Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals affirming the district court’s grant of summary judgment for The Blake School (the school) on Appellant’s negligence action based on a fatal accident caused by a high-school student while he was driving his cross-county teammates and a volunteer coach to an extracurricular athletic competition, holding that summary judgment was not proper under the circumstances of this case.In granting summary judgment for the school, the district court concluded that the school did not owe a duty of care to members of the general public as a matter of law. The court of appeals affirmed on a different ground, concluding that the school’s conduct did not create a foreseeable risk of injury to a foreseeable plaintiff. The Supreme Court reversed, holding (1) the school was subject to the black-letter common-law rule that it may be liable for the negligence of others if its own conduct creates a foreseeable risk of injury to a foreseeable plaintiff; and (2) foreseeability was at least a close call, making summary judgment on the element of duty inappropriate. View "Fenrich v. The Blake School" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant’s motion to correct his sentences under Minn. R. Crim. P. 27.03(9), holding that the district court did not commit reversible error.Appellant was convicted of murdering his ex-wife and kidnapping their three children. The Supreme Court affirmed Appellant’s convictions and sentences. Appellant later filed the present motion to correct his sentences. Relying on Minn. Stat. 611.02, 609.04 and 609.035, Appellant argued that the district court committed reversible error. The district court denied the motion without holding a hearing. The Supreme Court affirmed, holding (1) Appellant’s claims made under Minn. Stat. 609.04 and 611.02 challenging his convictions were outside the scope of Rule 27.03(9); and (2) Appellant’s sentences did not violate section 609.035. View "Munt v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s summary denial of Defendant’s second postconviction petition, holding that the record conclusively showed that Defendant was not entitled to relief.Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed. This appeal concerned the postconviction court’s summary denial of Defendant’s second petition for postconviction relief in which Defendant argued that he was entitled to relief under the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations governing postconviction petitions. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in summarily denying the petition because (1) certain claims did not satisfy the interests-of-justice exception to the statute of limitations, (2) other claims were untimely, and (3) the remaining claims were unsupported by arguments or legal authority. View "Nissalke v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing the claims filed by Depositors Insurance Company against Craig Dollansky after concluding that Depositors was barred by Minn. Stat. 60A.41(a) from proceeding against Dollansky in a subrogation action, holding that the statute indeed barred Depositors from proceeding in this action.Depositors insured a motor vehicle home owned by Karavan Trailers, Inc., which rented the motor home to Dollansky. The rental agreement provided that Dollansky was responsible for all damages to the RV during the term of the agreement. The motor vehicle caught fire while Dollansky was driving it. Karavan submitted a claim to its insurer, Depositors, which paid the full amount of the damages. Depositors then filed a complaint against Dollansky, alleging that Depositors was surrogated to the rights of Karavan in the same amount. The district court dismissed the claims, concluding that Depositors was barred by section 60A.41(a) from proceeding against Dollansky in a subrogation action. The court of appeals affirmed. The Supreme Court affirmed, holding that where Depositors provided insurance coverage to Dollansky as a permissive-use driver and the loss was caused by the nonintentional acts of Dollansky, section 60A.41(a) barred Depositors from proceeding against Dollansky in a subrogation action. View "Depositors Insurance Co. v. Dollansky" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Appellant’s petition for postconviction relief challenging his conviction for first-degree murder for the benefit of a gang, holding that Appellant’s claims were procedurally barred by the rule articulated in State v. Knaffla, 243 N.W.2d 737, 741 (Minn. 1976).The postconviction court found that Appellant was not entitled to relief because his claims were procedurally barred by the Knaffla rule. The Supreme Court affirmed, holding that because Appellant’s postconviction petition was based on claims that were raised and decided in previous proceedings, the postconviction court did not abuse its discretion when it summarily denied the petition. View "Jackson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing this qui tam action filed under the Minnesota False Claims Act, Minn. Stat. 15C.02 (MFCA), claiming that Respondents intentionally failed to pay fees and surcharges due to the State, holding that Appellant failed to state a claim as a matter of law.The fees and surcharges that were the subject of this litigation were imposed by statute for 911 services, the Telecommunications Access Minnesota (TAM) program, and the Telephone Assistance Plan (TAP) program. Respondents, telecommunications carriers, moved for dismissal, arguing that the 911, TAM, and TAP charges were all taxes and, therefore, dismissal was warranted because the MCFA does not allow qui tam actions based on “claims, records, or statements made under portions of Minnesota Statues relating to taxation,” Minn. Stat. 15C.03. The court of appeals agreed that the 911, TAM, and TAP surcharges were taxes, and therefore, this claim was prohibited by the tax bar provided in the MFCA. The Supreme Court affirmed, holding that, as the statutes at issue are currently written, the 911 fee, TAM charge, and TAP surcharges are taxes, and therefore, this action was barred. View "Phone Recovery Services, LLC v. Qwest Corp." on Justia Law