Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court determining that Appellant was not entitled to custody credit against her Minnesota sentence for time spent in the custody of the Red Lake Nation, holding that Appellant was not entitled to custody credit against her Minnesota sentence for the time she spent in Red Lake custody because her Minnesota conviction was not the sole reason for her Red Lake custody.In 2011, Appellant was convicted of third-degree controlled-substance crime in Beltrami County District Court. The district court stayed imposition of Appellant's sentence and placed her on probation. In 2017, while she was still on probation, Appellant was convicted of two gross misdemeanors in Red Lake Tribal Court. After serving her sentence in the Red Lake Detention Center Appellant was released directly to Beltrami County because the district court had revoked her stay. The district court concluded that Appellant was not entitled to custody credit for her incarceration time in the Red Lake Detention Center. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant was not entitled to custody credit against her Minnesota sentence for the time she spent in Red Lake custody. View "State v. Roy" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to strike for lack of probable cause count 3, domestic assault with intent to cause fear in another of immediate bodily harm, which was charged as a felony under Minn. Stat. 609.2242, subd. 4, holding that the unambiguous language of the statute supported the felony charges.In moving to strike count 3, Defendant argued that using his previous convictions to enhance count 3 to a felony was inconsistent with Minn. Stat. 609.035, which prohibits multiple punishments for the same course of conduct. The district court granted the motion. The court of appeals reversed, concluding that section 609.035 did not prohibit enhancement under subdivision 4. The Supreme Court affirmed, holding that the domestic abuse charges against Defendant qualified for the enhancement provided by subdivision 4. View "State v. Defatte" on Justia Law

The Supreme Court reversed the decision of the Commissioner of Human Services determining that RS Eden, a supervised living facility where J.W. received treatment before voluntarily leaving and dying of a drug overdose five days later, was responsible for maltreatment of J.W. by neglect, holding that the Commission's decision was not supported by substantial evidence.RS Eden appealed the maltreatment determination to the court of appeals, which affirmed. The Supreme Court reversed, holding that that Commissioner's finding of maltreatment for neglect for RS Eden's failure to obtain a waiver or to confer with a prescribing physicians was not supported by substantial evidence because RS Eden complied with the rules regarding the disposition of controlled substances and took reasonable steps to protect its client. View "In re Appeal by RS Eden" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree premeditated murder but reversed Defendant's conviction for second-degree intentional murder, holding that the district court improperly entered a conviction on both first-degree and second-degree murder.Specifically, the Court held (1) the district court did not abuse its discretion by admitting the recorded statement of an eyewitness under Minn. R. Evid. 807 even after the witness partially recanted the statement at trial; (2) the district court did not abuse its discretion by admitting the evidence of the contents of a backpack linking Appellant to items that went missing with the murder weapon; (3) the district court erred by entering a conviction for both first-degree and second-degree murder because second-degree intentional murder is a lesser-included offense of first-degree premeditated murder; and (4) none of Appellant's pro se claims had merit. View "State v. Hallmark" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction of burglary in the first degree and criminal sexual conduct in the fourth degree on the ground that the district court's failure to sua sponte instruct the jurors on the proper use of Minn. Stat. 634.20 relationship evidence was plain error, holding that the relevant law was unsettled at the time of appellate review, and therefore, Defendant failed to establish an error that was plain.At trial, the district court admitted section 634.20 evidence without sua sponge instructing the jurors on the proper use of that evidence. The court of appeals reversed due to the district court's failure to sua sponte instruct the jurors as such. The Supreme Court reversed, holding (1) for trials held after the release of this opinion, the rule that when a district court admits relationship evidence under Minn. Stat. 634.20 over a defendant's objection that the evidence does not satisfy section 634.20, the court must sua sponte instruct the jurors on the proper use of such evidence unless the defendant objects to the instruction by the court is hereby adopted; and (2) the district court's failure to give such an instruction was not an error that was plain. View "State v. Zinski" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court summarily denying Appellant's claims for ineffective assistance of trial and appellate counsel without holding an evidentiary hearing, holding that Appellant's claims were barred by the relevant statute of limitations.Appellant was convicted of first-degree premeditated murder under an aiding-and-abetting theory of liability. The district court imposed a sentence of life without the possibility of release. Appellant later filed his postconviction petition requesting an evidentiary hearing on his claims for ineffective assistance of trial and appellate counsel and mentioning a motion for testing conducted under Minn. Stat. 590.01, subd. 1a. The postconviction court concluded that Appellant's claims were barred by the two-year statute of limitations, Minn. Stat. 590.01, subd. 4. The Supreme Court affirmed, holding (1) Appellant's claims were barred by the two-year statute of limitations; and (2) Appellant's reference to testing did not satisfy the requirements of subdivision 1a. View "Jackson v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Appellant's consecutive sentences, holding that consecutive sentences for Appellant's offenses were a departure for which the district court had to provide written reasons, and in the absence of those written reasons, Appellant's consecutive sentences were unauthorized by law.Appellant filed a motion to correct his consecutive sentences under Minn. R. Crim. P. 27.03, subd. 9. The district court construed the motion as a petition for postconviction relief, which it denied as untimely. The court of appeals reversed the determination that Appellant's motion must be construed as a postconviction petition but affirmed the consecutive sentences. The Supreme Court reversed. On remand, the district court modified Appellant's sentences to run concurrently. The court of appeals affirmed in part and reversed in part. The Supreme Court held (1) Minn. R. Crim. P. 29.04, subd. 6 does not allow the State to argue, without seeking review, that the court of appeals erroneously reversed the district court's determination that construed Appellant's motion as a postconviction petition; and (2) Appellant's consecutive sentences were unauthorized by law because they were an upward departure from the presumptive sentence under the applicable version of the guidelines and the district court failed to give any reason justifying the departure. View "Bilbro v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court's grant of judgment on the pleadings to the State on Appellant's claims alleging false imprisonment and negligence, holding that the conditional release imposed under Minn. Stat. 169A.276, subd. 1(d), unambiguously begins when a Challenge Incarceration Program participant enters phase II of the program and begins living in the community.Appellant, a participant in the Challenge Incarceration Program administered by the Department of Corrections, brought this action arguing that the State failed correctly to calculate his conditional-release term and revoked his conditional release improperly after it had already ended. Specifically, Appellant argued that he was "released from prison" within the meaning of section 169A.276, subd. 1(d) when he entered phase II of that program. The district court granted the State's motion for judgment on the pleadings. The court of appeals affirmed. The Supreme Court reversed, holding that the conditional-release term imposed by section 169A.276, subd. 1(d), begins when a participant in the Challenge Incarceration Program begins living in the community. View "Heilman v. Courtney" on Justia Law

The Supreme Court reversed the conclusion of the Workers' Compensation Court of Appeals that the medical treatment parameters established under the Workers' Compensation Act do not apply when an employer contests its obligation under the Act to pay for an employee's particular medical treatment.Employee sought workers' compensation benefits for a work injury. Employer paid a lump sum and agreed to pay ongoing medical expenses that were reasonably required to cure and relieve Employee's symptoms. Employer paid for Employee's medical treatment until it determined that Employee's current treatment was no longer reasonable or necessary. Employee then filed a workers' compensation medical request seeking payment to cover the cost of his medications. Employer denied the request. A workers' compensation judge ordered Employer to pay for Employee's medications and treatment, holding that the treatment parameters did not apply to Employee's claim. The Workers' Compensation Court of Appeals affirmed. The Supreme Court reversed, holding (1) the ban on applying the treatment parameters in Minnesota Rule 5221.6020, subpart 2, applies only when an employer denies that it has an obligation under the Act to pay compensation for an alleged workplace injury; and (2) the workers' compensation tribunals erred in concluding that the treatment parameters did not apply to Employee's course of treatment. View "Johnson v. Darchuks Fabrication, Inc." on Justia Law

The Supreme Court reversed the judgments of the lower courts that, as a matter of law, a hospitalist owed no duty of care to a patient seeking to be admitted because no physician-patient relationship had been established, holding that there was sufficient evidence in the record to survive a summary judgment motion.A hospitalist denied a patient admission, and, three days later, the patient died. Plaintiff filed a professional negligence suit against the hospitalist and the hospital. The district court granted summary judgment for Defendants on the issue of duty, concluding that the relationship between the patient and the hospitalist did not create a doctor-patient relationship. The court of appeals affirmed. The Supreme Court reversed after noting that a physician-patient relationship is not a necessary element of a claim for professional negligence, holding (1) a physician owes a duty of care to a third party when the physician acts in a professional capacity and it is reasonably foreseeable that the third party will rely on the physician's acts and be harmed by a breach of the standard of care; and (2) it was reasonably foreseeable that the patient in this case would rely on the hospitalist's acts and be harmed by a breach of the standard of care. View "Warren v. Dinter" on Justia Law