Justia Minnesota Supreme Court Opinion Summaries

Lucas Peterson, a police officer for the City of Minneapolis, claimed workers' compensation benefits for PTSD, which he attributed to traumatic events experienced during his 22-year career. The City denied liability, arguing Peterson did not meet the criteria for PTSD and had pre-existing mental health conditions. Peterson filed a claim petition, and a compensation judge ruled in his favor, awarding benefits and penalties against the City for frivolous denial of benefits.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge’s decision, finding substantial evidence supported the PTSD diagnosis based on the most recent edition of the DSM. The WCCA also upheld the penalty for the City’s frivolous denial of primary liability. However, the WCCA erred in addressing Peterson’s claim for benefits for a diagnosis of other specified trauma and stressor-related disorder (OSTD) as a consequential mental injury of PTSD, as this issue was moot given the affirmed PTSD diagnosis.The Minnesota Supreme Court reviewed the case, affirming the WCCA’s decision that Peterson was entitled to workers' compensation benefits for PTSD and the penalty for frivolous denial. The Court found the compensation judge’s factual findings were not manifestly contrary to the evidence. However, the Court reversed the WCCA’s decision regarding the compensability of OSTD, agreeing that the issue was moot since Peterson was already entitled to benefits for PTSD. View "Peterson v. City of Minneapolis" on Justia Law

A dispute arose between a surety bond company, Granite Re, Inc. (Granite), and a creditor bank, United Prairie Bank (UPB), over entitlement to funds held by a receiver in a receivership action. Granite issued payment bonds to Molnau Trucking LLC (Molnau) for public works projects, but Molnau defaulted on both the projects and loans from UPB. The issue was whether Granite or UPB had priority to the bonded contract funds held by the receiver. Granite argued for priority under equitable subrogation, having paid laborers and suppliers, while UPB claimed priority under the UCC, having perfected its security interests in Molnau’s accounts receivable before Granite issued the bonds.The district court granted summary judgment in favor of UPB, recognizing Granite’s equitable subrogation rights but ruling that UPB’s perfected security interest had priority. The court of appeals affirmed, applying a “mistake of fact” standard from mortgage context case law, which Granite did not meet.The Minnesota Supreme Court reviewed the case and held that the “mistake of fact” standard does not apply to performing construction sureties. The court concluded that Granite, as a surety, has the right to equitable subrogation without needing to show a mistake of fact. The court further held that a surety’s right to equitable subrogation is not a security interest subject to the UCC’s first-in-time priority rule. Instead, a performing surety has priority over a secured creditor regarding bonded contract funds.The Minnesota Supreme Court reversed the court of appeals’ decision and remanded the case to the district court for entry of judgment in favor of Granite, allowing Granite to request redistribution of the bonded contract funds. View "In re Receivership of United Prairie Bank v. Molnau Trucking LLC" on Justia Law

Almost 30 years after his conviction for first-degree murder was affirmed, Nantambu Noah Kambon filed a petition for postconviction relief, raising several issues and requesting a new trial. The district court denied the petition without an evidentiary hearing, citing its untimeliness. Kambon appealed, raising two issues from the district court and introducing a new argument on appeal.The district court found Kambon's petition untimely under Minnesota Statutes section 590.01, which requires postconviction petitions to be filed within two years after the judgment of conviction or the appellate court’s disposition on direct appeal. Since Kambon's conviction became final before August 1, 2005, the two-year limitation ended on August 1, 2007. The district court also rejected Kambon's argument that his claim qualified under the new interpretation of law exception, reasoning that the petition was filed nearly 30 years after his direct appeal concluded, and all issues raised were known or should have been known during previous petitions.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that Kambon's claims were untimely and did not qualify for any exceptions to the two-year time limitation. The court also rejected Kambon's new argument that the United States Supreme Court's decision in Loper Bright Enterprises v. Raimondo, which overruled Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., applied to his case. The court clarified that the Chevron doctrine never applied to deference afforded to prior court decisions and that nothing in Chevron prevented Kambon from bringing his claims before 2007. Therefore, the court concluded that Loper Bright did not constitute a new interpretation of law that applied retroactively to Kambon's case. View "Kambon v. State" on Justia Law

Clifford Robert Letourneau, III, was charged with first-degree criminal sexual conduct under Minnesota Statutes section 609.342, subdivision 1(d), which criminalizes nonconsensual sexual penetration when the actor uses force, defined as the infliction of bodily harm. The complaint alleged that Letourneau arrived at K.L.'s home, and without consent, inserted his penis into her vagina, causing her to cry and bleed due to vaginal tearing.The district court dismissed the charge for lack of probable cause, concluding that the complaint did not allege facts showing that Letourneau used force to accomplish the act of sexual penetration. The court interpreted the statute to require the use of force to accomplish the act of penetration, not merely in conjunction with it.The Minnesota Court of Appeals reversed the district court's decision, interpreting the statute to require the use of force either before or during the act of sexual penetration, not necessarily to accomplish it. The court of appeals determined that the plain language of the statute criminalizes nonconsensual sexual penetration when the actor uses force either before or during the act.The Minnesota Supreme Court affirmed the court of appeals' decision, concluding that the plain language of section 609.342, subdivision 1(d) criminalizes nonconsensual sexual penetration when the actor uses force either before or during the act. The court held that the statute does not require the force to be used to accomplish the act of penetration. The court found that the facts alleged in the complaint, including K.L.'s statements about the bleeding and vaginal tearing caused by Letourneau's actions, established probable cause that Letourneau used force before or during the act of sexual penetration. View "State of Minnesota vs. Letourneau" on Justia Law

In early 2021, Jason Turner Johnson was charged with first-degree burglary and fifth-degree assault in Minnesota. Later, an additional charge of second-degree burglary was added. Johnson pleaded guilty to the second-degree burglary charge, and the other charges were dismissed. He was sentenced to 28 months in prison, but the sentence was stayed, and he was placed on probation for five years. In August 2023, Johnson's probation officer reported multiple probation violations, including new criminal charges and failure to contact his probation officer. Johnson requested jail credit for time spent in custody in North Dakota, which the district court partially granted.The district court revoked Johnson's probation, executed his stayed sentence, and awarded him partial jail credit for time spent in custody in North Dakota. The State of Minnesota appealed the jail credit determination. Johnson moved to dismiss the appeal, arguing that the State had no right to appeal the jail credit determination. The Minnesota Court of Appeals denied Johnson's motion, holding that the State's right to appeal a jail credit determination arises by necessary implication from its right to appeal any sentence imposed or stayed by the district court in a felony case.The Minnesota Supreme Court reviewed the case to determine whether the State could appeal the district court's jail credit determination following a probation revocation. The court concluded that the State's right to appeal a jail credit determination arises by necessary implication from its express right to appeal a probation revocation decision under Minnesota Rule of Criminal Procedure 27.04, subdivision 3(4)(a). Therefore, the court affirmed the decision of the court of appeals, allowing the State's appeal to proceed. View "State of Minnesota vs. Johnson" on Justia Law

In 1997, Milton K. Sanders was found guilty by a jury of one count of first-degree murder and two counts of attempted first-degree murder. The district court sentenced him to life in prison for the first-degree murder conviction and to consecutive 180-month prison sentences for the attempted first-degree murder convictions. Sanders's convictions and sentences were affirmed on appeal in 1999.In May 2024, Sanders filed a motion to correct his sentence, arguing that his consecutive sentences were unauthorized by law because they exaggerated the criminality of his conduct and were based on an incorrect criminal history score. The district court denied his motion, concluding that the sentences were authorized by law and that any error related to the criminal history score was harmless.The Minnesota Supreme Court reviewed the case. The court held that Sanders's argument regarding the exaggeration of his criminality was barred by the law of the case doctrine, as it had been previously addressed and denied in his direct appeal. Additionally, the court found that the consecutive sentences did not unfairly exaggerate the criminality of Sanders's conduct, as each offense involved a different victim, consistent with past sentences for similar offenses.Regarding the criminal history score, the court determined that any error in the district court's failure to pronounce Sanders's criminal history score at sentencing was harmless. The life sentence for first-degree murder was mandatory and unaffected by the criminal history score. The consecutive 180-month sentences for attempted first-degree murder were consistent with the presumptive sentence for a criminal history score of zero, as required by the sentencing guidelines.The Minnesota Supreme Court affirmed the district court's decision, concluding that the sentences were authorized by law and that any error related to the criminal history score was harmless. View "Sanders vs. State of Minnesota" on Justia Law

Ryan Charles Rooney was found guilty of first-degree domestic abuse murder after a jury trial and was sentenced to life in prison with the possibility of parole. Rooney appealed, arguing that the district court abused its discretion by precluding his alternative-perpetrator evidence and erred in denying his motion to suppress statements made to police officers. The case involves the murder of Rooney’s wife, Samantha Columbus-Boshey, whose body was found in a hotel room they had been staying in with her two young children.The district court precluded Rooney's alternative-perpetrator evidence, finding that he did not meet the foundational requirement to introduce such evidence. Additionally, the court denied Rooney's motion to suppress his statements to police officers, concluding that the statements were made voluntarily despite Rooney's head injury and hospitalization.The Minnesota Supreme Court reviewed the case and affirmed the district court's decisions. The court held that the district court did not abuse its discretion in precluding the alternative-perpetrator evidence, as Rooney failed to provide evidence with an inherent tendency to connect the third person, D.G., to the actual commission of the crime. The court also found that the district court correctly determined that Rooney's statements to police were voluntary, considering the totality of the circumstances, including his ability to comprehend and the nature of the interrogation.The Supreme Court concluded that the district court's rulings were based on a correct application of the law and were supported by the evidence. Therefore, the judgment of conviction was affirmed. View "State of Minnesota vs. Rooney" on Justia Law

James Jurgensen sustained a work injury on July 29, 2021, while employed by Dave Perkins Contracting, Inc. He hired attorney Joshua E. Borken, who agreed to a contingent fee of 20% of the first $130,000 of compensation and 20% of any excess amount, subject to approval. Minnesota Statutes § 176.081, subd. 1(a) (2022), caps attorney fees in workers’ compensation cases at $26,000. The parties settled for $150,000, and Borken sought $30,000 in fees, including $4,000 in excess fees. The compensation judge approved $26,000 but denied the excess fees after applying the Irwin factors.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge’s decision, finding no abuse of discretion in denying the excess fees. The WCCA also concluded that automatic approval of unobjected-to excess fees is inconsistent with section 176.081, which provides a presumptive cap on attorney fees. The WCCA did not address the constitutional issue due to a lack of jurisdiction.The Minnesota Supreme Court reviewed the case. The court held that the 2024 amendment to Minn. Stat. § 176.081, which increases the cap on attorney fees, does not apply retroactively. The court also held that the WCCA did not err by declining to automatically approve the requested excess fee. Additionally, the court found that Minn. Stat. § 176.081, subd. 1(a) (2022), does not violate the Contracts Clause of the Minnesota Constitution. Finally, the court concluded that the WCCA did not err by affirming the compensation judge’s denial of excess attorney fees under the Irwin factors.The Minnesota Supreme Court affirmed the decision of the WCCA, upholding the denial of the $4,000 in excess attorney fees. View "Jurgensen vs. Dave Perkins Contracting, Inc." on Justia Law

In 2011, Carlos Heard was convicted of third-degree depraved-mind murder and second-degree intentional murder for shooting and killing his brother and another person during a struggle over a gun. The district court sentenced him to 313 months for second-degree intentional murder and 180 months for third-degree depraved-mind murder. Heard appealed to the Minnesota Court of Appeals, challenging the district court's decision to allow impeachment evidence at his trial. The court of appeals affirmed his convictions, and the Minnesota Supreme Court denied review. Heard subsequently filed four postconviction petitions, all of which were denied.In 2023, Heard filed a fifth postconviction petition, arguing that the Minnesota Supreme Court's decisions in State v. Coleman and State v. Noor announced new substantive rules regarding the mental-state element of third-degree depraved-mind murder, which should apply retroactively to his case. The district court denied his petition, and the court of appeals affirmed, holding that Coleman and Noor did not announce new rules but rather clarified existing law.The Minnesota Supreme Court reviewed the case and concluded that Coleman and Noor did announce new rules of substantive law that apply retroactively. Coleman clarified that the mental-state element for third-degree depraved-mind murder requires a showing of reckless disregard for human life, while Noor held that this mental state cannot exist when the defendant's actions are directed at a particular person. The court also held that a postconviction petitioner is not required to independently satisfy the requirements of State v. Knaffla if the petitioner establishes that a new interpretation of state law is retroactively applicable in the first postconviction petition filed after the new interpretation is announced.The Minnesota Supreme Court reversed the court of appeals' decision and remanded the case to the district court to consider the effect of Coleman and Noor on Heard's third-degree depraved-mind murder conviction. View "Heard v. State" on Justia Law

A 15-year-old girl, S.W., left her home in Anoka County, Minnesota, without permission to stay with her mother’s cousin, A.G., in Wisconsin, where A.G. lived with the defendant, Paulson. After using methamphetamine together, Paulson assaulted A.G., took S.W. to his family’s property in Stacy, Minnesota, and kept her there for two days, during which he threatened her, provided her with drugs, and sexually assaulted her. S.W. was eventually recovered in Anoka County, where she reported the kidnapping and assaults to police.Paulson was initially charged in Anoka County District Court with first- and second-degree criminal sexual conduct. He moved to dismiss, arguing the offenses occurred in Isanti County, not Anoka County. The district court denied the motion, finding venue proper in Anoka County under Minnesota Statutes section 627.15, since S.W. was found there. The State later amended the complaint to add a kidnapping charge, to which Paulson entered an Alford plea. He did not challenge venue for the new charge. The district court accepted the plea and imposed sentence. On appeal, Paulson argued that his plea was invalid because the factual basis did not establish that venue was proper in Anoka County as required by Minnesota Statutes section 627.01. The Minnesota Court of Appeals rejected this argument, holding that venue is not an element of the offense.The Minnesota Supreme Court reviewed whether the statutory venue requirement is an element of the offense for purposes of the accuracy requirement of a guilty plea. The court held that the venue requirement in section 627.01 is not an element of the offense, and therefore, the factual basis for Paulson’s guilty plea was sufficient even though it did not establish venue. The decision of the court of appeals was affirmed. View "State of Minnesota vs. Paulson" on Justia Law