Justia Minnesota Supreme Court Opinion Summaries

The Minnesota Supreme Court affirmed the decision of the lower courts to terminate a mother's parental rights due to her failure to appear for the final day of a multiple-day termination of parental rights trial. The mother, identified as S.T., had argued that the district court violated her procedural due process rights by refusing to reschedule the trial to allow her to testify, offer additional witnesses, and cross-examine witnesses. However, the Supreme Court found that S.T. failed to demonstrate that the outcome of the trial was materially affected by her absence. The Supreme Court noted that although S.T.'s absence was troubling, the district court's refusal to continue or reschedule the hearing did not automatically violate due process. The court concluded that S.T. did not make a sufficient case that her testimony or that of her proposed witnesses would have materially affected the outcome of the trial. Therefore, the court upheld the termination of S.T.'s parental rights. View "In the Matter of the Welfare of the Children of: G.A.H. and S.T., Parents" on Justia Law

In 2015, a group of parents brought a class action lawsuit on behalf of their children, who were enrolled in Minneapolis and Saint Paul public schools. The parents claimed that the state of Minnesota violated their children's right to an adequate education under the Education Clause of the Minnesota Constitution due to the racial and socioeconomic segregation present in the schools. The case went through several years of litigation, and the district court certified a question for immediate appeal: whether racial imbalances in Minneapolis and Saint Paul public schools are sufficient, standing alone, to establish a violation of the Education Clause. The Minnesota Supreme Court reformulated the certified question and held that racial imbalances in Minneapolis and Saint Paul public schools, standing alone, are not sufficient to establish a violation of the Education Clause. The court ruled that while the parents do not have to establish that state action caused the racial imbalances, they must show that the racial imbalances are a substantial factor in causing their children to receive an inadequate education. The case was remanded back to the district court for further proceedings. View "Cruz-Guzman, as guardian and next friend of his minor children vs. State of Minnesota" on Justia Law

The Minnesota Supreme Court ruled that an individual can bring a private action under the Minnesota private attorney general statute to compel a healthcare provider to disclose that individual’s medical records as required by the Minnesota Health Records Act. This decision was based on the interpretation of the private attorney general statute, which the court concluded applies to laws regarding unfair, discriminatory, and other unlawful practices in business, commerce, or trade. The court found that the Minnesota Health Records Act, which mandates the timely disclosure of health records to patients, falls within this category. However, the court also held that an individual does not have a private right of action under the Minnesota Health Care Bill of Rights to compel a healthcare provider to disclose an individual’s medical records. The ruling affirmed in part, reversed in part, and remanded the case to the district court for further proceedings. View "Findling vs. Group Health Plan, Inc." on Justia Law

The Supreme Court affirmed the decision of the Minnesota Tax Court affirming the assessment of the Commissioner of Revenue assessing tax on an apportioned share of Cities Management, Inc.'s (CMI) income from the sale of the S corporation, holding that the income from the corporation's sale was apportionable business income.CMI, which did business in Minnesota and Wisconsin, and its nonresidential partial owner filed Minnesota tax returns characterizing the sale of CMI's goodwill as income that was not subject to apportionment by the State under Minn. Stat. Ann. 290.17. The Commissioner disagreed and assessed tax on an apportioned share of the corporation's income from the sale. The tax court affirmed. The Supreme Court affirmed, holding that CMI's income did not constitute "nonbusiness" income under section 290.17, subd. 6 and may be constitutionally apportioned as business income. View "Cities Management, Inc. v. Commissioner of Revenue" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree felony murder but reversed and vacated his conviction for second-degree murder, holding that it was error to convict Defendant of first-degree murder as well as the lesser-included offense of second-degree murder.After a jury trial, Defendant was found guilty of both first-degree felony murder and second-degree intentional murder and sentenced to life in prison with the possibility of release after thirty years. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not abuse its discretion by prohibiting Defendant from asserting his entrapment defense at trial and denying his request for jury instructions on the lesser-included offenses; (2) the evidence was sufficient to support the jury's guilty verdicts; but (3) the district court erred by entering convictions for both first-degree felony murder and second-degree intentional murder after the jury returned the guilty verdicts. View "State v. Cruz" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellants' appeal of the dismissal of their petition for permanent third-party custody of their great niece, K.J., holding that the court of appeals erred in dismissing the appeal for failure to timely serve the guardian ad litem with a notice of appeal under Minn. R. Civ. App. P. 103.01, subdivision 1.After Appellants filed their petition the district court appointed a guardian ad litem. A referee approved a stipulation of shared joint legal and physical custody of K.J. by Respondent, K.J.'s mother, and K.J.'s father. After a hearing, the court dismissed Appellants' petition for third-party custody. The court subsequently discharged the guardian ad litem, after which Appellants appealed. The court of appeals dismissed the appeal for failure to timely serve the guardian ad litem under Rule 103.01, subdivision 1. The Supreme Court reversed, holding (1) the guardian ad litem was no longer a party to the action once she was discharged by the district court; and (2) Rule 103.01, subdivision 1 does not require service of a notice of appeal on a former party whose dismissal is not itself the subject of the appeal. View "Blakey v. Jones" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the final order of the Commissioner of the Department of Human Services' (DHS) concluding that Trinity had engaged in the abuse outlined in DHS's notices and spreadsheets, holding that the first report of the administrative law judge (ALJ) was the binding decision in this matter.Trinity Home Health Care, which provided nursing and personal care assistant services, received reimbursement from DHS for services that it provided to Medicaid-eligible people with disabilities. After an investigation, DHS sent Trinity notices of termination from the program and demanding return of overpayments and payment-withholding. Both before and after remand by the Commissioner, the ALJ found that terminating Trinity's participation in the Minnesota Health Care Programs was an inappropriate sanction for Trinity's failure to provide certain records. The Commissioner modified the report, concluding that Trinity had engaged in the abuse alleged by the DHS. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Commissioner did not have the authority to remand the case due to the DHS's general authority to administer and supervise Medicaid; and (2) the Commissioner did not have implied authority to remand the case to the ALJ under case law. View "In re Surveillance & Integrity Review Appeals by Trinity Home Health Care Services" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court concluding that federal regulations implementing the federal Health Insurance Portability and Accountability Act (HIPAA) is a "specific authorization in law" under Minn. Stat. 144.293, subd. 2(2), holding that the court of appeals did not err.After Children's Health Care informed Appellants that their child's protected health information was disclosed to Children's institutionally-related foundation and its business associate for fundraising purposes Appellants sued, arguing that Children's violated the Minnesota Health Records Act, Minn. Stat. 144.291-.298. The district court granted summary judgment for Children's, concluding that the disclosure of the patient's health information was specifically authorized in law by federal regulations implementing HIPAA. The court of appeals affirmed. The Supreme Court affirmed, holding that the disclosure of the health information at issue was permitted by a "specific authorization in law," as that phrase is used in the Minnesota Health Records Act. View "Schneider v. Children's Health Care" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree intentional felony murder while committing burglary, holding that the State presented sufficient evidence to sustain Defendant's conviction.After a jury trial, Defendant was found guilty of three counts, including first-degree intentional felony murder while committing burglary. The trial court imposed a life sentence with eligibility for release after thirty years. Defendant appealed, arguing that the State presented insufficient evidence to prove his intent to kill. The Supreme Court affirmed, holding that the circumstantial evidence presented by the State was sufficient to support Defendant's conviction for first-degree intentional felony murder. View "State v. Colgrove" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of one count of possession of a firearm by an ineligible person under Minn. Stat. 609.165, subd. 1b(a), holding that a dissembled and incomplete shotgun can meet the plain language definition of a firearm under section 609.165, subd. 1b(a).Law enforcement officers discovered a disassembled twenty-gauge shotgun in Defendant's backpack, and a forensic scientist used a bolt and washer from a similar firearm to assembly and successfully fire the shotgun at issue. Defendant was found guilty of one count of possession of a firearm by an ineligible person. The court of appeals affirmed. The Supreme Court affirmed, holding that the evidence was sufficient for the jury to reach the commonsense verdict that it did. View "State v. Stone" on Justia Law