Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court discharged the writ of certiorari sought by Guardian Energy and dismissed the appeal in this case, holding that the order appealed from was not a final order at the time Guardian petitioned for a writ of certiorari, and therefore, this Court lacked jurisdiction.In 2015, the Supreme Court remanded this case to the tax court, concluding that the tax court's external-obsolescence calculations in valuating Guardian's property were not reasonably supported by the records. Before judgment was entered on the tax court's new order entered in 2016, Waseca County filed a motion requesting correction of computational errors made by the tax court through amended findings. Thereafter, the tax court stayed entry of judgment. Before the tax court ruled on the County's motion, Guardian sought review of the tax court's order. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the County's unresolved motion and the tax court's stay of entry of judgment rendered the 2016 order not final. Therefore, this Court lacked jurisdiction over Guardian's appeal. View "Guardian Energy, LLC, Relator v. County of Waseca" on Justia Law

The Supreme Court affirmed the decision of the post conviction court denying Appellant's motion to correct his sentence, holding that because Minn. Stat. 609.185 does not require a sentence of life imprisonment with the possibility of release, Appellant's sentence under Minn. Stat. 609.106(2)(1), which requires life in prison without the possibility of release, was authorized by law.Appellant was convicted of first-degree murder of a peace officer engaged in official duties and sentenced to life imprisonment without the possibility of release under section 609.106(2)(1). Appellant later moved to correct this sentence, asking that he be resentenced to life with the possibility of release rather than life without the possibility of release. The postconviction court denied the motion. The Supreme Court affirmed, holding that release is not possible when a sentence is imposed under section 609.106(2)(1) for a conviction under section 609.185(a)(4). View "Evans v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals dismissing the Minnesota Department of Natural Resource's (DNR) appeal of an order of the Chippewa/Swift Joint Board of Commissioners (Board) reestablishing the records for a public drainage system pursuant to Minn. Stat. 103E.101(4)(a), holding that the Board's order was a quasi-judicial decision subject to certiorari review.In dismissing the appeal, the court of appeals held that the order reestablishing records was not a quasi-judicial decision subject to certiorari review because the order was not a binding decision regarding the disputed claim but, rather, a preliminary step in a repair process. The Supreme Court disagreed, holding that record-reestablishment orders are final and binding and are therefore quasi-judicial decisions subject to quasi-judicial review. View "Minnesota Department of Natural Resources v. Chippewa/Swift Joint Board of Commissioners" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the order of the district court vacating the order of the Chief Administrative Law Judge (ALJ) that approved an annexation of certain property by the City of Proctor, holding that an orderly annexation agreement does not limit the authority of non-parties to the agreement to annex by ordinance property subject to the agreement.The City of Duluth and Midway Township entered into an orderly annexation agreement pursuant to Minn. Stat. 414.0325 regarding designated property in Midway and governing future annexations of that property by Duluth. Later, the owners of some of the designated property petitioned Proctor, a non-party to the agreement, to annex their property by ordinance pursuant to Minn. Stat. 414.033. Proctor did so, enacting an ordinance to that effect. The Chief ALJ issued a decision ruling that Proctor's annexation by ordinance was valid. The district court vacated the ALJ's decision, holding that Minn. Stat. 414.0325(1)(e) prevents annexations-by-ordinance of property within a designated area. The court of appeals reversed. The Supreme Court affirmed, holding that orderly annexation agreements created under section 414.0325 do not prevent non-parties from annexing property by ordinance under section 414.033. View "In re Annexation of Certain Real Property to the City of Proctor from Midway Township" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment for Respondent on Appellant's complaint alleging that Respondent failed to engage in an interactive process to determine reasonable accommodations for her disability before Respondent ended her employment, holding that genuine factual disputes existed that precluded summary judgment.Appellant brought this action under the Minnesota Human Right Act, Minn. Stat. 363A.01-.44, that included a claim for failure to accommodate her disability. Respondent argued that no interactive process was required under the Act, and regardless, Appellant could not perform the essential functions of her position and continuing her employment posed a serious threat to her health. The Supreme Court reversed the district court's grant of summary judgment for Respondent, holding (1) the Act does not mandate an interactive process; but (2) it was error to grant summary judgment for Respondent because genuine factual disputes existed regarding the essential functions of Appellant's employment and Respondent's defense that there was a "serious threat to the health or safety" of Appellant. View "McBee v. Team Industries, Inc." on Justia Law