Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court denied Petitioners' petition filed under Minn. Stat. 204B.44(a) asking that the Supreme Court direct the Minnesota Secretary of State to include Roque De La Fuente's name as a candidate for The Republican Party of Minnesota's nomination for United States President on the ballot for the Minnesota presidential nomination primary election on March 3, 2020, holding that Petitioners' claims failed.Petitioners argued that the procedure established by Minn. Stat. 207A.13, which allows a major political party to determine which candidates' names will be on the ballot for a statewide presidential nomination primary, was unconstitutional. The Supreme Court disagreed, holding that section 207A.13 does not violate (1) the prohibition against special privileges because the Legislature had a rational basis for classifying political parties based on a party's participation in a national convention to nominate the party's presidential candidate; (2) the Presidential Eligibility Clause because requiring a political party to identify the candidates for the ballot to be used in a presidential nomination primary is not a condition of eligibility to serve as President of the United States; and (3) Petitioners' rights of free association because any burden imposed on those rights by the ballot preparation procedures is outweighed by the associational rights of political parties and the State's regulatory interests. View "De La Fuente v. Simon" on Justia Law

The Supreme Court affirmed Defendant's convictions for eight crimes relating to the break in, robbery, and murder at James Herron's home but reversed the sentence imposed on Defendant for the first-degree aggravated robbery of Herron, holding that Defendant could not properly be sentenced for both first-degree murder while committing an aggravated robbery and first-degree aggravated robbery.Specifically, the Court held (1) the district court properly admitted Spreigl evidence at trial; (2) the district court did not abuse its discretion in denying Defendant's proposed defense of duress; (3) even assuming without deciding that the district court erred by admitting evidence from Defendant's Facebook account, including business records and photos, the error was harmless; but (4) the district court erred by sentencing Defendant for more than one of the additional crimes committed against Herron after the initial burglary. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's second petition for postconviction relief, holding that the district court properly declined to grant Appellant a new trial and that Appellant's remaining claims also did not entitle him to relief.The Supreme Court reversed in part the district court's denial of Appellant's second postconviction petition and remanded for a determination of whether an evidentiary hearing was required to consider evidence set forth in two affidavits. The district court conducted a hearing and found that the testimony set forth in the affidavits was not credible. The Supreme Court affirmed, holding (1) Appellant did not establish that he was entitled to a new trial under the tests set forth in Rainer v. State, 566 N.W.2d 692 (Minn. 1997), and State v. Caldwell, 322 N.W.2d 574 (Minn. 1982); and (2) the remainder of Appellant's claims were did not entitle Appellant to relief. View "Anderson v. State" on Justia Law

In this challenge to a zoning ordinance prohibiting industrial mineral operations within Winona County the Supreme Court affirmed the decision of the court of appeals affirming the order of the district granting summary judgment to the County on all of Minnesota Sands, LLC's claims, holding that the ordinance was constitutional.Minnesota Sands, a mining company, sought to mine and process silica sand in the County. Minnesota Sands sued the County requesting declaratory, injunctive, and monetary relief. The district court granted summary judgment to the County. The court of appeals affirmed, concluding that the ordinance did not violate the dormant Commerce Clause or work an unconstitutional taking of Minnesota Sands' property interests. The Supreme Court affirmed, holding (1) Minnesota Sands had standing to bring this case; (2) the County's ordinance did not violate the dormant Commerce Clause on its face, in purpose or in effect; and (3) Minnesota Sands' takings claims failed because the property interests it claimed were taken by the County had not yet accrued. View "Minnesota Sands, LLC v. County of Winona, Minnesota" on Justia Law

The Supreme Court dismissed Defendant's appeal from an order of the court of appeals affirming the district court's denial of Defendant's request for funding under Minn. Stat. 611.21(a) for out-of-court interpreter services to facilitate attorney-client communication with his public defender, holding that Defendant waived the interpreter-funding issue by pleading guilty before filing his petition for review.Defendant was charged with second-degree assault and attempted second-degree murder. Defendant needed an interpreter for his court appearances and meetings with his public defender. Defendant filed two ex parte applications to fund interpreter services, which the district court denied. Defendant pled guilty to second-degree assault and then filed a petition for review. The Supreme Court dismissed Defendant's appeal, holding that Defendant waived his right to challenge the denial of his request for funding by pleading guilty before filing his petition for review. View "State v. Montanez" on Justia Law