Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the court of appeals affirming the decision of the postconviction court that Defendant was entitled to a new trial because a juror was actually biased and not sufficiently rehabilitated but that the search of Defendant did not violate his Fourth Amendment rights.Defendant was convicted of possession of a firearm by an ineligible person. Thereafter, Defendant filed a postconviction petition arguing that the district court erred in denying his for-cause strike of Juror 18 and that the police unreasonably searched and seized him, violating his Fourth Amendment rights. The postconviction court rejected Defendant’s Fourth Amendment argument but concluded that the district court committed reversible error by denying the motion to strike Juror 18 for cause. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the search of Defendant was objectively reasonable under the emergency-aid exception to the Fourth Amendment warrant requirement; and (2) Defendant was entitled to a new trial because the presence of the actually biased juror. View "Ries v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals holding that Minn. Stat. 609.342(1)(h) does not require the State to prove that “sexual penetration” occurred, holding that the plain language of the statute requires proof of “sexual penetration," and therefore, the State presented insufficient evidence to support Defendant's conviction.Defendant was convicted of first-degree criminal sexual conduct under section 609.342(1)(h) for engaging in genital-to-genital contact with G.M. On appeal, Defendant argued that the State presented insufficient evidence to support the conviction because the statute requires proof of “sexual penetration” and the State did not prove sexual penetration. The court of appeals rejected Defendant’s argument and affirmed. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the plain language of subdivision 1(h) unambiguously requires proof of sexual penetration. View "State v. Ortega-Rodriguez" on Justia Law

The Supreme Court affirmed the decision of the tax court upholding the decision of the Commissioner of Revenue to include Pell grants in its calculation of Relators’ household income, holding that “nontaxable scholarship or fellowship grants” as used in Minn. Stat. 290A.03(3)(a)(2)(xiii) is plain and unambiguous and includes Pell grants.Household income is used to determine eligible for, and the amount of, a property tax income and includes “nontaxable scholarship or fellowship grants.” Relators argued that Pell grants are not scholarships or fellowships and therefore cannot be included in the income calculation made to determine the amount of the property tax refund. The Supreme Court disagreed, holding that Pell grants are nontaxable and therefore includable in calculating household income. View "Waters v. Commissioner of Revenue" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court that concluded that a fee agreement between the parties was not void and thus ordering arbitration, holding that the district court erred by directing entry of final judgment rather than staying the proceedings, and therefore, there was no proper final judgment from which to take an appeal.Plaintiffs sued Defendants after learning that Defendants had provided brokerage services to Plaintiffs without the requisite state license. Specifically, Plaintiffs alleged that the fee agreement obligating Defendants to pay for the services provided was void as against public policy. Defendants, in turn, moved to compel arbitration pursuant to the terms of the fee agreement and to dismiss or to stay the underlying proceedings. The district court ordered arbitration and dismissed the case, concluding that the fee agreement was not void. The court of appeals reversed, determining that the fee agreement was void. The Supreme Court vacated the court of appeals’ decision, holding that the district court erred by dismissing the case instead of staying proceedings and that the court of appeals erred when it concluded that it had jurisdiction over the merits of this case. View "Woischke v. Stursberg & Fine, Inc." on Justia Law