Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court determining that Appellant's claim of ineffective assistance of counsel failed under the second prong of Strickland v. Washington, 466 U.S. 668 (1984), holding that, even if Appellant had offered to plead guilty to second-degree murder, Appellant made no showing that there was a reasonable probability that the State would have entered into a plea agreement.A jury found Appellant guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. Appellant later filed a postconviction motion, alleging that her counsel provided ineffective assistance by failing to recommend that she plead guilty to second-degree murder and by failing adequately to inform her about the power of the State's case. The district court concluded that Appellant had satisfied the first but not the second prong of Strickland. The Supreme Court affirmed, holding that, even assuming that defense counsel's recommendation could have persuaded Appellant to make a qualifying offer, Appellant failed to show that any such offer would have been accepted by the State and presented to the court. View "Peltier v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted third-degree criminal sexual conduct, holding that the State proved that Defendant committed an act that was "a substantial step forward, and more than preparation for" the commission of third-degree criminal sexual conduct.Specifically, the Supreme Court held (1) in the statutory phrase "a substantial step toward, and more than preparation for" in the attempt statute, Minn. Stat. 609.17, the substantial step must be strongly corroborative of the actor's criminal purpose, but it need not objectively reveal the nature of the intended crime; and (2) the evidence in this case proved beyond a reasonable doubt that Defendant intended to commit the crime of third-degree criminal sexual conduct and that he committed an act that was a substantial step toward, and more than preparation for, the commission of the intended crime. View "State v. Wilkie" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's denial of Defendant's petition for postconviction relief, holding that, under Minn. Stat. 260B.245, subd. 1(b), delinquency adjudications may be deemed "felony convictions" for the purpose of the statutory definition of a crime of violence.Defendant was charged with possession of a firearm by an ineligible person, which required proof that Defendant had been convicted of a crime of violence. Defendant pled guilty to the offense, admitting that he had been adjudicated delinquent for committing fifth-degree possession of a controlled substance. The district court accepted the plea and placed Defendant on probation. Defendant later filed a petition for postconviction relief, asserting that his juvenile delinquency adjudication failed to satisfy the definition of a "crime of violence" because, under section 260B.245, a delinquency adjudication cannot be deemed a "conviction of crime." The district court denied postconviction relief. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase "felony convictions," as used in the statutory definition of crime of violence, includes a juvenile delinquency adjudication for felony-level offenses listed in Minn. Stat. 624.712, subd. 5; and (2) Defendant provided an adequate factual basis for his guilty plea. View "Roberts v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the tax court increasing the assessed unit value of a pipeline system for tax years 2015 and 2016, holding that the tax court did not err in its calculations for the cost indicator of value but erred in assigning equal weight to the cost and income indicators of value.On appeal, the taxpayer (1) challenged the tax court's market value determination, asserting that the court erred in its treatment of construction work in progress and external obsolescence in the computation of the cost indicator of value; and (2) challenged the weight that the court assigned to the cost indicator of value, as opposed to the income indicator, in determining the unit value of the pipeline system. The Supreme Court held that the tax court (1) did not err in its calculations for the cost indicator of value; but (2) erred by concluding that it had no discretion to adjust the default weightings prescribed by Minnesota Rule 8100.0300, subpart 5 for the cost and income indicators of value. View "Enbridge Energy, Limited Partnership v. Commissioner of Revenue" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to suppress evidence seized from his vehicle during a traffic stop, holding that a driver violates Minn. Stat. 169.30(b) by driving past the stop sign or stop line before coming to a complete stop.Defendant's vehicle was stopped after he failed to stop at a stop sign and stop line. The district court suppressed the evidence seized from Defendant's vehicle, concluding that the traffic stop was unlawful because Minn. Stat. 169.30(b) requires a driver "to stop at the intersection, not at the stop sign or stop line." The court of appeals reversed. The Supreme Court affirmed, holding (1) section 169.30(b) is violated when the driver a vehicle drives past the stop sign or stop line before coming to a complete stop; and (2) because Defendant failed to bring his vehicle to a complete stop before he drove his vehicle past the stop line and the stop sign, the traffic stop was lawful. View "State v. Gibson" on Justia Law

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