Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals reversing the district court’s grant of summary judgment in favor of Defendant, a Minneapolis bar, on Plaintiffs’ complaint pleading innkeeper-negligence and dram-shop claims, holding that summary judgment on both claims was improper.An off-duty employee of Defendant was fatally injured while helping other bar employees force an aggressive patron out of the bar. Plaintiffs, the decedent’s family, sued Defendant for the death. In granting summary judgment for Defendant, the district court determined (1) as to the innkeeper-negligence claim, the bar owed no duty based on the doctrine of implied primary assumption of risk; and (2) as to the dram-shop claim, the claim failed on the element of proximate cause. The court of appeals reversed. The Supreme Court affirmed, holding (1) the doctrine of implied primary assumption of risk does not apply to the operation and patronage of bars; and (2) there existed a genuine issue of material fact as to whether the aggressive patron’s actions were a proximate cause of the decedent’s fatal injury. View "Henson v. Uptown Drink, LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding Defendant’s conviction of simple robbery, holding that the evidence was sufficient to support the conviction.Defendant’s conviction arose from his act of taking a bottle of brandy from a liquor store and assaulting the store manager. On appeal, Defendant argued that he could not be convicted of simple robbery because the bottle that he took belonged to the business and not to a person, and therefore, the property was not “personal property” within the meaning of Minn. Stat. 609.24. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase “personal property” as used in the statute is a technical term that has acquired the specialized meaning of all property other than real property; and (2) therefore, the evidence was sufficient to support the conviction. View "State v. Bowen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Appellant’s conviction of felony domestic assault, holding that the evidence was sufficient to prove that Defendant and the victim were “persons involved in a significant romantic or sexual relationship” at the time of the offense under Minn. Stat. 609.2242(4).In affirming, the court of appeals concluded that the phrase “significant romantic or sexual relationship” is unambiguous. The Supreme Court affirmed, holding (1) that to determine whether two persons are involved in a “significant romantic or sexual relationship” for the purposes of the domestic-assault statute, a court must undergo a case-by-case analysis using the statutory factors of Minn. Stat. 518B.01(2), including the length of the relationship, the type of relationship, and the frequency of interactions between the two persons; and (2) the record was sufficient to support the jury’s finding that Defendant and the victim were in a “significant romantic or sexual relationship” when the assault occurred. View "State v. Robinson" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree premeditated murder and sentencing him to life in prison without the possibility of release, holding that, contrary to Defendant's assertions on appeal, Defendant’s conviction was not based on corroborated accomplice testimony and that there was no abuse of discretion in the jury instructions.Specifically, the Court held (1) the testimony of Defendant’s accomplice was sufficiently corroborated, and therefore, Defendant’s premeditated murder conviction did not violate Minn. Stat. 634.04; and (2) the district court did not abuse its discretion when it denied Defendant’s request to instruct the jury about the credibility of drug users or witnesses who could later be charged as accessories after the fact. View "State v. Thoresen" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court concluding that future, contingent earn-out payments are nonmarital property because they are property acquired by a spouse after the valuation date, holding that because the parties’ interest in Husband’s company was marital property that was acquired before the valuation date, the consideration for the sale of the company was also marital property.While married to Wife, Husband purchased an ownership interest in a company. During dissolution proceedings and after the district court’s valuation date for for marital property but before the dissolution, the company and Husband’s ownership interests in the company were sold. The purchase agreement gave the company and its owners an amount paid at the time of the sale and the right to receive future amounts. The district court concluded that the earn-out payments were nonmarital property. The court of appeals reversed. The Supreme Court affirmed, holding that the consideration for the sale of the company was marital property. View "Gill v. Gill" on Justia Law

The Supreme Court reversed the court of appeals affirming the district court’s competency determination in this criminal case, holding that the court of appeals erred when it did not follow State v. Ganpat, 732 N.W. 2d 232 (Minn. 2007), and place the burden of proving that Defendant was competent on the State.After determining that Defendant was mentally competent to proceed to trial, the district court convicted him of fourth-degree criminal sexual conduct. Defendant appealed, arguing that the district court failed to place the burden of proof on the State as required by Ganpat in determining him to be competent. In affirming, the court of appeals declined to follow Ganpat, instead ruling that competency should be determined based on the greater weight of the evidence without regard to burden of proof. The Supreme Court reversed and remanded, holding that the court of appeals and district court erred in failing to adhere to Ganpat and that it was not certain whether the district court would have made the same competency determination had it applied the correct burden of proof. View "State v. Curtis" on Justia Law