Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of check forgery, holding that a government inspection of a guest registry is a search under the Minnesota Constitution and that the district court committed reversible error by admitting evidence illegally seized from Defendant's hotel room.Based on evidence that law enforcement officers discovered in Defendant's hotel room, Defendant was charged with check forgery. Defendant filed a motion to suppress, arguing that the officers violated Minn. Const. art. I, 10 when they inspected the hotel guest registry, which led them to his room, without having any individualized suspicion of criminalized activity. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) law enforcement officers must have at least a reasonable, articulable suspicion to search a guest registry; (2) the hotel guest registry statutes, Minn. Stat. 327.10-.13 are constitutional because they do not authorize suspicionless searches; and (3) because the evidence admitted in this case was the fruit of the illegal, suspicionless search of the guest registry the district court erred by denying Defendant's motion to suppress. View "State v. Leonard" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder and second-degree murder but reversed the sentence in part, holding that the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder but any other error in the proceedings below was harmless.Specifically, the Supreme Court held (1) any error the district court may have made by declining to hold an evidentiary hearing regarding the admissibility of DNA evidence was harmless, and the district court did not abuse its discretion by denying Defendant's motion to exclude the DNA evidence; (2) Defendant was not prejudiced by alleged prosecutorial misconduct; and (3) the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder in its sentencing order, and therefore, the cause must be remanded to the district court to correct the error. View "State v. Garland" on Justia Law

The Supreme Court affirmed Defendant's sentences for drive-by shooting at an occupied vehicle and second-degree assault, holding that Minn. Stat. 609.035 did not prohibit the sentences for both offenses when the crimes arose from a single behavioral incident.The district court sentenced Defendant to forty-eight months for drive-by shooting at an occupied vehicle and thirty-six months for second-degree assault and imposed the two sentences to run concurrently. The court of appeals affirmed. The Supreme Court affirmed, holding that, under this Court's analysis in State v. Ferguson, 808 N.W.2d 586 (Minn. 2012), the district court properly imposed multiple sentences in this case. View "State v. Branch" on Justia Law

The Supreme Court affirmed the order of the state district court that revised Appellant's sentence from two consecutive terms of life without the possibility of release to two consecutive terms of life with the possibility of release after thirty years, holding that the court did not abuse its discretion when it strictly followed the terms of the federal district court's remand order.Appellant was convicted of two counts of first-degree premeditated murder and sentenced to two life without parole sentences consecutively. After Miller v. Alabama, 567 U.S. 460 (2012), was decided Appellant filed a petition for a writ of habeas corpus. Ultimately, the federal district court vacated the "without possibility of release" provision of Appellant's sentences and remanded for resentencing. On remand, the state district court, without a resentencing hearing, revised Appellant's sentence to two consecutive terms of life with the possibility of release after thirty years. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that the language of the federal district court order reflected a limited remand; and (2) did not abuse its discretion in concluding that the issue of whether Appellant's sentences should be served consecutively was beyond the scope of the remand order. View "State v. Thompson" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's request for postconviction relief and remanding the case for a new trial, holding that the trial court did not abuse its discretion under Minn. R. Evid. 106 by overruling Defendant's objection and allowing the jury to hear only an excerpt of a recorded police interview.Defendant was charged with second-degree sexual conduct. At trial, the State offered as evidence an eight-minute excerpt of an hour-long, videotaped, voluntary interview of Defendant by a police detective. Defendant objected and argued that the entire recording should be admitted into evidence and played for the jury under Rule 106. The trial court overruled the objection and played only the requested excerpt for the jury. The jury found Defendant guilty. Defendant filed a petition for postconviction relief, challenging the trial court's decision to play only the excerpt of the police interview for the jury. The district court denied postconviction relief. The court of appeals reversed, concluding that the entire interview should have been played for the jury. The Supreme Court reversed, holding that the trial court did not abuse its discretion when it properly overruled Defendant's objection under Rule 106. View "Dolo v. State" on Justia Law