Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court held that Minn. Stat. 609.344(1)(b) and 609.345(1)(b), which prohibit sexual penetration and sexual conduct where the complainant is between thirteen and sixteen years of age and the actor is more than two years older than the complainant, are constitutional even though they prevented Defendant from asserting a mistake-of-age defense.The statutes at issue provide a mistake-of-age defense but only to actors who are no more than 120 months older than the complainant. On appeal, the court of appeals held that the statutes did not violate the guarantees of substantive due process and equal protection under the federal and state constitutions and did not unconstitutionally impose strict liability. The Supreme Court affirmed, holding (1) sections 2609.344(1)(b) and 609.345(1)(b) do not violate substantive due process or equal protection by limiting a mistake-of-age defense to defendants who are no more than 120 months older than the complainant; and (2) the statutes do not impose strict liability but, instead, require proof beyond a reasonable doubt that the actor had a general intent to engage in sexual penetration or sexual contact with the complainant. View "State v. Holloway" on Justia Law

The Supreme Court held that a “school zone,” as defined by Minn. Stat. 152.01(14)(a), includes the entire area of a city block that is situated kitty-corner to school property when the land surrounding the school property is organized in a city-block system.Appellant was convicted of second-degree sale of a controlled substance in a school zone. Appellant filed a petition for postconviction relief arguing that the State had failed to prove that the drug sale at Appellant’s home occurred within 300 feet of school property and, therefore, did not prove that the sale occurred in a school zone. The postconviction court denied the petition, concluding that the entire area of Appellant’s block was included in the school zone. The court of appeals affirmed. The Supreme Court affirmed, holding (1) when the area surrounding school property is organized in a city-block system, as in this case, the school zone, as defined in section 152.01(14)(a)(2), includes the entire area of a city block that is kitty-corner to the school property; and (2) the evidence was sufficient to prove the school-zone element of second-degree sale of a controlled substance in a school zone. View "Lapenotiere v. State" on Justia Law

At issue was whether a former employee’s (Employee) delay in returning his employer’s (Employer) property excused Employer from paying a commission otherwise due to Employee.The district court concluded that a return-of-property clause in the parties’ employment contract was a condition precedent to Employer’s contractual obligation to pay the residual commission, and therefore, Employer was excused from its obligation to pay that commission. The court of appeals applied Restatement (Second) of Contracts 229 and reversed, determining that a loss of the commission would cause a “disproportionate forfeiture." Therefore, the court held that Employee’s failure immediately to return Employer’s property was excused as a matter of law.The Supreme Court affirmed in part and reversed in part, holding (1) because section 229 reflects this Court’s reluctance to enforce forfeitures, the court of appeals properly looked to it for guidance in resolving this case; but (2) on this record, the materiality and proportionality analysis contemplated by section 229 should not be resolved as a matter of law on appeal, and therefore, a remand is necessary. View "Capistrant v. Lifetouch National School Studios, Inc." on Justia Law

The Supreme Court held that separation-of-powers principles do not prevent the judiciary from ruling on whether the Legislature has violated its duty under the Education Clause of the Minnesota Constitution or violated the Equal Protection or Due Process Clauses of the Minnesota Constitution.Appellants brought a putative class-action complaint on behalf of their children, public school students, claiming that the State had violated the Education, Equal Protection, and Due Process Clauses of the Minnesota Constitution. The court of appeals concluded that the claims presented nonjusticiable political questions. The Supreme Court reversed,holding that Appellants’ claims were justiciable.Specifically, the Court held (1) the courts are the appropriate domain for determinations as to whether the Legislature has violated its constitutional duty under the Education Clause; and (2) as to Appellants’ equal protection and due process claims, while the Legislature plays a critical role in education, “it is ultimately the judiciary’s responsibility to determine what our constitution requires and whether the Legislature has fulfilled its constitutional duty.” View "Cruz-Guzman v. State" on Justia Law