Justia Minnesota Supreme Court Opinion Summaries

In this condemnation case, the Supreme Court affirmed the decision of the court of appeals reversing the district court’s award of $168,009 in attorney fees to the landowner under the condemnation fee-shifting statute, Minn. stat. 117.031(a), holding that the district court misinterpreted and misapplied the Court’s lodestar precedent.Using the lodestar method, the district court awarded the landowner the amount that he requested. The court of appeals reversed the award because the district court failed to begin its calculation with the presumptive lodestar amount of $34,133 and because the district court did not sufficiently explain why enhancing the presumptive lodestar amount by more than $130,000 would represent a reasonable fee. The Supreme Court affirmed, holding (1) under current Supreme Court law, an enhancement based on a contingent fee agreement is improper; and (2) the district court incorrectly applied the law and did not make adequate factual findings to support its enhanced attorney-fee award. View "State v. Krause" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals ruling that Minnesota’s vehicle forfeiture statute, Minn. Stat. 169A.63, is unconstitutional as applied to Helen and Megan Olson, holding that the statute is constitutional on its face and constitutional as applied to Megan but unconstitutional as applied to Helen.Megan was arrested for driving while impaired (DWI) and was subject to being charged with a first-degree DWI offense. Because a first-degree DWI offense is a “designated” offense under the DWI vehicle forfeiture statute, the vehicle Megan was driving when she was arrested - a 1999 Lexus owned by Megan’s mother Helen - was subject to forfeiture. The police seized the vehicle incident to Megan’s lawful arrest. The Olsons filed a demand for judicial determination of the forfeiture, arguing that section 169A.63(9)(d), which sets forth the procedural requirements for judicial hearings related to vehicle forfeiture for a DWI offense, violated their due process rights. The district court determined that the statute was unconstitutional on its face. The court of appeals affirmed on different grounds. The Supreme Court held that the statute was constitutional as applied to Megan, who did not own the vehicle, but unconstitutional as applied to Helen, the purportedly innocent owner. View "Olson v. One 1999 Lexus" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court determining that the physician-patient privilege covered a blood sample and granting Defendant’s motion to suppress the results of a blood-alcohol concentration test derived from the blood sample, holding that a blood sample is not covered by the physician-patient privilege.The blood sample in this case was drawn by a medical professional during the course of emergency medical treatment after Defendant was injured in an ATV accident. In reversing the district court’s decision to suppress the evidence, the court of appeals concluded that a blood sample does not fall within the plain meaning of the word “information” as used in Minnesota’s statutory physician-patient privilege, codified at Minn. Stat. 595.02(1)(d). The Supreme Court affirmed, holding holding that the word “information” as used in the statute does not include a blood samples, and therefore, the physician-patient privilege did not apply to Defendant’s blood sample and the results of the blood-alcohol concentration test derived from the blood sample. View "State v. Atwood" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the decision of the district court finding for Tenant in the underlying eviction proceedings brought by Landlord and concluding that Landlord had breached the covenants of habitability, holding that a tenant asserting a common-law habitability defense in an eviction proceeding is not required to follow the procedures for an action under the rent-escrow statute, Minn. Stat. 504B.385.In response to Landlord’s action, Tenant raised the common-law habitability defense. The district court agreed with Tenant and ordered retroactive and prospective rent abatement until Landlord’s habitability violations were fixed. On appeal, Landlord argued that a tenant must follow the statutory procedures, including written notice, for a rent-escrow action under section 504B.385. The court of appeals held that Tenant was not required to do so. The Supreme Court affirmed, holding that written notice is not required before a tenant raises a common-law habitability defense to an eviction proceeding. View "Ellis v. Doe" on Justia Law

The Supreme Court affirmed the decision of the workers’ compensation court of appeals (WCCA) reversing the workers’ compensation judge’s dismissal of Respondent’s petition for temporary total disability (TTD) benefits under the Minnesota Workers’ Compensation Act, holding that there is no statutory authority for an offset of workers’ compensation benefits by the amount of benefits paid under an employer’s self-funded, self-administered short-term disability (STD) plan.After awarded TTD benefits to Respondent, the compensation judge determined that Respondent’s employer (Employer) was entitled to offset those benefits by the amount of STD benefits already paid. Because Employer had already paid STD benefits in essentially the same amount that would be owed as TTD benefits, the compensation judge then dismissed Respondent’s petition. The WCCA reversed. The Supreme Court affirmed, holding that the WCCA did not err in determining the Employer was not entitled to offset its workers’ compensation liability to Respondent by the amount of STD benefits it paid to Respondent. View "Bruton v. Smithfield Foods, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying the motion for summary judgment filed by the City of Minneapolis as to Plaintiff’s claims under the Human Rights Act that the City discriminated against him by failing to accommodate his disability and retaliated against him for seeking an accommodation, holding that Plaintiff’s claims under the Human Rights Act were not barred by the exclusive-remedy provision of the Minnesota Workers’ Compensation Act.In moving for summary judgment, the City argued that Plaintiff’s claims were barred by the exclusivity provision in the Workers’ Compensation Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court overruled its decision in Karst v. F.C. Hayer Co., 447 N.W.2d 180 (Minn. 1989) and reversed, holding that an employee can pursue claims under both the Workers’ Compensation Act and the Human Rights Act because each act provides a distinct cause of action that redresses a discrete type of injury to an employee. View "Daniel v. City of Minneapolis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court’s denial of Appellant’s request for a jury instruction on the defense of voluntary intoxication, holding that Minn. State. 617.23(2), the indecent-exposure statute, does not require the State to prove that the defendant had a specific intent to be lewd.Defendant was charged with indecent exposure in the presence of a minor under the age of sixteen. After concluding that the indecent-exposure statute creates a general-intent crime, the district court denied Defendant’s request that the jury be instructed on the defense of voluntary intoxication because that defense only applies to specific-intent crimes. The jury found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that the offense of indecent exposure is a general-intent crime, and therefore, the court of appeals did not err when it affirmed the district court’s denial of Defendant’s request for a jury instruction on the defense of voluntary intoxication. View "State v. Jama" on Justia Law

The Supreme Court reversed the decision of the tax court concluding that the Commissioner of Revenue had overvalued Enbridge Energy, LP’s (EELP) pipeline system for 2013, 2014, and 2015 and issuing a new valuation for all three years, holding that, contrary to the tax court’s conclusion, the tax court is bound by Minnesota Rule 8100, an administrative rule regarding ad valorem taxes for utilities, when valuing a pipeline system and in allocating system unit value.Specifically at issue on appeal was whether the tax court erred in concluding that it is not bound by Rule 8100 when valuing a pipeline system. In reversing, the Supreme Court held that the tax court must follow Rule 8100 on how utilities, including pipelines, should be valued for tax purposes, and the tax court erred by concluding otherwise. View "Commissioner of Revenue v. Enbridge Energy, LP" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the district court’s denial of the City of Richfield’s motion to vacate an arbitration award reinstating Nathan Kinsey, a police officer, after the City discharged him for failing to report his use of force and violating other policies, holding that enforcing the arbitration award does not violate a well-defined and dominant public policy.The arbitrator ordered reinstatement after finding that Kinsey did not use excessive force and his decision not to report the use of force was a “lapse in judgment,” and therefore, the City did not have just cause to discharge Kinsey. The district court denied the City’s motion to vacate the award. The court of appeals reversed, concluding that enforcement of the award would violate well-defined and dominant public policies against excessive force. The Supreme Court reversed, holding that reinstatement of Kinsey does not violate any public policy. View "City of Richfield v. Law Enforcement Labor Services, Inc." on Justia Law

The Supreme Court affirmed the decision of the postconviction court summarily denying Appellant’s present petition for postconviction relief, holding that the record conclusively established that Appellant was not entitled to relief.Appellant was convicted of aiding and abetting first-degree felony murder. After the conviction was affirmed on direct appeal, Appellant filed three petitions for postconviction relief, each of which was summarily denied. At issue int his appeal was Appellant’s fourth petition for postconviction relief, which the postconviction court denied without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his claims. View "Crow v. State" on Justia Law