Justia Minnesota Supreme Court Opinion Summaries

The case involves Nicholas Sterry, an inmate at the Moose Lake Correctional Facility, who filed a lawsuit against the Minnesota Department of Corrections (DOC) and Correctional Officer Ashley Youngberg. Sterry alleged that Youngberg sexually assaulted and harassed him while he was working in the prison kitchen. The DOC was aware of Youngberg's history of harassment but had not disciplined her prior to the incidents involving Sterry. Sterry's lawsuit included claims of battery, intentional and negligent infliction of emotional distress, and negligence under a theory of vicarious liability.The district court dismissed Sterry's claims, concluding that the DOC was immune from the suit under the Minnesota State Tort Claims Act because Youngberg was not acting within the scope of her employment when the alleged assault occurred. Sterry appealed this decision, and the court of appeals reversed the district court's ruling. The court of appeals found that Sterry's complaint alleged sufficient facts to survive the motion to dismiss, as it was consistent with common law principles of vicarious liability applicable to private employers.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court held that a state employer could be held vicariously liable for an employee’s intentional tort under the Minnesota State Tort Claims Act if the tort is related to the duties of the employee and occurs within work-related limits of time and place. The court also found that Sterry's complaint alleged sufficient facts to survive the DOC's motion to dismiss. The court concluded that Sterry's claim could allow a jury to find that Youngberg was acting within the scope of her employment when the alleged assault occurred, under circumstances where the DOC would be liable under common law for vicarious liability. View "Sterry v. Minnesota Department of Corrections" on Justia Law

The case revolves around a dispute over attorney fees awarded under Minnesota Statutes section 117.031(a) in an eminent domain proceeding. The State of Minnesota, through the Department of Transportation (MnDOT), seized a portion of Joseph Hamlin's property under the "quick take" provision of Minnesota eminent domain law. Hamlin was awarded attorney fees after the compensation he received was more than 40% greater than MnDOT's final offer. The attorney fees awarded exceeded the amount Hamlin owed his attorney under a contingent fee agreement.MnDOT appealed the district court's decision, arguing that the term "reasonable" in section 117.031(a) should limit the attorney fee award to the amount owed in the contingent fee agreement. The district court had applied the lodestar method (a method for calculating attorney fees based on the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate) and awarded Hamlin $63,228 in attorney fees. The court of appeals affirmed the district court's decision, holding that "reasonable attorney fees" in section 117.031(a) are calculated under the lodestar method and are not limited by any existing agreement between the landowner and his attorney.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court reiterated its previous holding in County of Dakota v. Cameron that "reasonable attorney fees" in section 117.031(a) refers to attorney fees calculated by the lodestar method. Therefore, an award of reasonable attorney fees is not capped by a contingent fee agreement. The court concluded that a landowner's fee agreement with their attorney does not limit an award of attorney fees because "reasonable attorney fees" under section 117.031(a) means attorney fees calculated using the lodestar method. View "State v. Schaffer" on Justia Law

The case revolves around the appellant, McKinley Juner Phillips, who was convicted of first-degree premeditated murder and second-degree intentional murder for the stabbing death of his wife, Shavon Phillips. The appellant had conceded at trial that he caused the death of his wife but had requested that the jury be given instructions for first-degree heat-of-passion manslaughter in addition to the instructions for first-degree premeditated murder and second-degree intentional murder. The district court denied the requested instruction, reasoning that the evidence did not support a heat-of-passion instruction.The appellant appealed the district court's decision, arguing that the court committed reversible error by denying the requested instruction. The appellant's argument was based on the premise that the jury's finding of premeditation does not necessarily preclude a finding of heat-of-passion.The Minnesota Supreme Court, however, affirmed the district court's decision. The Supreme Court held that the appellant was not prejudiced by the district court’s decision not to instruct the jury on first-degree heat-of-passion manslaughter because the court gave instructions on both first-degree premeditated murder and second-degree intentional murder and the jury found the appellant guilty of first-degree premeditated murder. The court reasoned that the mental states of premeditation and heat of passion cannot coexist, and since the jury found the appellant guilty of premeditated murder, it would not have found him guilty of heat-of-passion manslaughter. View "Phillips v. State" on Justia Law

The case revolves around Tokvan Ly, a man suffering from severe mental illness, who was incarcerated in the Scott County Jail. The district court found Ly incompetent to face criminal proceedings and ordered him committed to the care of the appellant, Jodi Harpstead, the Commissioner of Human Services. The law requires that persons in Ly's position be prioritized for admission to state-operated treatment programs and be admitted within 48 hours. However, Ly was not admitted within this timeframe. Fifteen days after his commitment, Ly remained in jail and was not receiving the specialized treatment needed for his severe mental illness. Consequently, he filed a petition for writs of mandamus and habeas corpus, alleging that the Commissioner was failing to comply with a mandatory duty to admit him to treatment within 48 hours under the Priority Admission statute and seeking damages resulting from his delayed admission to treatment.The district court issued a peremptory writ of mandamus that determined the Commissioner’s liability solely on the facts as alleged in Ly’s petition, and set the issue of mandamus damages for a fact trial. The Commissioner appealed the district court’s order, contending that she could immediately appeal the order before entry of final judgment. The court of appeals disagreed and dismissed the appeal for lack of jurisdiction.The Minnesota Supreme Court concluded that the basis for appeal from an order issuing a peremptory writ of mandamus under Rule 103.03(g) has been extinguished, and that appeal must instead proceed from a final judgment under Minn. R. Civ. App. P. 103.03(a). The court further concluded that an order issuing a peremptory writ is not appealable under Rule 103.03(a) as a form of irregular judgment, and that the district court order currently on appeal does not satisfy the finality requirement of that rule. However, the court invoked its inherent authority and its authority under Minn. R. Civ. App. P. 102 to suspend the final judgment requirement of Rule 103.03(a), reverse the decision of the court of appeals, exercise jurisdiction over the Commissioner’s underlying appeal, and remand to the court of appeals to consider the merits of the appeal. View "Ly v. Harpstead" on Justia Law

The case involves Angel Ignacio Sardina-Padilla, who was convicted of first-degree premeditated murder for the death of Jose Genis Cuate. Sardina-Padilla appealed the conviction, arguing that the district court erred in denying his motion to suppress evidence obtained from a warrant to search his Facebook accounts. He claimed that the warrant application failed to establish probable cause and did not satisfy minimal constitutional requirements for particularity. He also argued that the district court abused its discretion by summarily denying his petition for postconviction relief, which alleged ineffective assistance of counsel.The district court had denied Sardina-Padilla's motion to suppress the evidence obtained from the June warrant, concluding that the totality of the circumstances described in the June warrant application suggested that the accounts likely contained relevant evidence. The court also concluded that the June warrant satisfied minimal constitutional requirements for particularity.On appeal, the Supreme Court of Minnesota affirmed the district court's decision. The court found that the district court did not err in finding that the warrant application alleged that Sardina-Padilla asked someone to delete his Facebook account during a jail call. The court also concluded that the June warrant was sufficiently particular, considering the circumstances of the case, the nature of the crimes under investigation, and whether the officers could have provided a more precise description of the evidence sought. Finally, the court concluded that there was no reasonable probability that the trial’s outcome would have been different if counsel had successfully challenged the tracking data, and therefore, the district court did not abuse its discretion by summarily denying Sardina-Padilla’s petition for postconviction relief. View "State v. Sardina-Padilla" on Justia Law

The case revolves around the petitioner, Ryan Binkley, who sought to have his name included on the Republican Party of Minnesota's ballot for the 2024 presidential nomination primary. However, the Chair of the Republican Party of Minnesota did not include Binkley as a candidate when notifying the Minnesota Secretary of State, Steve Simon, of the candidates for its ballot. Consequently, Binkley and his campaign committee filed a petition with the court, arguing that the procedures established by Minnesota Statutes section 207A.13, subdivision 2(a), which allow a major political party to determine the candidates that will appear on its ballot for the presidential nomination primary, violate the Electors Clause of the United States Constitution.The case was brought before the Minnesota Supreme Court after the petitioners' claim was denied in the lower court. The petitioners argued that the Electors Clause prohibits state-based favoritism on ballots through the exclusion of qualified candidates. The Secretary of State, however, contended that the presidential nomination primary is not subject to the Electors Clause because Minnesota does not use the presidential nomination primary to appoint presidential electors.The Minnesota Supreme Court agreed with the Secretary of State, ruling that the presidential nomination primary is not part of the process that Minnesota uses to appoint presidential electors. Therefore, the statutes that govern the presidential nomination primary do not fall within the scope of the Electors Clause. The court concluded that the petitioners' claim that section 207A.13, subdivision 2(a) violates the Electors Clause fails as a matter of law. The petition was thus denied. View "J. Binkley for President 2024 vs. Simon" on Justia Law

The defendant, Sylvester Jones, was charged with third-degree criminal sexual conduct, using force to accomplish sexual penetration. After initially pleading not guilty, Jones later entered a guilty plea to the third-degree criminal sexual conduct charge in return for dismissal of other charges. However, during the plea hearing, Jones made a statement on record denying that he had committed the offense. Despite this, the judge found Jones’s factual basis sufficient to support his guilty plea, accepted it, and adjudged Jones guilty. Jones did not request withdrawal of his guilty plea at the continued sentencing hearing, and the district court sentenced Jones to 153 months in prison.On appeal, Jones argued that his unaddressed assertion of innocence made the factual basis for his guilty plea inaccurate. The court of appeals affirmed the lower court's decision, reasoning that Jones’s assertion of innocence during the plea hearing did not invalidate his plea because after he made the assertion, Jones admitted to the factual basis for the guilty plea through affirmative responses to defense counsel’s leading questions.The Minnesota Supreme Court disagreed with the lower courts. The court found that Jones’s guilty plea was inaccurate because he made a statement at the plea hearing that negated at least one element of the charged offense, and his guilty plea was not sufficiently rehabilitated because defense counsel subsequently used solely leading questions to elicit the necessary admissions for the factual basis. The court concluded that Jones is entitled to withdraw his plea to correct a manifest injustice under Minn. R. Crim. P. 15.05, subd. 1. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "State of Minnesota vs. Jones" on Justia Law

The case involves a dispute over two years of Minnesota individual tax returns filed by Christopher and Nancy Wendell, residents of Wisconsin. In 2019 and 2020, the Wendells filed joint tax returns reporting no Minnesota taxable income, despite receiving over $1 million in payments from Minnesota sources. The Wendells claimed that the payments were not taxable wages or ordinary business income. The Commissioner of Revenue disagreed, modified the Wendells’ reported income, assessed additional income tax, and imposed a 25 percent penalty for filing a frivolous tax return. The Wendells appealed the Commissioner’s assessment, and the Minnesota Tax Court granted summary judgment in the Commissioner’s favor.The Minnesota Tax Court found that the Wendells’ tax liability was correctly calculated and adjusted, that no material facts were in dispute, and that the frivolous return penalty statute was constitutional. The Wendells then appealed to the Minnesota Supreme Court.The Minnesota Supreme Court affirmed the decision of the tax court. The court held that the Commissioner of Revenue had the authority to adjust the Wendells’ reported federal adjusted gross income, the tax court did not err in granting summary judgment in favor of the Commissioner, and the statutory penalty for filing a frivolous return is constitutional. The court rejected the Wendells' arguments that the penalty for filing a frivolous tax return was unconstitutional under the Due Process Clauses and Excessive Fines Clauses of the United States Constitution and Minnesota Constitution or the Equal Protection Clause of the United States Constitution. View "Wendell vs. Commissioner of Revenue" on Justia Law

The case involves an employee, Daniel Johnson, who had previously injured his back in 2005 while working for Furniture & Things, Inc. He continued to work for the company until 2011, managing his persistent back and leg pain with self-care treatments. In 2016, Johnson started working for Concrete Treatments, Inc., where he sustained another back injury in October 2018. He sought medical treatment for his worsening condition, which was diagnosed as a lumbar strain. In 2021, Johnson underwent surgery for severe spinal canal stenosis. He filed a workers’ compensation claim, seeking benefits for his 2005 and 2018 injuries and payment of outstanding medical expenses.The compensation judge found that Johnson had sustained a permanent work-related injury in October 2018 and that both the 2005 and 2018 injuries were substantial contributing factors to his need for medical care and surgery. The judge also concluded that Johnson was entitled to make a direct claim for unpaid medical expenses owed to his medical providers, who had not intervened in the proceedings. Concrete Treatments appealed the judge's findings on liability and conclusion regarding Johnson’s right to assert a direct claim for unpaid medical expenses.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge’s determination that Johnson sustained a permanent work-related injury in October 2018 and that the injury was a substantial contributing factor to his permanent low back condition and need for surgery. However, the WCCA held that Johnson could not assert a direct claim for unpaid medical expenses because his medical providers had not intervened in the proceedings.The Supreme Court of Minnesota affirmed in part and reversed in part the WCCA’s decision. The court held that Johnson is entitled to assert a direct claim for unpaid medical expenses and that the compensation judge’s findings regarding the October 2018 injury are not manifestly contrary to the evidence. The case was remanded to the WCCA to determine whether further factual findings are necessary regarding Johnson’s direct claim for unpaid medical expenses. View "Johnson vs. Concrete Treatments" on Justia Law

The case revolves around the legality of the Emergency Management Act (the Act) in Minnesota, which allows the Governor to declare a peacetime emergency in response to a pandemic. The appellants, led by Drake Snell, challenged the Act, arguing that it did not authorize the Governor to declare a peacetime emergency in response to the COVID-19 pandemic and that it violated the nondelegation doctrine.Previously, the district court had dismissed Snell's case, concluding that the Act was a constitutional delegation of power to the Governor. The court of appeals affirmed this decision, stating that the Act granted the Governor the authority to declare a peacetime emergency in response to the COVID-19 pandemic. The court of appeals declined to consider Snell's argument that the Act violated the nondelegation doctrine, holding that it was not within the scope of remand.The Supreme Court of Minnesota affirmed the decision of the court of appeals. The court concluded that the Act does authorize a governor to declare a peacetime emergency in response to a public health crisis such as a pandemic. Furthermore, the court found that Governor Walz was authorized under the Act to declare a peacetime emergency in response to the COVID-19 pandemic. Lastly, the court rejected Snell's contention that the Act violates the nondelegation doctrine, stating that the Act does not represent an unconstitutional delegation of legislative authority. The court noted that the Act places durational limits on the powers and subjects them to termination by the Legislature, thus providing a check on the Governor's powers. View "Procaccini vs. Walz" on Justia Law