Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting summary judgment to the City of Brainerd after the City restructured its fire department and eliminated all of its union positions, holding that the City engaged in an unfair labor practice prohibited by Minn. Stat. 179A.13, subd. 2(2).Firefighters Union Local 4725 and the union president sued the City under the Public Employment Labor Relations Act (PELRA), Minn. Stat. 197A.01-.25, alleging that in eliminating the union positions, the City engaged in unfair labor practices prohibited by PELRA. The district court granted summary judgment for the City. The court of appeals reversed, ruling that the City violated section 179A.13, subd. 2(2) by undergoing a department reorganization that resulted in the dissolution of a bargaining unit. The Supreme Court affirmed, holding that the City's interference with the existence of an employee organization constituted a prohibited unfair labor practice. View "Firefighters Union Local 4725 v. City of Brainerd" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's decision awarding Mother and Father joint physical custody and equal parenting time, holding that the district court did not misapply the domestic-abuse presumption or the friendly-parent factor and appropriately exercised its discretion in analyzing the best interests factors.After a trial, the family court referee found that Mother had committed domestic abuse against Father. However, the referee found that best interest of the parties' child required that the parties be awarded joint physical custody and equal parenting time and that the statutory presumption against joint legal custody was not rebutted, thus awarding sole legal custody to Mother. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not misapply the rebuttable presumption against awarding joint custody when domestic violence has occurred between parents; (2) did not misapply the friendly-parent factor in its best-interests analysis; and (3) did not abuse its discretion in concluding that the child was best served by a joint physical custodial arrangement. View "Thornton v. Bosquez" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the district court's decision denying Defendant's petition for postconviction relief asserting the invalidity of a test-refusal conviction under Birchfield v. North Dakota, 579 U.S. ___ (2016), and Johnson v. State, 916 N.W.2d 674 (Minn. 2018), holding that the district court properly placed the burden of proof on Defendant instead of the State.Birchfield announced the rule that, in the absence of a warrant or an exception to the warrant requirement, refusal to submit to a blood or urine test cannot be criminalized. Johnson made the rule retroactive. The district court denied Defendant's request for postconviction relief, concluding that he failed to prove there was no applicable exception to the warrant requirement. The court of appeals reversed, holding that the district court erred by placing the burden of proof on Defendant instead of the State. The Supreme Court reversed and announced a heightened pleading standard for Birchfield/Johnson postconviction proceedings, holding that the district court properly placed the burden of proof on Defendant. View "Fagin v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court's dismissal of Appellants' complaint against U.S. Bank on statute of limitations grounds, holding that Appellants' breach of fiduciary duty claim was timely.On January 24, 2017, Appellants filed their lawsuit, alleging breach of fiduciary duty and unjust enrichment. U.S. Bank moved to dismiss the claim, arguing that Appellants failed to satisfy the applicable six-year statute of limitations. In response, Appellants asserted that they had suffered no damages earlier than August 2012. The district court granted the motion to dismiss, concluding that Appellants could have raised their claims in April 2010. The court of appeals affirmed, concluding that "some damage" occurred on April 27, 2010. The Supreme Court reversed, holding that U.S. Bank failed to establish - based on the pleadings - that Appellants suffered "some damage" in the form of financial harm before August 2012, and therefore, the district court erred by granting the motion to dismiss. View "Hansen v. U.S. Bank National Ass'n" on Justia Law

The Supreme Court reversed the court of appeals' decision reversing the order of the Commissioner of the Department of Labor and Industry for Baywood Home Care to pay unpaid overtime wages and liquidated damages, holding that the court erred in determining that the Commissioner's conclusion that split-day plans are not permitted under the Minnesota Fair Labor Standards Act, Minn. Stat. 177.21-.35, was based on an unpromulgated rule.Baywood paid its employees using a split-day plan even after an employee had worked forty-eight hours in a workweek. The Commissioner issued compliance order ordering Baywood to cease and desist from failing to pay overtime. The court of appeals reversed. The Supreme Court reversed, holding (1) the Act requires employers to pay employees at least time-and-a-half wages for all hours worked in the first forty-eight hours of a given workweek, regardless of whether the employee received time-and-a-half compensation during the first forty-eight hours of employment in that workweek; (2) time-and-a-half payments for regularly scheduled work occurring before an employee has worked forty-eight hours in a workweek may not be excluded from an employee's remuneration to calculate the employee's regular rate; and (3) the Commissioner's failure to promulgate interpretive rules meant that the Department's interpretation did not receive deference, but the Court nevertheless adopted that interpretation. View "In re Minnesota Living Assistance, Inc." on Justia Law