Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief, holding that the district court did not err in denying the petition without holding an evidentiary hearing.Defendant was convicted of first-degree murder as an accomplice. The Supreme Court affirmed on direct appeal. Thereafter, Defendant filed the present petition for postconviction relief, alleging several claims of error. The district court denied the petition without a hearing, reasoning that Defendant's arguments were either procedurally barred or lacked merit. The Supreme Court affirmed, holding that Defendant's claims were either procedurally barred or failed on the merits. View "Onyelobi v. State" on Justia Law

The Supreme Court reversed the determination of the Commissioner of Human Services that Appellant committed maltreatment under the Maltreatment of Minors Act, Minn. Stat. 626.556, subd. 2(g), when a three-year-old child wandered away from Appellant's daycare, holding that the Commissioner misinterpreted the Act and failed to make necessary findings.After an investigation, Wright County determined that Appellant was responsible for maltreatment when the child was found .3 miles from the daycare facility unattended but uninjured. The Commissioner affirmed the determination. The court of appeals affirmed. The Supreme Court reversed, holding that the Commissioner erred by misinterpreting the statute and that the Commissioner failed to make a factual determination on the length of Appellant's absence as explicitly called for by the Act. View "In re Maltreatment Determination of Amanda Restorff" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's complaint alleging two counts under the Minnesota Consumer Fraud Act, Minn. Stat. 325F.69, holding that a person who is targeted by a fraudulent demand and consequently pays an attorney to investigate his liability in response to that demand has been "injured" within the meaning of the private attorney general statute, Minn. Stat. 8.31, subd. 3a.Plaintiff alleged that Defendant engaged in a practice of fraud by sending unlawful demand letters and that he suffered an injury by having to hire an attorney to respond to Defendant's fraudulent demands. The district court dismissed the counts based on violations of the Consumer Fraud Act for failure to state a claim. The court of appeals affirmed, concluding that Plaintiff failed to sufficiently plead that he was injured by Defendant's purported violation of the Act. The Supreme Court reversed, holding that Defendant's alleged violations of the Act caused him a pecuniary loss in the form of hiring an attorney to investigate and resolve the fraud, and therefore, Plaintiff alleged an injury sufficient to plead a cause of action under the private attorney general statute. View "Engstrom v. Whitebirch, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction for third-degree murder, holding that the third-degree murder statute, Minn. Stat. 609.195(a), does not require the State to prove beyond a reasonable doubt that the defendant lacked an "intent to effect the death of any person."On appeal, Defendant argued that there was insufficient evidence to support her conviction because the State failed to prove beyond a reasonable doubt that she lacked an intent to effect the death of any person because, an an apparent suicide attempt, her driving conduct showed an intent to effect the death of herself. The court of appeals agreed and reversed Defendant's conviction. The Supreme Court reversed after applying the State v. Stokely, 16 Minn. 282 (1871), line of precedent, holding that the "without intent to effect the death of any person" clause of the third-degree murder statute does not require the State to prove beyond a reasonable doubt that the defendant lacked an "intent to effect the death of any person." View "State v. Hall" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the tax court reaching a valuation for KCP Hastings, LLC's shopping mall, holding that the tax court erred in the assignment of value to an outlot on the property and erred when it used a gross building area other than the one stipulated to by the parties and otherwise did not err.The Supreme Court previously remanded this case to the tax court after concluding that the tax court's valuation of KCP's properly was not reasonably supported by the record. On remand, the tax court reached a new valuation for KCP's property. The Supreme Court affirmed in part and reversed in part, holding (1) the tax court clearly erred in assigning value to a portion of the mall's parking lot on the basis that the outlot could be sold and developed; (2) the tax court erred by using a different gross building area than the one stipulated to by the parties; and (3) the remainder of the tax court's determinations were not erroneous. View "KCP Hastings, LLC v. County of Dakota" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) affirming a compensation judge's judgment finding that Alapati Noga, a former defensive lineman for the Minnesota Vikings, who now suffers from dementia, was entitled to permanent and total disability benefits, holding that Noga did not satisfy the statute of limitations under Minn. Stat. 176.151.Noga played as a defensive lineman for the Vikings from 1988 until 1992. While playing for the Vikings, Noga experienced head injuries and headaches. In 2015, Noga filed a claim petition for workers' compensation benefits. A compensation judge found that Noga sustained a Gillette injury of "head trauma, brain injury, and/or dementia" that culminated on or about December 1, 1992 and that the injury was a substantial contributing factor to Noga's permanent and total disability.The WCCA vacated certain findings and remanded several issues. On remand, the compensation judge resolved those issues in Noga's favor, determining, among other things, that the statute of limitations was satisfied under Minn. Stat. 176.151 because the Vikings provided Noga with medical care that constituted a "proceeding." The WCCA affirmed. The Supreme Court reversed, holding that the Vikings' provision of care for Noga's head injuries did not constitute a proceeding that prospectively satisfied the statute of limitations. View "Noga v. Minnesota Vikings Football Club" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's exercise of specific personal jurisdiction over Ford Motor Company in this products liability case, holding that the claims in this case arose out of or related to Ford's contacts with Minnesota, and therefore, the exercise of specific personal jurisdiction by the Minnesota court was proper.A Ford vehicle owned by a Minnesota resident was involved in a car crash in which an airbag in the vehicle failed to deploy and a passenger was seriously injured. Ford moved to dismiss the passenger's claims for lack of personal jurisdiction, arguing that because the car involved in the accident was not designed, manufactured, or originally sold in Minnesota, Ford could not be subject to personal jurisdiction in Minnesota. The district court held that the exercise of jurisdiction over Ford was proper, and the court of appeals affirmed. The Supreme Court affirmed, holding that Ford's contacts with Minnesota were sufficient to support specific personal jurisdiction and that the reasonableness factors did not detract from the reasonableness of asserting jurisdiction over Ford in this case. View "Bandemer v. Ford Motor Co." on Justia Law

The Supreme Court affirmed the decision of the Minnesota Tax Court holding that the Minnesota Legislature incorporated the federal "minimum base amount" limitation into Minnesota's research and development (R&D) tax credit statute, Minn. Stat. 290.068, and that for the 2011 tax year, the term "aggregate gross recipes" referred to federal aggregate gross receipts, not Minnesota aggregate gross receipts, holding that the tax court's conclusions were without error.Specifically, the Court held (1) to calculate Minnesota's R&D tax credit, Minnesota incorporates the "minimum base amount" limitation set forth in I.R.C. 41(c)(2); and (2) the plain language of Minn. Stat. 290.068, subd. 2(c) and its incorporation of the term "aggregate gross receipts" through the term "base amount" referred to federal aggregate gross receipts for the 2011 tax year, and therefore, the tax court did not err in concluding that federal aggregate gross receipts must be used in the fixed-base-percentage formula contained with the base amount calculation for General Mills, Inc.'s 2011 Minnesota R&D tax credit. View "General Mills, Inc. v. Commissioner of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the district court construing Defendant's motion to correct his sentence as a motion for postconviction relief and summarily denying postconviction relief without holding an evidentiary hearing, holding that the court did not err in treating Defendant's motion as a petition for postconviction relief and in summarily denying the petition.Defendant was found guilty of first-degree premeditated murder and second-degree murder. Defendant later filed a motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9. The district court construed the motion as a petition for postconviction relief under Minn. Stat. 590.01, determining that the motion fell outside the scope of Rule 27.03 because it implicated more than just his sentence. The court then summarily denied the petition because the petition was untimely. The Supreme Court affirmed, holding (1) the district court did not err in considering Defendant's motion to correct his sentence as a petition for postconviction relief; and (2) the district court did not abuse its discretion in summarily denying Defendant's request for postconviction relief because, even if the facts alleged in the petition were true, they were legally insufficient to entitle him to the requested relief. View "Rossberg v. State" on Justia Law

The Supreme Court affirmed the decision of the tax court holding that the Minnesota Legislature incorporated the federal "minimum base amount" limitation into Minnesota's research and development (R&D) tax credit statute, Minn. Stat. 290.068, and that for the 2011 tax year the term "aggregate gross receipts" referred to federal aggregate gross receipts, not Minnesota aggregate gross receipts, holding that the reasoning from the Court's opinion in General Mills v. Commissioner of Revenue, __ N.W.2d __, filed today, governed this case as well.At issue was whether the Legislature's incorporation of the federal tax code's definition of the term "base amount" in the tax credit statute includes the federal "minimum base amount" limitation and whether the term "aggregate gross receipts" as used in the Internal Revenue Code formula for calculating the R&D credit refers to Minnesota or federal aggregate gross receipts. The Supreme Court affirmed the tax court's decision, holding (1) to calculate the Minnesota R&D tax credit, section 290.068, subd. 2(c) incorporates the "minimum base amount" limitation contained within I.R.C. 41(c)(2); and (2) the plain language of section 290.068, subd. 2(c) and its incorporation of the term "aggregate gross recipes" through the term "base amount" referred to federal aggregate gross receipts for the 2011 tax year. View "International Business Machines Corp. v. Commissioner of Revenue" on Justia Law