Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Appellant's petition seeking the return of seized property, holding that the district court did not clearly err in finding that the seized property was being held as potential evidence in a pending investigation and in deciding that the property was being held in good faith.Appellant, an attorney, was part of an investigation. Pursuant to a search warrant, law enforcement officers seized electronic devices containing files about Appellant's current and former clients. Appellant filed a motion seeking the return of the seized property. The district court considered the motion to be a petition under Minn. Stat. 626.04 and denied the motion on the ground that the property was being held in good faith as potential evidence in an uncharged matter. While this appeal was pending, Appellant was charged with theft by swindle. The Supreme Court affirmed without prejudice to any future challenge to the lawfulness of the search and seizure, holding that the district court did not abuse its discretion in denying the petition even though the court should have required the State to return the attorney copies of all client files seized. View "K.M. v. Burnsville Police Department" on Justia Law

In this dispute over the amount of loss after a fire occurred at the home of Respondents the Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court granting Respondents' motion to confirm an appraisal award but denying Respondents' motion for preaward interest as untimely, holding that the district court erred by applying the Minnesota Uniform Arbitration Act, Minn. Stat. 572B.01-.31, to a fire loss appraisal award.Respondents' home was insured against fire loss by Appellant. When Appellant and Respondent were unable to agree on the amount of the loss Respondents requested an appraisal. After an appraisal panel issued an award, which State Farm paid, Respondents sought confirmation of the appraisal and moved the court to grant preaward interest on the appraisal award. The superior court confirmed the appraisal award but denied the motion for preaward interest as untimely. The court of appeals reversed and remanded. The Supreme Court affirmed, holding (1) the Act did not apply to the appraisal process under the Minnesota Standard Fire Insurance Policy, Minn. Stat. 65A.01; and (2) a remand was necessary to allow the district court to determine whether Respondents were owed preaward interest and, if so, the amount of interest owed. View "Oliver v. State Farm Fire & Casualty Insurance Co." on Justia Law

The Supreme Court held that the fair and accurate reporting privilege protects news reports about statements on a matter of public concern made by law enforcement officers at an official press conference in an official press release.After Defendant was arrested in connection with a murder three law enforcement agencies held a press conference to announce Defendant's arrest and to discuss the investigation. That same day, the Minnesota Department of Public Safety issued a corresponding press release. Defendant was later released from jail and cleared as a suspect. Defendant sued Respondents for defamation based on their news coverage about his arrest. A jury found for Respondents. The district court set the jury verdict aside and ordered a new trial. The court of appeals reversed and reinstated the judgment for Respondents. The Supreme Court affirmed in part and reversed in part, holding (1) out of the eleven alleged defamatory statements in the news reports the fair and accurate reporting privilege applies to seven statements; and (2) the jury instructions and special verdict form did not adequately set forth the relevant factors that the jury should consider in determining whether the privilege was defeated for lack of fairness and substantial accuracy, and the error was prejudicial as to five of the seven statements. View "Larsen v. Gannett Co., Inc." on Justia Law

In this appeal from the tax court's conclusion that the market value of Relator's two parcels of improved real estate was higher than the initial assessment value determined by Hennepin County or the valuation opinion presented by the sole appraiser to testify at trial the Supreme Court reversed in part the tax court, holding that the tax court erred in its valuation determination under the sales comparison approach.Relator sought review of Hennepin County's assessed value of $8,384,300 for Relator's retail shopping center property as of January 2, 2015. After a trial, the tax court gave a final valuation determination for the property of $8,461,400. Relator appealed, arguing that the tax court's value determination was excessive. The Supreme Court affirmed in part and reversed in part, holding (1) the tax court did not err in its decision to afford no weight to Relator's expert's opinion on the income approach; but (2) the tax court erred in its valuation determination based on the sales-comparison approach. View "Inland Edinburgh Festival, LLC v. County of Hennepin" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the determination of Scott County that Consumer Directed Community Support (CDCS) money that Cindy Ali, whose son was disabled, had allocated to herself as wages to care for her child was not excluded from the annual income calculation for the purpose of Section 8 eligibility, holding that amounts allocated to a parent to care for her disabled child are not excluded as income under 24 C.F.R. 5.609(c)(16).This dispute arose from the interplay between two public welfare programs, the state CDCS option for families with disabled members, and Section 8, an income-based federal housing program. Ali participated in the Section 8 housing program until Scott County, the local housing administrator, determined that the amounts Ali paid herself under the CDCS option were not excluded from her income when calculating her eligibility for Section 8 housing. As a result, Ali lost her Section 8 eligibility. The court of appeals affirmed. The Supreme Court affirmed, holding that the CDCS amounts Ali received as compensation for her services in caring for her child were correctly included as annual income when calculating Ali's Section 8 eligibility. View "In re Cindi Ali" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals holding that a proposed charter amendment was not manifestly unconstitutional but was an improper referendum, holding that the proposed amendment was not an improper exercise of the charter amendment power and was not manifestly unconstitutional.After the City of Bloomington changed from a system of open trash collection to a system of organized collection a group of residents attempted, through an amendment to the City Charter, to require that voters pre-approve a change in the method of trash collection. The City refused to put the proposed charter amendment on the ballot. In the original appeal, the Supreme Court remanded the case to the court of appeals for decision on whether the proposed amendment would violate the Contract Clauses of the United States and Minnesota Constitutions and whether it was an attempt to exercise the voter referendum power through an improper means. On remand, the court of appeals concluded that the proposed amendment was an improper referendum but was not unconstitutional. The Supreme Court reversed in part, holding that the proposed charter amendment was not an improper referendum and did not violate the Contract Clauses. View "Jennissen v. City of Bloomington" on Justia Law

The Supreme Court affirmed the judgment of the district court holding that Appellant, who was injured while she was driving a Pontiac and sought additional primary underinsured motorist (UIM) benefits under an insurance policy that covered a separate vehicle, a Chevrolet, was not entitled to primary UIM benefits under the Chevrolet policy, holding that Appellant could not recover additional primary UIM benefits under the Chevrolet policy.State Farm, Appellant's insurer, paid Appellant the Pontiac policy's UIM benefits limit but denied that the Chevrolet policy applied to Appellant's claim for additional primary UIM benefits. The district court granted summary judgment for State Farm, holding that the Chevrolet policy did not apply under Minn. Stat. 65B.49, subd. 3a(5). The court of appeals affirmed. The Supreme Court affirmed, holding (1) consistent with section 65B.49, subdivision 3a(5) and precedent interpreting that provision, Appellant was limited to primary UIM benefits under the policy that covered the vehicle she occupied at the time of the accident; and (2) even assuming that parties can contract around the priority scheme for primary UIM benefits that the legislature established in section 65B.49, subdivision 3a(5), no explicit language in the State Farm policies actually did so. View "Visser v. State Farm Mutual Automobile Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's petition for postconviction relief, holding that the alleged facts, even when viewed in a light most favorable to Appellant, conclusively showed that he was entitled to no relief.Appellant was convicted of murder and attempted murder. Appellant later filed his postconviction petition alleging that several reversible errors were committed by the judge, prosecutor, and his counsel during his jury trial. The district court denied the petition without holding an evidentiary hearing and without addressing the ineffective assistance of appellate counsel claim. The Supreme Court affirmed, holding (1) Appellant's claims were procedurally barred by State v. Knaffla, 243 N.W.2d 737 (Minn. 1976); and (2) the failure to address the ineffective assistance of appellate counsel claim did not require a remand because the facts alleged conclusively showed that Appellant was not entitled to relief on his claim. View "Zumberge v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant's sentence on count two, first-degree criminal sexual conduct, holding that the district court abused its discretion by imposing a greater than double durational departure on count two.The district court imposed 360-month, consecutive sentences for Defendant's two convictions of first-degree criminal sexual conduct, imposing these greater-than-double durational departures on the sentences based on the aggravating factors of particular cruelty and the particular vulnerability of the victim. In reversing the sentence on count two, the court of appeals determined that imposing a greater-than-double durational departure on a consecutive sentence when both counts involved a single victim unduly exaggerated the criminality of Defendant's conduct. The Supreme Court affirmed, albeit on different grounds, holding that this was not an extremely rare case involving severe aggravating circumstances, and therefore, the district court erred in imposing a greater-than-double durational departure on count two. View "State v. Barthman" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's second petition for postconviction relief, holding that the district court did not abuse its discretion when it denied Appellant's petition.Appellant was found guilty of first-degree premeditated murder and first-degree felony murder and sentenced to life imprisonment. This appeal concerned Appellant's second petition for postconviction relief, in which Appellant requested a new trial based on four theories of ineffective assistance of appellate counsel. The district court denied the petition, concluding, among other things, that Appellant's claims were time barred under Minn. Stat. 590.01, subd. 4(a). The Supreme Court affirmed, holding that Appellant's petition was time-barred and Appellant did not meet the interests of justice exception to the time bar. View "Fox v. State" on Justia Law