Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Appellants' action seeking judicial review of a zoning variance granted by the Town of Duluth to Charles and Carol Danielson-Bille (the Billes), holding that the Billes should have been joined as a necessary party under Minn. R. Civ. P. 19.01.The Billes sought to build a retirement home on Lake Superior. The Town of Duluth Board of Supervisors granted a zoning variance. In appealing the decision, Appellants properly served Duluth within the thirty-day appeal period set forth in the local Duluth ordinance that authorized judicial review of the zoning variance decision but failed to serve the Billes within the same thirty-day period. Duluth and the Billes filed motions to dismiss, asserting that service was improper. The district court dismissed Billes from the case because they had not been timely served and then dismissed the entire action with prejudice, determining that the Billes were a necessary and indispensable party under Rule 19.01 and that the action could not proceed without them. The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred by dismissing the action rather than joining the Billes to the action under Rule 19.01. View "Schulz v. Town of Duluth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's denial of Defendant's motion to suppress, holding that the officer formed a reasonable, articulable suspicion to make the traffic stop that led to Defendant's arrest.The officer informed Defendant that he had been stopped because the car's windshield was cracked and because it did not appear that Defendant had been wearing his seat belt. Defendant was subsequently charged with driving while impaired and violating his driver's license restriction. Defendant moved to suppress the evidence obtained as a result of the stop, alleging that the stop was unconstitutional. The district court denied the motion to suppress. The court of appeals affirmed, holding that the officer was not justified in stopping Defendant for the crack in his windshield but that the evidence supported a conclusion that the officer had reasonable suspicion that Defendant was not wearing his seat belt. The Supreme Court affirmed, holding that, even if the officer's observation that Defendant was not wearing his seat belt was mistaken, the mistake was objectively reasonable under the circumstances. View "State v. Poehler" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that, by the plain words of Minn. Stat. 604.02, a tortfeasor's liability to an injured employee is not reduced by the employer's fault.At issue was whether the 2003 amendment to Minn. Stat. 604.02, subd. 1 overturned the line of decisions holding that an employer liable to an injured employee under the Workers' Compensation Act and a third party liable in tort to that same employee do not have either joint or several liability. In this case, an employee was injured in the workplace. The employee and his employer settled the workers' compensation claim. The employee brought a negligence against the tortfeasor, which brought a third-party contribution claim against the employer. The jury found that the injury was caused by the employee, the employer, and the tortfeasor. The district court applied section 604.02 to reduce the net damage award to the employee by an amount proportionate to the employer's fault. The court of appeals reversed, concluding that the lower court erred in applying section 604.02 under the circumstances. The Supreme Court affirmed, holding that the tortfeasor's liability to the employee was not reduced by the fault of the employer. View "Fish v. Ramler Trucking, Inc." on Justia Law

The Supreme Court affirmed the decision of the Workers' Compensation Court of Appeals (WCCA) ruling that Minn. Stat. 176.179 did not apply to Appellant's vacated workers' compensation award, holding that no mistaken compensation was paid, and thus, section 176.179 did not apply.Appellant injured his low back during the course of his employment and entered into a settlement agreement with his employer. The WCCA approved the settlement by an award. Appellant later petitioned to vacate the award, arguing that there was a mutual mistake of fact when the settlement was entered into and a substantial change in his medical condition that could not have been anticipated at the time of the award. The WCCA vacated the award based on the substantial change in Appellant's medical condition. When Appellant then filed a claim petition for additional benefits the parties disagreed as to whether Employer was entitled to a credit for the $40,000 already paid under the vacated award. The compensation judge ruled that section 176.179 did not apply and that Employer was entitled to full credit against Appellant's claim for benefits. The Supreme Court affirmed, holding because no mistake of fact or law occurred, no mistaken compensation was paid and that section 176.179 did not apply. View "Block v. Exterior Remodelers, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree manslaughter, holding that the plain language of the first-degree manslaughter statute, Minn. Stat. 609.20(2), does not require the State to prove that death or great bodily harm was a reasonably foreseeable result when the underlying crime is fifth-degree assault.On appeal, Defendant argued that the district court erred by failing to instruct the jury that a conviction for first-degree manslaughter required proof that he committed fifth-degree assault with such violence or force that great bodily harm or death was reasonably foreseeable. The court of appeals affirmed, concluding that the district court did not err in declining to so instruct the jury. The Supreme Court affirmed, holding that section 609.20(2) does not require the State to prove that death or great bodily harm was a reasonably foreseeable result of the defendant's conduct when the underlying crime is fifth-degree assault. View "State v. Stay" on Justia Law

In this case against two for-profit universities (the Schools) alleging that the Schools violated the Minnesota Consumer Fraud Act (MCFA), Minn. Stat. 325F.69, and the Uniform Deceptive Trade Practices Act (DTPA), Minn. Stat. 325D.44, the Supreme Court held that the Attorney General proved that a causal nexus was established between the Schools' fraudulent statements and the harm suffered by students.At issue was whether the Attorney General established a causal nexus between the Schools' statements misleading prospective students about the value of criminal justice degrees offered by the Schools and the harm suffered by students who entered the Schools' criminal justice program. During trial, fifteen students who had enrolled in the criminal justice program testified. The district court ultimately issued an injunction and ordered equitable restitution requiring the Schools to disgorge the tuition collected from the criminal justice program students. The court of appeals upheld the restitution order for the students who testified at trial but reversed the order as to nontestifying students. The Supreme Court reversed in part, holding (1) the Attorney General established a causal nexus between the Schools' misleading statements and the harm suffered by the non testifying students; and (2) the equitable restitution process ordered by the district court was proper. View "State v. Minnesota School of Business, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder, first-degree aggravated robbery, and possession of a firearm by an ineligible person related to a fatal shooting, holding that the district court did not clearly err by overruling Defendant's Batson objection to the State's peremptory challenge of a prospective juror.On appeal, Defendant argued that the district court erred in overruling his Batson objection to the State's peremptory challenge of the juror because the State's challenge was racially motivated and the proffered explanation for exercising the challenge was pretextual. The Supreme Court affirmed, holding that the district court did not clearly err in determining that the race-neutral reason for striking the juror was not a pretext for racial discrimination. View "State v. Adams" on Justia Law

In this case brought under the Federal Employers' Liability Act (FELA), 45 U.S.C. 51-60, the Supreme Court reversed the decision of the court of appeals affirming the district court's use of the federal post judgment interest rate of .058 percent per year after the district court awarded Employee damages, holding that the state post judgment interest rate applies.In his complaint against his employer, BNSF Railway Company, Employee claimed that he suffered cumulative trauma to his back resulting from his twenty years of employment as a conductor and engineer. The jury decided in favor of Employee. The district court awarded damages and postjudgment interest, applying the federal postjudgment interest rate. The Supreme Court reversed and remanded the case to the district court to apply the ten percent postjudgment interest rate set forth in Minn. Stat. 549.09, subd. 1 (c)(2), holding that postjudgment interest in an action brought under FELA in Minnesota courts is calculated in accordance with Minn. Stat. 549.09, subd. 1(c). View "Alby v. BNSF Railway Co." on Justia Law

In this personal injury action, the Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court deducting from a damages award to Respondent the amount of discounts negotiated by Respondent's managed-care organizations, holding that the discounts were payments made pursuant to the United States Social Security Act under Minn. Stat. 548.251, subd. 1(2).After her car struck a school bus that failed to yield at an intersection, Respondent brought this action against the driver and the owner of the bus (collectively, Appellants). The medical expenses of Respondent, a medical-assistance enrollee, were covered by two managed-care organizations that contracted with Minnesota's Prepaid Medical Assistance Plan under the state's Medicaid program. The jury awarded damages, but the district court deducted from the award the discounts negotiated by the managed-care organizations. The court of appeals reversed. The Supreme Court affirmed, holding that the negotiated discounts were "payments made pursuant to the United States Social Security Act" under section 548.251, subd. 1(2), and therefore, Appellants could not offset the damages award for those payments. View "Getz v. Peace" on Justia Law

The Supreme Court affirmed the order of the district court directing the City of Saint Paul to put a referendum question regarding the City's ordinance that established organized waste collection in the City on the ballot for the next municipal election, concluding that holding a referendum on the issue will not unconstitutionally impair the City's contract with haulers that provide organized waste collection.The City refused to put the referendum question on the ballot, concluding that the referendum was preempted by state statutes that govern solid waste collection, conflicts with state policy, and would by an unconstitutional interference with the City's contract with the haulers. Respondents with filed a petition challenging the City's refusal. The district court granted the petition. The Supreme Court affirmed, holding that the City has not demonstrated that a substantial impairment of its contractual obligation will occur with the referendum vote, and therefore, the Court need not address the other two factors. View "Clark v. City of Saint Paul" on Justia Law