marvin. The Commissioner of Minnesota Department of Human Services adopted the human services judge's recommendation. The district court concluded that the non-homestead life estates should not be included in Marvin's assets, ruling that the term "individual" in section 256B.056, subd. 4a included Marvin. The Supreme Court reversed, holding that an "individual" in the statute refers to the medical assistance applicant and not a community spouse. View "In re Schmalz" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction on the ground that Defendant was denied effective assistance of counsel because, by conceding in the written closing argument elements of the crimes charged, Defendant's attorney conceded guilt without Defendant's consent or acquiescence, holding that no new trial was required.In reversing the conviction, the court of appeals reasoned that defense counsel's concession of one or more elements of a crime is a concession of guilt and that an unconsented-to concession requires a new trial. The Supreme Court reversed, holding (1) defense counsel's concessions of fewer than all of the elements was not a concession of guilt, and therefore, no new trial was required; and (2) counsel's concessions did not amount to trial error under Strickland v. Washington, 466 U.S. 668 (1984). View "State v. Huisman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the district court's decision that the Minneapolis Sick and Safe Time Ordinance violated the extraterritoriality doctrine, holding that because the primary purpose and effect of the Ordinance is the regulation of sick and safe time within the City of Minneapolis, the Ordinance does not violate the extraterritoriality doctrine.The Ordinance at issue required employers to provide sick and safe time to employees who worked within the city. The district court enjoyed the City from enforcing the Ordinance against employers resident outside the City because the Ordinance violated the extraterritoriality doctrine. The court of appeals reversed, concluding that the Ordinance's primary purpose and effect was to regulate activity within the geographic boundaries of Minneapolis, and therefore, the Ordinance did not violate the extraterritoriality doctrine. The Supreme Court affirmed, holding that because the primary purpose and effect of the Ordinance is the regulation of sick and safe time within the City, the Ordinance does not violate the extraterritoriality doctrine. View "Minnesota Chamber of Commerce v. City of Minneapolis" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Father's paternity action on the grounds that Minn. Stat. 259.25, subd. 8 barred the action, holding that the statute did not bar Father's action.Father failed to register with the Minnesota Fathers' Adoption Registry within thirty days of the birth of his child. Father subsequently filed this paternity action seeking to be adjudicated as his child's father. The district court dismissed the action, concluding that because Father had failed timely to register with the Fathers' Adoption Registry he was barred under Minn. Stat. 259.52, subd. 8 from bringing or maintaining a paternity action. The court of appeals affirmed. The Supreme Court reversed, holding that Minn. Stat. 259.52, subd. 8 did not apply to Father under the circumstances of this case. View "T. G. G. v. H. E. S." on Justia Law

In this wrongful death case, the Supreme Court affirmed the judgment of the court of appeals affirming the district court's grant of summary judgment for Honeywell International, holding that a claim accrues in an asbestos-related wrongful death action when the fatal disease is causally linked to asbestos.Deborah Palmer brought this action against Honeywell after her husband, Gary Palmer, died from mesothelioma. The district court dismissed the case, concluding that the statute of limitations barred Deborah's claim because she filed her action more than six years after Gary learned that exposure to asbestos had caused his mesothelioma. The court of appeals affirmed. The Supreme Court affirmed, holding (1) under DeCosse v. Armstrong Cork Co., 319 N.W.2d (Minn. 1982), wrongful death actions brought in connection with asbestos-related deaths accrue either upon the manifestation of the fatal disease in a way that it causally linked to asbestos or upon the date of death, whichever is earlier; and (2) because Deborah did not file this wrongful death action until more than six years after the claim accrued, Minn. Stat. 573.02, subd. 1 barred her claim. View "Palmer v. Walker Jamar Co." on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's convictions for first-degree premeditated murder, first-degree domestic abuse murder, and second-degree intentional murder, holding that the district court violated Minn. Stat. 609.04 when it entered convictions on the offenses of first-degree domestic abuse murder and second-degree intentional murder in addition to the conviction for first-degree premeditated murder.The Supreme Court affirmed the jury's verdicts but remanded the case to the district court to vacate the convictions for first-degree domestic abuse murder and second-degree intentional murder, holding (1) the evidence was sufficient to support the jury's verdicts; (2) the district court did not commit reversible error in admitting statements Defendant made during interviews with police; but (3) the district court erred by convicting Defendant of first-degree domestic abuse murder and second-degree intentional murder in addition to first-degree premeditated murder. View "State v. Balandin" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the district court's grant of summary judgment in favor of Defendant after concluding that Plaintiff failed to allege conduct sufficiently severe or pervasive to support a claim for sexual harassment, holding that the conduct alleged by Plaintiff was sufficiently severe or pervasive for a reasonable person to find the work environment to be hostile or abusive.In granting summary judgment to Defendant, the district court determined that the conduct alleged did not meet the severe-or-pervasive standard for actionable sexual harassment based on a hostile work environment. The court of appeals affirmed. The Supreme Court reversed in part, holding (1) Plaintiff has not presented the Court with a compelling reason to abandon the severe-or-pervasive standard for analyzing the objective component of a claim for sexual harassment under the Minnesota Human Rights Act, Minn. Stat. 363A.01-.44; and (2) considering the totality of the circumstances, Plaintiff presented sufficient evidence for a reasonable jury to decide that the complained of behavior was sufficiently severe or pervasive to substantially interfere with Plaintiff's employment or to create an intimidating, hostile, or offensive employment environment. View "Kenneh v. Homeward Bound, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court that Appellant could not enforce the contract between Appellant and Respondent whereby Appellant purchased an interest in Respondent's personal injury suit because it violated Minnesota's common law prohibition against champerty, holding that Minnesota's common-law prohibition against champerty is abolished.When Respondent settled her suit and did not abide by the terms of the contract, Appellant sued to enforce the contract. Both the district court and the court of Appeals held that Appellant could not enforce the agreement against Respondent because Minnesota law applied to the agreement and the agreement violated Minnesota's common-law prohibition against champerty. The Supreme Court reversed, holding (1) because the contract was champertous the lower courts did not err in determining that, under prior decisions, the contract was unenforceable; but (2) changes in the legal profession and in society show that the ancient prohibition against champerty is no longer necessary. View "Maslowski v. Prospect Funding Partners LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court denying the motion to dismiss filed by State Representative John Lesch on a claim brought by Lyndsey Olson, Saint Paul City Attorney, for defamation per se based on statements Lesch made in a letter sent to the mayor of Saint Paul, holding that legislative immunity did not protect Lesch's letter.Lesch's letter, which was written on Lesch's official letterhead from the Minnesota House of Representatives but was marked "personal and confidential," suggested that Olson was not the right person for the position of City Attorney. Olson brought a defamation suit against Lesch, alleging that Lesch "knowingly, intentionally and maliciously made false and defamatory" statements about her in the letter. Lesch moved to dismiss the complaint, asserting that his statements were communications that were protected by legislative immunity under the Speech or Debate Clause of the Minnesota Constitution and under Minn. Stat. 540.13. The district court denied the motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that neither Article IV, Section 10 nor section 540.13 extended legislative immunity to Lesch's letter. View "Olson v. Lesch" on Justia Law

The Supreme Court held that the Commissioner of the Department of Natural Resources had the statutory authority to change the official name of a well-known Minneapolis lake from Lake Calhoun to Bde Maka Ska because the forty-year limitation on lake name changes in Minn. Stat. 83A.05, subd. 1 applies only to county boards, not to the Commissioner.In 2018, the Commissioner invoked his authority under Minn. Stat. 83A.02(1), (3) to change the name of Lake Calhoun to Bde Maka Ska. Respondent argued that section 83A.05's provision prohibiting changing a body of water's name "which has existed for 40 years" applied to the Commissioner's statutory authority to change the lake's name. Respondent petitioned for a writ of quo warranto challenging the Commissioner's authority. The district court denied the petition, concluding that ongoing action was necessary to obtain the writ and that there was no such action here. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) a writ of quo warranto was an appropriate method to challenge the Commissioner's authority in this case; but (2) the Commissioner's authority under section 83A.02(1), (3) to change the name of a lake is not limited by section 83A.05, subd. 1. View "Save Lake Calhoun v. Strommen" on Justia Law