Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of second-degree driving while impaired, holding that the State properly used Defendant's license revocation as an aggravating factor to enhance his charge of driving while impaired.Defendant was charged with second-degree driving while impaired for refusal to submit to chemical testing in violation of Minn. Stat. 169A.25, subd. 1(b), which requires that the defendant both refuse to submit to chemical testing and the presence of one aggravating factor. Defendant's prior license revocation was the aggravating factor, but the State waited until the license revocation was sustained to charge Defendant. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) a license revocation is "present" as an aggravating factor as of its effective date, and it may be used to enhance a charge of driving while impaired once review has occurred or the right to review has been waived; and (2) therefore, the State properly used Defendant's license revocation as an aggravating factor. View "State v. Anderson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's sentences in connection with his conviction for two counts of violating an order of protection (OFP) under Minn. Stat. 518B.01, subd. 14(d)(1), holding that the multiple-victim rule authorized two sentences in this case and that Defendant's consecutive sentences did not unfairly exaggerate the criminality of his behavior.A temporary OFP prohibited Defendant from contacting either his infant son or his son's mother. After Defendant had contact with both his son and the mother at a hotel, the State charged Defendant with two counts of violating an OFP. Defendant pleaded guilty to both counts, and the district court sentenced him to two permissive consecutive sentences. The court of appeals affirmed the sentences, concluding that Minn. Stat. 609.035, subd. 1 did not prohibit the district court from imposing multiple sentences for crimes that were committed during a single behavioral incident. The Supreme Court affirmed, holding (1) the multiple-victim rule applied in this case because Defendant made in-person contact with two protected persons, and therefore, there were two victims of the OFP-violation crime; and (2) Defendant's sentences did not exaggerate the criminality of his behavior. View "State v. Alger" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the district court's denial of Defendant's request for non-identifying information about a confidential reliable informant's relationship with police and the informant's information-gathering activities, holding that the State's common law privilege to withhold the identity of an informant does not protect non-identifying information.Defendant was charged with drug possession and sale crimes. Defendant filed discovery and suppression motions seeking information about a confidential reliable informant, on whose observations the State relied to obtain a warrant to search Defendant's home. The district court denied the motions, concluding that Defendant was not entitled to discover the informant's identity or any other information about the informant. Defendant was convicted of fifth-degree sale of a controlled substance. The court of appeals reversed, holding that the State's common law privilege did not protect non-identifying information. The Supreme Court affirmed, holding that the court of appeals (1) properly concluded that the State's common law privilege does not apply to non-identifying information; and (2) did not err in concluding that the non-identifying information Defendant requested related to the case, as required by Minn. R. Crim. P. 9.01. View "State v. Dexter" on Justia Law

The Supreme Court affirmed the decisions of the district court denying Appellant's ineffective assistance of trial counsel claim raised in his first petition for post conviction relief and the claims raised in his second petition for postconviction relief, holding that the district court did not abuse its discretion by denying Appellant's claims.After a jury trial, Appellant was found guilty of first-degree felony murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed. In his first petition for postconviction relief, Appellant raised some of the same issues addressed in his direct appeal but also claimed that he received ineffective assistance of trial counsel. The district court ordered an evidentiary hearing only on the ineffective assistance of counsel claim and, after a hearing, denied the claim. Appellant then filed a second petition for postconviction relief, which the district court summarily denied. The Supreme Court affirmed both of the district court's orders, holding (1) Appellant did not satisfy the first prong of Strickland on his ineffective assistance of counsel claim; and (2) all of Appellant's claims in his second petition were time barred. View "Griffin v. State" on Justia Law

In this medical malpractice case, the Supreme Court reversed the decision of the court of appeals concluding that the district court abused its discretion by admitting testimony about causation from Dr. John Stark, an orthopedic surgeon, and Dr. Kevin Stephan, an infection-disease specialist, holding that the district court did not abuse its discretion in admitting the doctors' causation testimony.This action arose from right-knee arthroplasty Dr. James Schaffhausen performed on Plaintiff. In her complaint, Plaintiff argued that, as a result of the surgery, she suffered permanent neurologic damage. The jury found for Plaintiff. Dr. Schaffhausen moved for judgment as a matter of law or a new trial, arguing that it was error for Dr. Stark and Dr. Stephan to testify as to causation because they were not neurologists. The district court denied the motions. The court of appeals reversed, concluding that the experts were not qualified to testify as to causation because they lacked the requisite occupational experience in neurology. The Supreme Court reversed, holding that where the district court carefully weighed the qualifications of Dr. Stark and Dr. Stephan before deciding to admit their testimony, the court did not abuse its discretion in admitting their testimony on the issue of causation. View "Marquardt v. Schaffhausen" on Justia Law

In this case involving a Minnesota voter's request for access to information in Minnesota's statewide voter registration list the Supreme Court held that registered Minnesota voters have access to "public information lists" as defined by law, as well as to information provided by the secretary of state, but the Legislature has restricted access to the other information sought.A statewide voter registration list is contained in the Statewide Voter Registration System (SVRS). The Secretary of State is responsible for administering the SVRS, and the Legislature has allowed some of the information in the SVRS to be made available for inspection in the form of a "public information list." Plaintiff sought access to non-private government data"from the SVRS. The Secretary informed Plaintiff that he was entitled to information in the SVRS related to currently registered Minnesota voters but declined to produce SVRS information on voter status and other issues. The district court ordered the Secretary to produce the requested data. The court of appeals affirmed. The Supreme Court reversed, holding that the relevant provisions of the Minnesota Government Data Practices Act and the Minnesota Election Law provides that access to the voter registration list contained in the SVRS is limited to "public information lists" and to information provided by the Secretary. View "Cilek v. Office of Minnesota Secretary of State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction for failure to register as a predatory offender, holding that Defendant's 1992 California conviction for sexual battery did not require him to register as a predatory offender under Minn. Stat. 234.166, subd. 1b(b).When Defendant was incarcerated in Minnesota, prison officials informed him that he was required to register as a predatory offender because of his 1992 California conviction. Because Defendant did not register in the fall of 2016 the State charged him with failing to register as a predatory offender. The district court found Defendant guilty. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant's California criminal sexual battery conviction was not an offense requiring registration in Minnesota because California's criminal sexual battery could be proven without proving a violation of Minnesota's fourth-degree criminal sexual conduct by force or coercion. View "State v. Martin" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction of felony deprivation of parenting rights in violation of Minn. Stat. 609.26, subd. 1(3) on the grounds that the evidence was insufficient because the circumstances proved supported a reasonable inference that Defendant did not have a subject intent to substantially deprive her child's father of parenting time, holding that the court of appeals erred when it concluded that the State presented insufficient evidence to support the conviction.Implicit in the court of appeals' analysis was an assumption that section 609.26, subd. 1(3) required the State to prove that Defendant had the subjective intent substantially to deprive the father of his parental rights. The Supreme Court reversed, holding (1) section 609.26, subd. 1(3) establishes an objective standard that focuses on the nature of the defendant's action; and (2) the only reasonable inference that can be drawn from the circumstances proved here was that Defendant's actions, viewed objectively, manifested an intent substantially to deprive the child's father of court-ordered parenting time. View "State v. Culver" on Justia Law

The Supreme Court affirmed the judgment of the tax court concluding that the market value of a distribution-warehouse property in Rogers, Minnesota was $15,638,000 as of January 2, 2014 and $15,597,000 as of January 2, 2015, holding that the tax court did not err in any of the ways asserted by Medline Industries.Specifically, the Supreme Court held that the tax court (1) did not err by crediting some of the county appraiser's opinions despite rejecting his opinion about the highest and best use of the property as a multi-tenant facility; (2) did not clearly err in the sales-comparison approach by relying on four comparable sales other than the May 2017 of a former Walgreens distribution center; (3) did not err in its income approach analysis; and (4) did not err in relying on the cost approach. View "Medline Industries, Inc. v. County of Hennepin" on Justia Law

The Supreme Court affirmed Defendant's conviction of simple robbery, holding that the evidence was sufficient to support Defendant's conviction.On appeal, Defendant argued that the evidence introduced at trial was insufficient to establish that her temporary use of force overcame another person's resistance, as required by Minn. Stat. 609.24. The Supreme Court affirmed, holding (1) the force element of simple robbery is satisfied the moment an actor uses force for the purpose of overcoming another's resistance to the taking or carrying away of property; and (2) the State provided sufficient evidence of Defendant's use of force to sustain a conviction for simple robbery. View "State v. Townsend" on Justia Law