Justia Minnesota Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the district court granting Defendant postconviction relief by ordering a substantive sentencing hearing, holding that, under the circumstances of this case, it would be manifestly unfair for the district court not to hold a substantive sentencing hearing in accordance with State v. Warren, 592 N.W.2d 440 (Minn. 1999).After a jury trial, Defendant was convicted of two counts of first-degree murder. Defendant was seventeen years old when he committed the offenses. The district court sentenced Defendant to two consecutive sentences of life in prison without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, the district court resentenced Defendant to two consecutive sentences of life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant subsequently filed his postconviction petition requesting a substantive hearing to consider whether, pursuant to the test articulated in Warren, his modified sentences should be served concurrently rather than consecutively. The district court granted the petition. The Supreme Court affirmed, holding that the unique circumstances of this case warranted the exercise of this Court's inherent supervisory powers to direct that the district court hold a substantive sentencing hearing in accordance with Warren. View "State v. Thompson" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of felony domestic assault-harm under Minn. Stat. 609.2242, subds. 1(2), 4, holding that there was no error in the proceedings below and that the evidence was sufficient to support the conviction.On appeal, the court of appeals concluded that the district court erred by instructing the jury that Defendant could use reasonable force to resist an "assault against the person" rather than to resist any "offense against the person" but that the error was not plain and that sufficient evidence supported the conviction. The Supreme Court affirmed, holding (1) use of nonlethal self-defense under section 609.06, subd. 1(3) requires a person to resist an offense carrying the threat of bodily harm; (2) the district court's use of the phrase "assault against the person" in the jury instruction at issue was not error; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Lampkin" on Justia Law

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The Supreme Court affirmed the decision of the district court summarily denying Appellant's petition for postconviction relief without an evidentiary hearing, holding that Appellant was conclusively entitled to no relief on his claims even if the facts alleged were proven by a preponderance of the evidence.Appellant, who was imprisoned for first-degree premeditated murder, filed a petition seeking postconviction relief and an evidentiary hearing, arguing that he was deprived of his Sixth Amendment right to effective assistance of appellate counsel in his direct appeal. The district court summarily denied relief. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the postconviction petition without an evidentiary hearing. View "Woodard v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court and court of appeals finding that a repurchase rate in a litigation financing agreement violated Minnesota's usury statute, Minn. Stat. 334.01, holding that such an agreement is not subject to the usury law when repayment of the purchase price is contingent upon a recovery in the underlying litigation.Appellants sought enforcement of a litigation financing agreement they entered into with Respondent. The lower courts deemed the agreement unenforceable as violating the common-law prohibition on champerty. Following reversal, Respondent challenged the enforceability of the agreement on several different grounds. The district court and court of appeals held that the repurchase rate violated section 334.01 and that the rate, reduced to eight percent, began to accrue after the date of the Court's decision in Maslowski I. The Supreme Court reversed and remanded the case, holding (1) the agreement was not subject to section 334.01; (2) remand was required to address Respondent's challenge to the repurchase rate under the common-law doctrine of unconscionability; and (3) the repurchase rate began to accrue after the litigation financing agreement was signed, not after this Court's abolition of the former prohibition on champerty. View "Maslowski v. Prospect Funding Partners LLC" on Justia Law

Posted in: Contracts
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The Supreme Court held that, under Minnesota statutes in a condemnation proceeding, Blue Earth County did not owe just compensation to Landowners for the loss of a right to access to a newly constructed controlled-access highway built across their property.The district court ruled that Landowners had not been deprived of any right of access for which they should be justly compensated, noting that the County continued to provide farm access to Landowners' property. The court of appeals affirmed. The Supreme Court affirmed, holding that a person who owns property abutting a newly constructed controlled-access highway has no right of access to the controlled-access highway. View "Wood v. County of Blue Earth" on Justia Law

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The Supreme Court reversed the conclusions of the district court and court of appeals that Minn. Stat. 515B.2-118(b), a statute of limitations contained within the Minnesota Common Interest Ownership Act, applied to bar Appellant's claims in this case, holding that the lower courts erred.Appellant owned and operated a common interest community in Richfield that was registered under the Act in 2004. Following a repair project, Appellant sought commercial contributions from Respondent, who refused under the belief that its property interest had been severed from the community. Both parties brought actions seeking declarations as to whether Respondent was required to contribute to the repair project. Respondent cited an amended declaration, recorded in 2007, in arguing that it was not a member of the community and thus not responsible for contributions. The district court and court of appeals concluded that section 515B.2-118(b) applied to bar Appellant's claims. The Supreme Court reversed, holding that the statute of limitations contained in section 515B.2-118 for challenging the validity of an amendment or supplemental declaration does not bar an action that broadly challenges not the underlying validity of an amended declaration but whether severance occurred under the statute. View "City Bella Commercial, LLC v. City Bella on Lyndale" on Justia Law

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The Supreme Court affirmed in part and vacated in part the decision of the tax court that the taxable 2018 market value of a DoubleTree in Bloomington was $25,500,000, an amount that exceeded the valuations offered by the DoubleTree's owner and the County of Hennepin, holding that remand was required on a single issue.The County initially assessed the value of the DoubleTree property at $31,586,400, but Relator, the DoubleTree's owner, appealed the valuation to the tax court. After a trial, the tax court determined that the taxable 2018 market value of the DoubleTree was $25,500,000. The Supreme Court vacated the judgment in part and otherwise affirmed, holding that remand was required for the tax court to revisit and explain its adoption of the percentage reduction to the sales price of one of the hotels it used in its sales comparison analysis to account for non-taxable assets included in the sales price of comparator hotels. View "Bloomington Hotel Investors, LLC v. County of Hennepin" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and his sentence of life in prison without the possibility of release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confrontation when it admitted the victim's dying declarations into evidence during the jury trial, and this Court reaffirms that dying declarations are an exception to the Confrontation Clause; (2) the district court did not violate Defendant's Fifth Amendment right to counsel by denying Defendant's motion to suppress his statements to police officers because Defendant validly waived his invoked right to counsel; and (3) there was no reasonable possibility that the admission of Spreigl evidence related to a prior assault charge into evidence significantly affected the verdict. View "State v. Buchan" on Justia Law

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The Supreme Court held that an action taken by the Minnesota Pollution Control Agency (MPCA) in issuing a National Pollutant Discharge Elimination System/State Disposal System permit was arbitrary and capricious and that the permit did not comply with a Minnesota rule addressing wastewater discharges to groundwater, Minn. R. 7060.0600, subp. 2.At issue was the MPCA's issuance of the permit for a Poly Met Mining, Inc. project. The court of appeals reversed in part, concluding that the MPCA failed properly to consider whether the federal Clean Water Act (CWA) applied to future discharges from Poly Met's facility to groundwater. The Supreme Court remanded the cause, holding (1) remand was required because there were suggestions that the MPCA did not properly consider whether the permit complies with the CWA and that the MPCA did not genuinely engage in reasoned decision-making; (2) remand was required for consideration of whether a variance was available to allow the planned discharge to the unsaturated zone within the containment system; and (3) the prohibition on injecting polluted water directly to the groundwater saturated zone for long-term storage did not apply in this case. View "In the Matter of the Denial of Contested Case Hearing Requests & Issuance of National Pollutant Discharge Elimination System" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals denying Defendant's motion for a new trial, holding that the record was insufficient to determine whether Defendant's right to a public trial was violated due to restrictions put in place by the district court arising from the COVID-19 pandemic.In December 2019, Defendant was charged with first-degree aggravated robbery. Because of the restrictions placed on trials due to the pandemic the county submitted a trial plan that excluded all spectators from the courtroom but included a one-way video feed that would broadcast the trial in an adjacent courtroom. The trial court overruled Defendant's objection, and the trial proceeded. After Defendant was convicted he moved for a new trial. The court of appeals denied the motion. The Supreme Court reversed, holding that additional findings were required on the decision to close the courtroom before it could be determined whether Defendant's public trial right was violated. View "State v. Bell" on Justia Law