Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals ruling that James Bergman was not disqualified from receiving a permit to carry a firearm, holding that the sealing of judicial records under a court's inherent authority does not satisfy the federal requirement of expungement.In 2007, a Minnesota district court issued an expungement order under its inherent authority sealing the judicial records of Bergman's prior conviction of domestic assault. Thereafter, Bergman applied for a permit to carry a firearm. Bergman was granted the permit. In 2017, the Isanti County Sheriff denied Bergman's permit-to-carry application because of his prior domestic assault conviction. The district court denied Bergman's petition for a writ of mandamus. The court of appeals reversed. The Supreme Court reversed, holding that the sealing of judicial records under a district court's inherent authority is not sufficient under federal law to expunge a previous conviction and thereby reinstate an applicant's right to carry a firearm in Minnesota. View "Bergman v. Caulk" on Justia Law

The Supreme Court affirmed the decision of the tax court reducing Hennepin County's valuation of a Lowe's store in Plymouth, Minnesota for the 2015 tax year, holding that the tax court did not inflate the property's fair market value and did not violate Lowe's due process rights.Lowe's petitioned the tax court asserting that Hennepin County's assessment for the 2015 tax year overstated the fair market value of the property. The tax court agreed and reduced the County's valuation. The Supreme Court affirmed, holding (1) the tax court did not violate Lowe's due process rights by failing to rely on evidence in the record in reaching its conclusions; and (2) because the record supported the tax court's decision to place greater weight on the cost approach rather than on the sales approach and its adjustments under both approaches, the tax court did not violate Lowe's due process rights. View "Lowe's Home Centers, LLC (Plymouth) v. County of Hennepin" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the conclusion of the district court that Mother had to notify her three children's biological father of her request to change the children's names, holding that where Mother was the only parent listed on her children's birth certificates and no one had been adjudicated as their father, Mother was the legal parent with authority to apply to change her children's names.At issue was the notice provision found in Minn. Stat. 259.10 relating to name-change applications on behalf of minors. The district court determined that the biological father had a legally recognized parent-child relationship with the eldest two children and was therefore entitled to notice of the name-change petitions. The court of appeals affirmed. The Supreme Court reversed, holding that because Mother was the only legal parent of her three minor children the district court erred when it determined that the biological father was a "parent" under section 259.10. View "In re Application of J.M.M." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's conclusion that the Minnesota Fair Labor Standards Act (the MFLSA) does not preempt the ordinance enacted by the City of Minneapolis that requires employers to pay minimum-wage rates that are higher than the rates set forth in the MFLSA, holding that district court correctly ruled that the MFLSA does not preempt the ordinance.The MFLSA establishes the minimum wage Minnesota employers must pay their employees. At issue was whether the City's ordinance requiring employers to pay minimum-wage rates higher than the rates set forth in the MFLSA was preempted by the MFLSA. The district court determined that state law does not preempt the ordinance because the MFLSA sets a floor, not a ceiling, for minimum-wage rates. The Supreme Court affirmed, holding (1) the MFLSA sets a floor, which does not prohibit, but instead permits, employers to pay the higher wage the ordinance requires; and (2) the Legislature did not intend to occupy the field of minimum-wage rates through the MFLSA. View "Graco, Inc. v. City of Minneapolis" on Justia Law