Justia Minnesota Supreme Court Opinion Summaries

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

In this family dispute over real estate ownership resulting in a land partition action the Supreme Court reversed the decision of the court of appeals affirming the district court's order finding Appellant in contempt for failure to pay sand and gravel royalties, holding that a party who acquired a royalty interest through a stipulated judgment may not enforce that interest by post judgment discovery and a contempt motion.The land partition action was settled and judgment was issued based on a stipulated settlement by the parties. As part of the settlement, Respondent agreed to convey a gravel pit to Appellant, reserving a one-seventh interest in sand and gravel royalties. Under the settlement and resulting judgment, Appellant was required to pay for these royalties and sign releases allowing Respondent to contact gravel purchasers for verification purposes. The district court later found Appellant in contempt for failure to pay royalties but allowed Appellant to purge the contempt finding by, inter alia, paying Respondent's attorney fees. The court of appeals affirmed. The Supreme Court reversed, holding (1) because the parties' stipulated judgment created an interest in land and not a judgment debt, postjudgment discovery was not permitted; and (2) the district court erred in holding Appellant in contempt and ordering payment of attorney fees. View "Sehlstrom v. Sehlstrom" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant’s first-degree burglary conviction, holding that the victim must be physically present during the burglary for a conviction under Minn. Stat. 609.582(1)(b).Section 609.582(1)(b) elevates burglary to a first-degree offense if “the burglar possesses, when entering or at any time while in the building,….any article used or fashioned in a manner to lead the victim to reasonably believe it to be a dangerous weapon.” On appeal, Defendant argued that because the victim was not physically present during the burglary, the evidence was not sufficient to support his conviction. The court of appeals affirmed. The Supreme Court reversed, holding that section 609.582(1)(b) requires the victim to be physically present during the burglary. View "State v. Rogers" on Justia Law

In this first-degree murder case the Supreme Court affirmed the judgment of the district court summarily denying Appellant’s second and third petitions for postconviction relief, holding that Appellant was conclusively entitled to no relief.In his petitions, Appellant alleged, among other things, that two of the State’s witnesses recanted, that he was denied his right to confront the witnesses against him, and that he was denied his right to self-representation. The postconviction court denied the petitions without a hearing. The Supreme Court affirmed, holding that the district court did not abuse its discretion in summarily denying postconviction relief because five of Appellant’s claims were filed after the statute of limitations expired and the sixth was legally insufficient to entitle Appellant to a new trial. View "Reed v. State" on Justia Law

In this condemnation case, the Supreme Court affirmed the decision of the court of appeals reversing the district court’s award of $168,009 in attorney fees to the landowner under the condemnation fee-shifting statute, Minn. stat. 117.031(a), holding that the district court misinterpreted and misapplied the Court’s lodestar precedent.Using the lodestar method, the district court awarded the landowner the amount that he requested. The court of appeals reversed the award because the district court failed to begin its calculation with the presumptive lodestar amount of $34,133 and because the district court did not sufficiently explain why enhancing the presumptive lodestar amount by more than $130,000 would represent a reasonable fee. The Supreme Court affirmed, holding (1) under current Supreme Court law, an enhancement based on a contingent fee agreement is improper; and (2) the district court incorrectly applied the law and did not make adequate factual findings to support its enhanced attorney-fee award. View "State v. Krause" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals ruling that Minnesota’s vehicle forfeiture statute, Minn. Stat. 169A.63, is unconstitutional as applied to Helen and Megan Olson, holding that the statute is constitutional on its face and constitutional as applied to Megan but unconstitutional as applied to Helen.Megan was arrested for driving while impaired (DWI) and was subject to being charged with a first-degree DWI offense. Because a first-degree DWI offense is a “designated” offense under the DWI vehicle forfeiture statute, the vehicle Megan was driving when she was arrested - a 1999 Lexus owned by Megan’s mother Helen - was subject to forfeiture. The police seized the vehicle incident to Megan’s lawful arrest. The Olsons filed a demand for judicial determination of the forfeiture, arguing that section 169A.63(9)(d), which sets forth the procedural requirements for judicial hearings related to vehicle forfeiture for a DWI offense, violated their due process rights. The district court determined that the statute was unconstitutional on its face. The court of appeals affirmed on different grounds. The Supreme Court held that the statute was constitutional as applied to Megan, who did not own the vehicle, but unconstitutional as applied to Helen, the purportedly innocent owner. View "Olson v. One 1999 Lexus" on Justia Law