Justia Minnesota Supreme Court Opinion Summaries

In this divorce proceeding, the Supreme Court affirmed the decision of the court of appeals concluding that the certain contingent earn-out payments set forth in a purchase agreement selling a company in which Husband had an ownership interest were marital property.While married to Wife, Husband purchased an ownership interest in a company. During dissolution proceedings but before the dissolution, Husband and the other owners of the company sold the company and their ownership interests in the company. The purchase agreement gave the company and its owners the right to receive and up-front payment and two potential future earn-out payments. The district court concluded that the earn-out payments were nonmarital property under Minn. Stat. 518.003, subd. 3b because they were property acquired by a spouse after the district court’s valuation date for marital property. The court of appeals reversed. The Supreme Court affirmed after noting that the consideration for the sale of the company occurred before the dissolution and included an amount paid at the time of the sale and a contractual right to receive future payments. The Court held that because the parties’ interest in the company was marital property acquired before the valuation date, the consideration for the sale was also marital property. View "Gill v. Gill" on Justia Law

At issue was whether a notice to remove an assigned tax court judge was timely and, if so, whether the assigned judge erred in finding that it was impracticable to honor the notice.OCC, LLC, a property owner in Hennepin County, petitioned for a writ of mandamus that directed the tax court to vacate an order that quashed OCC’s notice to remove the assigned tax court judge and to honor the notice. The tax court declined specifically to decide whether the notice was timely and, instead, concluded that it was not “practicable” to honor the removal notice. The Supreme Court granted OCC’s petition for mandamus, directed the tax court to vacate its order quashing the notice to remove, and directed the tax court to honor that notice by assigning OCC’s consolidated tax proceedings to a different judge, holding (1) OCC’s notice to remove was timely under Minn. R. Civ. P. 63.03; and (2) the record did not establish that honoring the timely notice to remove was impracticable in this case. View "OCC, LLC v. County of Hennepin" on Justia Law

The Supreme Court held that the decision of the United States Supreme Court in Birchfield v. North Dakota, 579 U.S. __ (2016), and this Court’s decisions in State v. Trahan, 886 N.W.2d 216 (Minn. 2016), and State v. Thompson, 886 N.W.2d 224 (Minn. 2016), announced a new rule of constitutional law that applies retroactively to cases on collateral view.In this consolidated appeal arising from two separate traffic stops, the Supreme Court reviewed the decision of the court of appeals concluding that the Birchfield rule did not apply retroactively to Defendant’s final convictions because the rule was procedural in nature, and that, therefore, the district courts properly denied Defendant’s postconviction petitions. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the Birchfield rule is substantive and applies retroactively to Defendant’s convictions on collateral review. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the decision of the postconviction court denying Appellant’s petition for postconviction relief without an evidentiary hearing, holding that the postconviction court did not abuse its discretion.Appellant was found guilty of first-degree premeditated murder committed for the benefit of a gang. Appellant filed a petition for postconviction relief alleging a witness-recantation claim, ineffective assistance of trial counsel, and a Brady violation. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it summarily denied (1) Appellant’s witness-recantation claim where the evidence presented in support of the claim lacked sufficient indicia of trustworthiness; (2) Appellant’s ineffective assistance of counsel claim because the claim was Knaffla-barred; and (3) Appellant’s Brady-violation claim because the record conclusively showed that Appellant was not entitled to relief. View "Campbell v. State" on Justia Law

The Supreme Court held that Minnesota’s Legend Drug Tax, Minn. Stat. 295.52(4), applies to a non-resident pharmacy’s delivery of prescription drugs to Minnesota-based patients and doctors and that such application does not violate the Due Process Clause or Commerce Clause of the United States Constitution.Respondent-pharmacy requested funds from the Department of Revenue for taxes paid under the Legend Drug Tax on transactions between Respondent’s non-resident pharmacies and Minnesota-based patients and doctors. The Commissioner of Revenue denied the refunds. The Tax Court granted summary judgment for Respondent, concluding that the Legend Drug Tax did not apply to the transactions at issue. The Supreme Court reversed, holding that the tax did apply to the transactions and that application of the tax comported with the Due Process and Commerce Clauses of the United States Constitution. View "Walgreens Specialty Pharmacy, LLC v. Commissioner of Revenue" on Justia Law

The Supreme Court held that the classification of a prior offense under Minnesota Sentencing Guidelines 2.B.7.a for the purpose of calculating a defendant’s criminal history score is determined by the Minnesota offense definitions and sentencing policies in effect when the defendant committed the current offense rather than when the defendant is sentenced for the current offense.In 2007, Appellant was convicted of fifth-degree possession of a controlled substance. In March 2016, Appellant committed the current offense of fifth-degree possession of a controlled substance. At that time, the offense was a felony offense. In September 2016, when Appellant was sentenced, the Legislature had reclassified fifth-degree possession of a controlled substance to a gross misdemeanor under certain circumstances. The district court counted the 2007 conviction as a felony in calculating Appellant’s criminal history score. On appeal, Appellant argued that defendants can receive felony criminal history points only for prior felony convictions that are still classified as such at the time of sentencing. The court of appeals disagreed. The Supreme Court affirmed, holding that Appellant’s prior offense was still a felony at the time he committed the current offense, and therefore, Appellant properly received a felony criminal history point. View "State v. Scovel" on Justia Law

The Supreme Court held that a warrantless narcotics-dog sniff in the hallway outside Defendant’s apartment did not violate Defendant’s right to be free from unreasonable searches under the Minnesota and United States Constitutions.A jury found Defendant guilty of first-degree and fifth-degree possession of a controlled substance and possession of a firearm by a prohibited person. The court of appeals reversed the convictions, concluding that the narcotics-dog sniff in the hallway immediately adjacent to Defendant’s apartment door was a search under the Fourth Amendment because it violated Defendant’s reasonable expectations of privacy and that the warrantless search of Defendant’s home was unreasonable. The Supreme Court reversed, holding (1) the police did not intrude upon the curtilage of Defendant’s apartment or his reasonable expectation of privacy when they conducted the dog sniff, and therefore, no Fourth Amendment search occurred; and (2) because the police were lawfully present in the hallway and had a reasonable suspicion of criminal activity, the dog sniff did not violate Minn. Const. art. I, section 10. View "State v. Edstrom" on Justia Law

The Supreme Court held that a statutory city does not have express authority under Minn. Stat. 462.358(2)(a) to condition approval of a subdivision application on the payment of an infrastructure charge for future road-improvement projects.Respondent submitted an application to the City of Woodbury for approval to subdivide and develop a parcel of land. The City conditioned approval of the subdivision application upon payment of a roadway charge. Respondent then brought this action against the City. The lower courts determined that the City lacked statutory authority to impose an infrastructure charge under section 462.358(2)(a). The Supreme Court affirmed, holding that the statute did not authorize the City’s infrastructure charge. View "Harstad v. City of Woodbury" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding Defendant’s conviction of fifth-degree criminal sexual conduct and indecent exposure for sending a picture of his genitals to a minor over Facebook Messenger, holding that Defendant’s simultaneous electronic communications with the minor were sufficient to support his convictions.To be convicted of either crime, Defendant had to exhibit or expose his genitals “in the presence of a minor.” On appeal, Defendant argued that he did not meet the “presence” requirement of the crimes for which he was convicted because he was not physically present with the victim and because he only sent a likeness of his genitals, rather than exposing his actual genitals. The court of appeals affirmed both convictions. The Supreme Court affirmed, holding that Defendant specifically chose to engage in near-simultaneous conversation with the victim and thus used technology to effectively enter the victim’s private room, and therefore, Defendant’s conduct met the statutory requirements to be convicted of the crimes. View "State v. Decker" on Justia Law

The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that Plaintiff’s injury “arose out of” her employment under the “increased-risk” test the Court applied in Dykhoff v. Xcel Energy, 840 N.W.2d 821 (Minn. 2013).Plaintiff, an employee of Relator, fell down a set of stairs as she was leaving work. The workers’ compensation judge held that the injury did not arise out of employment. The WCCA reversed, determining that the compensation judge applied the incorrect test to determine whether the stairs were hazardous and that the correct test was whether the stairs posed an “increased risk” as opposed to a “neutral risk.” Because the stairs alone increased Plaintiff’s risk of injury, the WCCA concluded that her injury arose out of her employment. The Supreme Court affirmed, holding (1) an injury arises out of employment when there is a causal connection between the injury and the employment; and (2) applying that rule, there was a causal connection between Plaintiff’s injury on the stairway and her employment. View "Roller-Dick v. CentraCare Health System" on Justia Law