Justia Minnesota Supreme Court Opinion Summaries

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

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