Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the Workers' Compensation Court of Appeals (WCCA) ruling that Minn. Stat. 176.179 did not apply to Appellant's vacated workers' compensation award, holding that no mistaken compensation was paid, and thus, section 176.179 did not apply.Appellant injured his low back during the course of his employment and entered into a settlement agreement with his employer. The WCCA approved the settlement by an award. Appellant later petitioned to vacate the award, arguing that there was a mutual mistake of fact when the settlement was entered into and a substantial change in his medical condition that could not have been anticipated at the time of the award. The WCCA vacated the award based on the substantial change in Appellant's medical condition. When Appellant then filed a claim petition for additional benefits the parties disagreed as to whether Employer was entitled to a credit for the $40,000 already paid under the vacated award. The compensation judge ruled that section 176.179 did not apply and that Employer was entitled to full credit against Appellant's claim for benefits. The Supreme Court affirmed, holding because no mistake of fact or law occurred, no mistaken compensation was paid and that section 176.179 did not apply. View "Block v. Exterior Remodelers, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree manslaughter, holding that the plain language of the first-degree manslaughter statute, Minn. Stat. 609.20(2), does not require the State to prove that death or great bodily harm was a reasonably foreseeable result when the underlying crime is fifth-degree assault.On appeal, Defendant argued that the district court erred by failing to instruct the jury that a conviction for first-degree manslaughter required proof that he committed fifth-degree assault with such violence or force that great bodily harm or death was reasonably foreseeable. The court of appeals affirmed, concluding that the district court did not err in declining to so instruct the jury. The Supreme Court affirmed, holding that section 609.20(2) does not require the State to prove that death or great bodily harm was a reasonably foreseeable result of the defendant's conduct when the underlying crime is fifth-degree assault. View "State v. Stay" on Justia Law

In this case against two for-profit universities (the Schools) alleging that the Schools violated the Minnesota Consumer Fraud Act (MCFA), Minn. Stat. 325F.69, and the Uniform Deceptive Trade Practices Act (DTPA), Minn. Stat. 325D.44, the Supreme Court held that the Attorney General proved that a causal nexus was established between the Schools' fraudulent statements and the harm suffered by students.At issue was whether the Attorney General established a causal nexus between the Schools' statements misleading prospective students about the value of criminal justice degrees offered by the Schools and the harm suffered by students who entered the Schools' criminal justice program. During trial, fifteen students who had enrolled in the criminal justice program testified. The district court ultimately issued an injunction and ordered equitable restitution requiring the Schools to disgorge the tuition collected from the criminal justice program students. The court of appeals upheld the restitution order for the students who testified at trial but reversed the order as to nontestifying students. The Supreme Court reversed in part, holding (1) the Attorney General established a causal nexus between the Schools' misleading statements and the harm suffered by the non testifying students; and (2) the equitable restitution process ordered by the district court was proper. View "State v. Minnesota School of Business, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder, first-degree aggravated robbery, and possession of a firearm by an ineligible person related to a fatal shooting, holding that the district court did not clearly err by overruling Defendant's Batson objection to the State's peremptory challenge of a prospective juror.On appeal, Defendant argued that the district court erred in overruling his Batson objection to the State's peremptory challenge of the juror because the State's challenge was racially motivated and the proffered explanation for exercising the challenge was pretextual. The Supreme Court affirmed, holding that the district court did not clearly err in determining that the race-neutral reason for striking the juror was not a pretext for racial discrimination. View "State v. Adams" on Justia Law

In this case brought under the Federal Employers' Liability Act (FELA), 45 U.S.C. 51-60, the Supreme Court reversed the decision of the court of appeals affirming the district court's use of the federal post judgment interest rate of .058 percent per year after the district court awarded Employee damages, holding that the state post judgment interest rate applies.In his complaint against his employer, BNSF Railway Company, Employee claimed that he suffered cumulative trauma to his back resulting from his twenty years of employment as a conductor and engineer. The jury decided in favor of Employee. The district court awarded damages and postjudgment interest, applying the federal postjudgment interest rate. The Supreme Court reversed and remanded the case to the district court to apply the ten percent postjudgment interest rate set forth in Minn. Stat. 549.09, subd. 1 (c)(2), holding that postjudgment interest in an action brought under FELA in Minnesota courts is calculated in accordance with Minn. Stat. 549.09, subd. 1(c). View "Alby v. BNSF Railway Co." on Justia Law

In this personal injury action, the Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court deducting from a damages award to Respondent the amount of discounts negotiated by Respondent's managed-care organizations, holding that the discounts were payments made pursuant to the United States Social Security Act under Minn. Stat. 548.251, subd. 1(2).After her car struck a school bus that failed to yield at an intersection, Respondent brought this action against the driver and the owner of the bus (collectively, Appellants). The medical expenses of Respondent, a medical-assistance enrollee, were covered by two managed-care organizations that contracted with Minnesota's Prepaid Medical Assistance Plan under the state's Medicaid program. The jury awarded damages, but the district court deducted from the award the discounts negotiated by the managed-care organizations. The court of appeals reversed. The Supreme Court affirmed, holding that the negotiated discounts were "payments made pursuant to the United States Social Security Act" under section 548.251, subd. 1(2), and therefore, Appellants could not offset the damages award for those payments. View "Getz v. Peace" on Justia Law

The Supreme Court affirmed the order of the district court directing the City of Saint Paul to put a referendum question regarding the City's ordinance that established organized waste collection in the City on the ballot for the next municipal election, concluding that holding a referendum on the issue will not unconstitutionally impair the City's contract with haulers that provide organized waste collection.The City refused to put the referendum question on the ballot, concluding that the referendum was preempted by state statutes that govern solid waste collection, conflicts with state policy, and would by an unconstitutional interference with the City's contract with the haulers. Respondents with filed a petition challenging the City's refusal. The district court granted the petition. The Supreme Court affirmed, holding that the City has not demonstrated that a substantial impairment of its contractual obligation will occur with the referendum vote, and therefore, the Court need not address the other two factors. View "Clark v. City of Saint Paul" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting summary judgment to the City of Brainerd after the City restructured its fire department and eliminated all of its union positions, holding that the City engaged in an unfair labor practice prohibited by Minn. Stat. 179A.13, subd. 2(2).Firefighters Union Local 4725 and the union president sued the City under the Public Employment Labor Relations Act (PELRA), Minn. Stat. 197A.01-.25, alleging that in eliminating the union positions, the City engaged in unfair labor practices prohibited by PELRA. The district court granted summary judgment for the City. The court of appeals reversed, ruling that the City violated section 179A.13, subd. 2(2) by undergoing a department reorganization that resulted in the dissolution of a bargaining unit. The Supreme Court affirmed, holding that the City's interference with the existence of an employee organization constituted a prohibited unfair labor practice. View "Firefighters Union Local 4725 v. City of Brainerd" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's decision awarding Mother and Father joint physical custody and equal parenting time, holding that the district court did not misapply the domestic-abuse presumption or the friendly-parent factor and appropriately exercised its discretion in analyzing the best interests factors.After a trial, the family court referee found that Mother had committed domestic abuse against Father. However, the referee found that best interest of the parties' child required that the parties be awarded joint physical custody and equal parenting time and that the statutory presumption against joint legal custody was not rebutted, thus awarding sole legal custody to Mother. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not misapply the rebuttable presumption against awarding joint custody when domestic violence has occurred between parents; (2) did not misapply the friendly-parent factor in its best-interests analysis; and (3) did not abuse its discretion in concluding that the child was best served by a joint physical custodial arrangement. View "Thornton v. Bosquez" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the district court's decision denying Defendant's petition for postconviction relief asserting the invalidity of a test-refusal conviction under Birchfield v. North Dakota, 579 U.S. ___ (2016), and Johnson v. State, 916 N.W.2d 674 (Minn. 2018), holding that the district court properly placed the burden of proof on Defendant instead of the State.Birchfield announced the rule that, in the absence of a warrant or an exception to the warrant requirement, refusal to submit to a blood or urine test cannot be criminalized. Johnson made the rule retroactive. The district court denied Defendant's request for postconviction relief, concluding that he failed to prove there was no applicable exception to the warrant requirement. The court of appeals reversed, holding that the district court erred by placing the burden of proof on Defendant instead of the State. The Supreme Court reversed and announced a heightened pleading standard for Birchfield/Johnson postconviction proceedings, holding that the district court properly placed the burden of proof on Defendant. View "Fagin v. State" on Justia Law