Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the judgment of the compensation judge dismissing Petitioner's claim petition seeking workers' compensation benefits for post-traumatic stress disorder (PTSD), which Petitioner claimed resulted from numerous traumatic incidents that he experienced while working, holding that the WCCA erred.At issue on appeal was the correct interpretation of Minn. Stat. 176.011, subs.15(d), which requires an employee seeking workers' compensation benefits where the alleged injury is PTSD arising out of employment to prove that the employee has been diagnosed with PTSD by a licensed psychologist or psychiatrist using the latest version of the Diagnostic and Statistical Manual of Mental Disorders (DSM) in making a diagnosis. The Supreme Court held (1) Minn. Stat. 176.011, subs.15(d) does not require a compensation judge to conduct an independent assessment to verify that the diagnosis of the psychologist or psychiatrist conforms to the PTSD criteria set forth in the DSM before accepting the expert's diagnosis; and (2) the WCCA erred by overriding the compensation judge's choice between two competing medical experts because the expert opinion adopted by the compensation judge had an adequate factual foundation for the diagnosis. View "Smith v. Carver County" on Justia Law

The Supreme Court affirmed the decision of the tax court dismissing petitions filed by Wal-Mart Real Estate Business Trust (the Trust) challenging Anoka County's assessment of the Trust's three parcels of land in the county, holding that the tax court properly found that the properties were "income-producing" and that the Trust's disclosures were inadequate.Each parcel at issue in this case had a Walmart retail store, operated by Walmart, Inc. The Trust was a wholly-owned subsidiary of Walmart. The tax court dismissed the Trust's petitions challenging the Trust's assessment of the parcels because the Trust failed to disclose certain information before the deadline set forth in Minn. Stat. 278.05, subd. 6(a). The Trust appealed, arguing that it was not subject to the mandatory disclosure rule because Walmart stores are not "income-producing" within the meaning of the tax statute's mandatory-disclosure provision. The Supreme Court affirmed, holding that the properties were income-producing and that the Trust's disclosures were inadequate. View "Wal-Mart Real Estate Business Trust v. County of Anoka" on Justia Law

The Supreme Court affirmed the decision of the tax court affirming the conclusion of the Commissioner of Revenue that the sales tax exemption in Minn. Stat. 297A.68, subd. 5 for the purchase of capital equipment did not apply to items that Kroll Ontrack, LLC purchased.Kroll - a Minnesota LLC that sold technology-driven services to government entities, law firms, and corporate law departments - provided two internet-based programs that allowed its customers to maintain private databases of litigation documents and to sort, search, and produce relevant documents from those databases. From March 1, 2011 to November 30, 2012 Kroll purchased machinery and equipment needed to run its computer system and paid Minnesota sales tax on its purchases. In 2014, Kroll filed two requests for a refund of the sales tax it paid on the machinery and equipment, asserting that these items qualified as exempt capital equipment. The Commissioner of Revenue denied the refund claim. The tax court affirmed. The Supreme Court affirmed, holding that Kroll's system did not qualify for the capital equipment exemption in Minn. Stat. 297A.68, subd. 5. View "Kroll Ontrack, LLC v. Commissioner of Revenue" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the district court ordering Defendant to pay restitution for destruction of a cabin after a jury found him guilty of burglary but did not reach a verdict on an arson charge, holding that the court of appeals erred by applying an incorrect standard.Defendant was charged with second-degree burglary and first-degree arson for the destruction of a cabin in Minnesota that was burglarized and then set on fire. The jury found Defendant guilty of burglary but could not reach a verdict on the arson charge. The State declined to retry Defendant for arson, but, after determining that the arson was factually related to the burglary, ordered Defendant to pay restitution for the fire-damaged cabin. The court of appeals affirmed, concluding that the burglary and the fire were sufficiently "factually intertwined" to allow restitution. The Supreme Court reversed, holding that the court of appeals erred by applying a factual-relationship standard rather than a direct-causation standard when considering whether fire damage to the cabin was a result of Defendant's offense. View "State v. Boettcher" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court suppressing the results of Defendant's blood test, holding that the limited right to counsel established in Friedman v. Commissioner of Public Safety, 473 N.W.2d 828 (Minn. 1991), does not apply when an individual is asked to submit to a blood test pursuant to a warrant.After Defendant was arrested for driving while impaired, the police officer obtained a search warrant to take a sample of her blood for alcohol concentration testing. The officer read Defendant the implied-consent advisory for blood and urine tests, and Defendant allowed her blood to be drawn. Defendant moved to have the results of her blood test suppressed, arguing that, under Friedman, she had a limited constitutional right to consult with counsel before deciding whether to submit to a blood test. The district court agreed. The Supreme Court disagreed, holding that the limited right to counsel under the Minnesota Constitution recognized in Friedman does not apply when a driver is presented with the choice to submit to a blood test pursuant to a search warrant. View "State v. Rosenbush" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court summarily denying Defendant's petition for postconviction relief arguing that counsel provided ineffective assistance and that an expert witness for the State provided unreliable testimony at trial, holding that the postconviction court did not err.Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed Defendant's conviction on direct appeal. Defendant later filed a petition for postconviction relief, which the postconviction court summarily denied. The Supreme Court affirmed, holding that Defendant's claims were either meritless or time-barred. View "Odell v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of aiding and abetting first-degree murder, holding that any error in the proceedings below was harmless.Specifically, the Court held (1) the district court's admission of Spreigl evidence of three other-crimes incidents was not an abuse of discretion; (2) the testimony of Defendant's accomplice was sufficiently corroborated; (3) the district court did not abuse its discretion when it twice denied Defendant's motion for a continuance to review newly produced evidence; (4) the district court abused its discretion when it sustained a relevance objection to a question during the cross examination of a police investigator, but the error was harmless; and (5) Defendant's pro se claims were without merit. View "State v. Smith" on Justia Law

In this case filed by a bus driver who sought reimbursement for chiropractic services related to her work-related injury the Supreme Court affirmed the decision of the court of appeals to reinstate Plaintiff's arbitration award after the district court vacated the award, holding that a provision in the Minnesota Workers' Compensation Act, Minn. Stat. 176.83, subd. 5(c), did not bar coverage.Plaintiff's employer's workers' compensation carrier agreed to pay workers' compensation benefits to Plaintiff but refused to pay for more than twelve weeks of chiropractic care in accordance with the treatment parameters adopted for purposes of the Act. In accordance with that decision, Plaintiff's first chiropractor stopped treatment after twelve weeks of providing care. Plaintiff then received additional care from a different chiropractor. It was for this care that Plaintiff sought reimbursement from State Farm, her personal automobile no-fault insurer. State Farm denied coverage. An arbitrator ruled in favor of Plaintiff and awarded her the full amount she sought. The district court vacated the arbitrator's award, and the court of appeals reversed. The Supreme Court affirmed, holding that the statutory prohibition on reimbursement in section 176.83, subd. 5(c) is limited to the first provider whose services the workers' compensation payer determined to be excessive. View "Rodriguez v. State Farm Mutual Automobile Insurance Co." on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the decision of the district court granting summary judgment to Appellants - Someplace Safe, Inc. an advocacy organization, and Jacquelyn Jorud, Respondent's former wife - in this defamation and negligence action, holding that summary judgment was properly awarded to Someplace Safe on negligence but that the question of damages required a remand.Respondent alleged that Appellants' statements accused him of committing domestic violence. The district court granted summary judgment to Appellants on the defamation claims, concluding that the statements were protected by a qualified privilege, Respondent failed to establish a genuine issue of material face on malice, and Respondent had not shown proof of actual damages. The court of appeals reversed, concluding that Respondent provided sufficient evidence of damages and breach of duty to warrant a trial on his claims. The Supreme Court held (1) Respondent's defamation claim against Jorud must be remanded to determine whether the allegedly defamatory statements involved a matter of public or private concern; and (2) no material fact questions existed about whether Someplace Safe acted with reasonable care before publishing the allegedly defamatory statements. View "Maethner v. Someplace Safe, Inc." on Justia Law

The Supreme Court affirmed the decision of the postconviction court denying Appellant's petition for postconviction relief without holding an evidentiary hearing, holding that the petition was untimely.Defendant was convicted of first-degree premeditated murder. The conviction was affirmed on appeal. After unsuccessfully filing a petition for postconviction relief Defendant filed this instant petition for postconviction relief alleging several claims of ineffective assistance of counsel during his trial and direct appeal. The postconviction court denied the claims without an evidentiary hearing, ruling that Defendant's claims were time-barred under the two-year statute of limitations. The Supreme Court affirmed, holding that the petition was properly denied because it was filed more than two years after the disposition of Appellant's direct appeal and because the facts alleged in the petition would not have satisfied any exception to the applicable statute of limitations. View "Jackson v. State" on Justia Law