Justia Minnesota Supreme Court Opinion Summaries

A man was involved in a single-vehicle accident in Minnesota, after which law enforcement discovered a self-assembled pistol in his car that lacked a serial number. He admitted to possessing the firearm and not having a permit to carry it. The firearm, a Glock 19-style pistol, was constructed from parts purchased in 2021, before new federal regulations required serial numbers on certain parts kits. He was charged with felony possession of a firearm without a serial number under Minnesota law, as well as carrying a pistol without a permit.The Anoka County District Court granted the defendant’s motion to dismiss the charge related to the serial number, finding that while he knowingly possessed a firearm without a serial number, the relevant Minnesota statute was unconstitutionally vague as applied. The State appealed. The Minnesota Court of Appeals reversed the district court, holding that the statute plainly applied to any firearm lacking a serial number, regardless of whether federal law required one, and remanded the case for further proceedings.The Supreme Court of Minnesota reviewed the case. It held that Minnesota Statutes section 609.667(3) criminalizes possession of a firearm without a serial number only if federal law requires that the firearm have a serial number. The court reasoned that Minnesota has no independent serial number regime and that the statute’s reference to federal law means only firearms required by federal law to have serial numbers are covered. Because the defendant’s firearm was not required by federal law to have a serial number, the Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court. View "State v. Vagle" on Justia Law

An employee who worked as a packaging operator began experiencing left shoulder pain, which she attributed to her work activities. After seeking medical treatment, including surgery, her employer and its workers’ compensation insurer initially accepted her claim as work-related but later denied it based on an independent medical examination. While the workers’ compensation claim was pending, the employee’s health insurer paid for her medical expenses as required by Minnesota law when compensability is disputed. The employee then filed a workers’ compensation claim seeking a determination that her injury was compensable and that her employer should cover her medical expenses. The health insurer was notified of its right to intervene in the proceedings but did not do so within the statutory deadline.A compensation judge found the employee’s injury was work-related and compensable, but concluded that the employee could not bring a direct claim for medical expenses already paid by her health insurer, reasoning that only medical providers, not insurers, could be the subject of such claims. The judge also ruled that the health insurer’s failure to intervene extinguished its right to reimbursement. The Workers’ Compensation Court of Appeals (WCCA) reversed, holding that the employee could bring a direct claim for the medical expenses paid by the health insurer and that the employer and its insurer must reimburse the health insurer, despite its failure to intervene.The Minnesota Supreme Court reviewed the case. It held that, consistent with its recent decision in Johnson v. Concrete Treatments, Inc., an employee may bring a direct claim under the Workers’ Compensation Act for medical expenses related to a compensable work injury, even if those expenses were paid by a health insurer before compensability was determined. However, the Court also held that the WCCA erred in reviving the health insurer’s independent intervenor interest, which was extinguished by its failure to timely intervene. The Court affirmed in part and reversed in part. View "Brunner vs. Post Consumer Brands" on Justia Law

In 2014, Diamond Lee Jamal Griffin was convicted in Hennepin County District Court of first-degree intentional felony murder while committing or attempting to commit aggravated robbery, stemming from the fatal shooting of Francisco Benitez-Hernandez in Minneapolis in July 2013. Griffin appealed, and the Minnesota Supreme Court affirmed his conviction, concluding that the evidence supported a reasonable inference that Griffin shot Benitez-Hernandez with intent to kill. Griffin's subsequent petitions for postconviction relief were also denied.Griffin filed a preliminary application for relief under a 2023 Minnesota law that allows individuals convicted of certain felony murder offenses under an aiding-and-abetting theory to have their sentences vacated if they can show they neither caused the death nor intentionally aided in causing the death. The Hennepin County District Court denied Griffin's application, concluding that there was no reasonable probability that Griffin was entitled to relief under the new law, based on the application, supporting materials, and previous court decisions.The Minnesota Supreme Court reviewed the case and addressed two primary issues: the appropriate standard of review for appeals under the new law and whether the district court abused its discretion in denying Griffin's application. The court concluded that the standard of review is abuse of discretion, given the text of the law and its treatment of the application as a postconviction proceeding. The court then determined that the district court did not abuse its discretion in denying Griffin's application, as the established facts and prior court decisions supported the conclusion that Griffin caused the death of Benitez-Hernandez. The Minnesota Supreme Court affirmed the district court's decision. View "State of Minnesota vs. Griffin" on Justia Law

Fletcher Properties, Inc. and other appellants own multi-tenant residential properties in Minneapolis. The City of Minneapolis enacted an ordinance prohibiting property owners from refusing to rent to individuals based on requirements of public assistance programs, including Section 8 housing vouchers. Fletcher challenged the ordinance, claiming it violated the Minnesota Constitution’s Takings Clause and was preempted by the Minnesota Human Rights Act (MHRA).The district court initially ruled in favor of Fletcher, finding the ordinance violated due process and equal protection clauses. The court of appeals reversed this decision, and the Minnesota Supreme Court affirmed, remanding the case to address the remaining claims. On remand, the district court granted summary judgment for the City, rejecting Fletcher’s takings and preemption claims. The court of appeals affirmed this decision, leading to the current appeal.The Minnesota Supreme Court reviewed the case and held that the ordinance does not constitute a physical or regulatory taking under the Minnesota Constitution. The court applied the Penn Central factors, concluding that the economic impact of the ordinance, interference with investment-backed expectations, and the character of the government action did not support a finding of a regulatory taking. The court also determined that the ordinance does not effect a physical taking as landlords voluntarily rent their properties and are not compelled to continue doing so.Additionally, the court held that the ordinance is not preempted by the MHRA. The court found no conflict between the ordinance and the MHRA, as the MHRA does not grant landlords an affirmative right to reject voucher holders. The court also concluded that the MHRA does not occupy the field of housing discrimination based on public assistance, allowing for local regulation.The Minnesota Supreme Court affirmed the decision of the court of appeals, upholding the ordinance. View "Fletcher Properties, Inc. vs. City of Minneapolis" on Justia Law

Erick Dewaun Haynes pleaded guilty to first-degree felony murder under an aiding-and-abetting theory. He admitted to planning a confrontation with his ex-girlfriend's new partner, R.C., involving two juveniles armed with handguns. The plan resulted in the juveniles shooting and killing his ex-girlfriend, Zaria McKeever, instead. Haynes received a mandatory life sentence with the possibility of parole. The plea agreement did not specifically address restitution.The district court ordered Haynes to pay $7,500 in restitution to the Minnesota Crime Victims Reimbursement Board (CVRB) and reserved the determination of additional restitution for 90 days. Haynes did not challenge this order. The State later sought additional restitution for McKeever’s family members, totaling $17,026.06. Haynes did not object to this request either, and the district court granted it.Haynes appealed the restitution award, arguing that the district court failed to make necessary factual findings and that some restitution recipients were not "victims" under the statute. The Minnesota Supreme Court reviewed the case and concluded that Haynes forfeited his challenges by not raising them in the district court. The court emphasized that challenges to restitution must be made within 30 days of the order, as outlined in Minnesota Statutes section 611A.045, subdivision 3. Since Haynes did not follow this procedure, his challenges were not properly before the court.The Minnesota Supreme Court affirmed the district court’s restitution award, holding that Haynes forfeited his right to challenge the restitution by failing to object in the district court. View "State of Minnesota vs. Haynes" on Justia Law

James Nyonteh was convicted of first-degree premeditated murder, first-degree domestic abuse murder, second-degree intentional murder for killing his wife, and first-degree criminal sexual conduct for sexually abusing his minor stepdaughter. The district court sentenced him to life imprisonment without the possibility of release and a consecutive prison term of 144 months. Nyonteh appealed his convictions, arguing that the district court erred by dismissing a juror for sleeping during the trial, that the State failed to prove beyond a reasonable doubt that his stepdaughter feared imminent great bodily harm during the sexual assaults, and that the district court erred by entering multiple convictions for the same conduct against the same victim.The district court had excused a juror who repeatedly fell asleep during the trial, despite efforts to keep him awake and engaged. The court determined that the juror's inability to stay awake compromised the fairness of the trial. The jury found Nyonteh guilty on all charges, and the district court entered convictions for first-degree premeditated murder and first-degree criminal sexual conduct, but the warrant of commitment also included convictions for first-degree domestic abuse murder and second-degree intentional murder.The Minnesota Supreme Court reviewed the case and held that the district court did not abuse its discretion in excusing the sleeping juror, as the juror's conduct raised concerns about the fairness of the trial. The court also found that the evidence was sufficient to support Nyonteh's conviction for first-degree criminal sexual conduct, as the circumstances proved that his stepdaughter reasonably feared imminent great bodily harm.However, the court agreed with Nyonteh that the district court erred by entering multiple convictions for the same conduct against the same victim. The court reversed the additional convictions for first-degree domestic abuse murder and second-degree intentional murder and remanded the case to the district court to vacate those convictions. The court affirmed the remaining convictions and sentences. View "State of Minnesota vs. Nyonteh" on Justia Law

A hailstorm damaged the roof of Hector Campbell’s home, which was insured under a replacement cost insurance policy by Great Northwest Insurance Company. Campbell hired a contractor to replace the damaged shingles. The contractor discovered that the roof’s decking had gaps larger than permissible under the state code for shingle installation. Consequently, the contractor installed a new layer of sheathing before affixing the new shingles. Great Northwest denied coverage for the sheathing installation and the contractor’s overhead and profit costs, citing policy exclusions.The district court determined that Great Northwest’s denial of coverage for the sheathing violated Minnesota Statutes section 65A.10, subdivision 1, which mandates that replacement cost insurance cover the cost of replacing or repairing damaged property in compliance with the minimum code requirements. However, the court granted summary judgment to Great Northwest on the overhead and profit issue, concluding that Campbell’s policy clearly excluded coverage for those costs. Both parties appealed.The Minnesota Supreme Court reviewed the case. The court held that Minnesota Statutes section 65A.10, subdivision 1, requires Great Northwest to cover the cost of installing the new sheathing because it was necessary to replace the damaged shingles in accordance with the state building code. Therefore, the policy exclusion for sheathing was invalid under the statute. However, the court also held that Great Northwest could deny coverage for the contractor’s overhead and profit because Campbell failed to establish that these costs were part of the “cost of replacing, rebuilding, or repairing any loss or damaged property in accordance with the minimum code as required by state or local authorities.” The court affirmed the decision of the court of appeals on both issues. View "Great Northwest Insurance Company vs. Campbell" on Justia Law

Ricky Darnell Waiters was convicted of first-degree felony murder and attempted first-degree felony murder following a shooting incident in Winona County. His convictions were affirmed on direct appeal. Waiters subsequently filed multiple petitions for postconviction relief, all of which were denied by the district court. In his latest petition, Waiters sought reversal of his convictions or a new trial, citing claims of ineffective assistance of counsel, prosecutorial misconduct, erroneous evidentiary rulings, and insufficient evidence.The district court summarily denied Waiters's latest petition without a response from the State. Waiters appealed, and the Supreme Court of Minnesota remanded the case for further proceedings, as the basis for the district court's decision was unclear. On remand, the State argued that Waiters's claims were both procedurally and time-barred. The district court agreed and again summarily denied the petition, providing a written order with its reasoning. Waiters appealed this decision.The Supreme Court of Minnesota reviewed the case and affirmed the district court's summary denial of Waiters's petition for postconviction relief. The court held that Waiters's petition was time-barred under Minnesota Statutes section 590.01, subdivision 4, as it was filed more than two years after the appellate court's disposition of his direct appeal. The court also found that the exceptions to the time bar, including newly discovered evidence and new interpretations of law, did not apply to Waiters's claims. Consequently, the court concluded that the district court did not abuse its discretion in denying the petition without an evidentiary hearing. View "Waiters vs. State of Minnesota" on Justia Law

A man entered a senior living apartment building in Minneapolis, where he had previously visited several times, and asked to see a vacant apartment. After being shown the apartment by a manager, he pushed her into a closet, choked her, and brandished a knife. The victim fought back and screamed for help, after which the man stopped, apologized, and left. He was later arrested and, after being read his Miranda rights, confessed to police that he had planned to rape the victim but did not follow through. The man was charged with attempted first-degree criminal sexual conduct.The Hennepin County District Court denied the defendant’s motion to suppress his confession, found him guilty of attempted first-degree criminal sexual conduct causing personal injury using force or coercion, and sentenced him to prison. The court found him not guilty of the charge involving use of a dangerous weapon. The defendant appealed, arguing that his conviction violated Minnesota’s corpus delicti statute, which prohibits convictions based solely on a confession. The Minnesota Court of Appeals reversed the conviction, holding that for attempt crimes, the statute requires independent evidence of both intent and a substantial step toward the crime, and found that only the confession established intent.The Minnesota Supreme Court reviewed the case and held that the corpus delicti statute is satisfied for both completed and attempt offenses when there is independent evidence that reasonably tends to prove the defendant committed the charged offense. The court concluded that the State’s evidence, independent of the confession, reasonably tended to show the defendant committed attempted first-degree criminal sexual conduct. The Supreme Court reversed the Court of Appeals’ decision and remanded the case for consideration of the defendant’s remaining appellate arguments. View "State v. Hill" on Justia Law

Wells Fargo Bank filed a complaint against Astra Genstar Partnership, LLP, seeking a declaratory judgment related to a property purchased at a foreclosure sale. Wells Fargo requested a declaration that all previously held interests in the property, including Astra's interest, were terminated. Astra filed an answer opposing Wells Fargo's request. The district court granted Wells Fargo's motion for judgment on the pleadings, ruling that any interest Astra had in the property was terminated by the foreclosure sale and the redemption period's expiration. The court administrator failed to notify the parties of the judgment immediately.The district court entered judgment on December 28, 2023, but the parties did not receive notice until March 15, 2024, after the appeal deadline had passed. Astra appealed to the Minnesota Court of Appeals on May 13, 2024. The court of appeals dismissed the appeal, stating it was late under Minnesota Rule of Civil Appellate Procedure 104 and that Rule 14.01(c)(2) of the Minnesota General Rules of Practice for the District Courts did not apply to appellate courts.The Minnesota Supreme Court reviewed the case and concluded that Rule 14.01(c)(2) does not authorize appellate courts to reinstate a late appeal. However, the court determined that the interests of justice warranted reinstating the appeal because the court administrator failed to transmit notice of the judgment as required by Minnesota Rule of Civil Procedure 77.04. The Supreme Court reversed the court of appeals' decision and reinstated Astra's appeal, emphasizing the need to avoid setting a trap for the unwary and to preserve the right to appeal. View "Wells Fargo Bank v. True Gravity Ventures, LLC" on Justia Law