Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant’s convictions but reversed his sentence for first-degree murder of an unborn child, holding that the plain language of Minn. Stat. 609.106 does not authorize a sentence of life imprisonment without the possibility of release for a conviction of first-degree murder of an unborn child.Defendant was convicted of first-degree premeditated murder and first-degree premeditated murder of an unborn child. The Supreme Court upheld the convictions but reversed Defendant’s life sentence, holding (1) structural error did not occur when the district court judge presided over Defendant’s jury trial after defense counsel commented during an ex parte conversation that Defendant might commit perjury; (2) Defendant received effective assistance of counsel; (3) the district court did not commit plain error in its jury instructions; and (4) Defendant’s sentence of life imprisonment without the possibility of release for his conviction of first-degree murder of an unborn child was not authorized by section 609.106. View "State v. Mouelle" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing the portion of Appellants’ appeal arising out of orders denying their motions in limine because Appellants did not raise their objections in a motion for a new trial, holding that a motion for a new trial is not required to preserve objections to pretrial orders that decide motions in limine for appellate review.In this condemnation proceeding, Hennepin County sought to seize Appellants’ property by eminent domain. Dissatisfied with the award of compensation they received for the taking, Appellants appealed the decision of the court-appointed commissioners. After the matter was set for trial, Appellants brought several motions in limine, all of which were denied. The matter then proceeded to trial, and the district court entered a judgment for $0. Appellants did not move for a new trial but instead appealed the judgment on several grounds, including the denial of their motions in limine. The court of appeals dismissed the portion of the appeal arising out of the denial of Appellants’ motions in limine. The Supreme Court reversed, holding that pretrial orders on motions in limine are appealable regardless of whether those orders have been assigned as error in a motion for a new trial. View "County of Hennepin v. Bhakta" on Justia Law

The Supreme Court in this negligence case decided not to extend the doctrine of implied primary assumption of risk, which is a complete bar to tort liability, to recreational skiing and snowboarding, thus affirming the decision of the court of appeals concluding that the district court erred in granting summary judgment to Defendant.Plaintiff, a ski instructor, was struck by Defendant, an adult snowboarder performing an aerial trick, while Plaintiff was teaching a young student in an area marked “slow skiing area.” Plaintiff sued Defendant for negligence. The district court granted summary judgment for Defendant, concluding that under the doctrine of implied primary assumption of risk Defendant owed Plaintiff no duty of care. The court of appeals reversed after assuming that the doctrine of implied primary assumption of risk generally applies to actions between skiers, holding that material fact issues precluded summary judgment. The Supreme Court affirmed on different grounds, holding that the doctrine of implied primary assumption of risk does not extend to recreational downhill skiing and snowboarding. The Court remanded the case. View "Soderberg v. Anderson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the district court’s denial of Defendant’s motion to correct his sentence, holding that the two-tier conditional-release term contained in Minn. Stat. 617.247, subd. 9, the child pornography statute, is not ambiguous and was properly applied in this case.Defendant pleaded guilty to one count of possessing child pornography. Relying on Minn. Stat. 617.247, subd. 9, the district court imposed a conditional-release term of ten years in addition to a twenty-month term of incarceration. In his motion to correct his sentence, Defendant argued that the proper term of conditional release was five years. The district court denied the motion. The court of appeals reversed and vacated Defendant’s conditional-release term, concluding that the statute contained a “temporal ambiguity” and that Defendant’s sentence was not authorized by law. The Supreme Court reversed, holding that section 617.247, subd. 9 is unambiguous and requires a ten-year conditional-release term for Defendant. View "State v. Overweg" on Justia Law