Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed and remanded in part the postconviction court’s denial of Petitioner’s second petition for postconviction relief without holding an evidentiary hearing.Petitioner was found guilty of first-degree premeditated murder and sentenced to life in prison without the possibility of release. After his first postconviction petition was summarily denied, Petitioner filed his second postconviction petition, alleging the existence of sixteen pieces of newly discovered evidence. The postconviction court denied the second petition without holding an evidentiary hearing, concluding that the petition was untimely because the facts alleged in the petition did not satisfy the statutory newly-discovered-evidence exception. The Supreme Court reversed in part, holding (1) the postconviction court abused its discretion by making improper credibility determinations without holding an evidentiary hearing; and (2) the facts alleged in support of Petitioner’s remaining claims did not satisfy the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Petitioner’s petition for postconviction relief, holding that the postconviction court did not abuse its discretion.Petitioner was found guilty of first-degree premeditated murder and first-degree felony murder. Petitioner was sentenced to life imprisonment without the possibility of release for the murder conviction. The Supreme Court affirmed. Petitioner later filed a petition for postconviction relief, alleging six grounds for postconviction relief. The postconviction court rejected the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Petitioner’s claims were either procedurally barred or failed as a matter of law. View "Fox v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the district court’s grant of partial summary judgment in favor of Father on Son’s personal injury suit, holding that the Recreational-Use Statute, Minn. Stat. 604A.20-.27, did not apply to the facts of this case.Son was injured after he fell from a deer stand on Father’s property. The district court ruled that Father was entitled to recreational-use immunity, which allowed Son to proceed to trial to seek recovery under the trespasser exception to the statute. Based solely on the trespasser theory, the jury concluded that Son was ninety-five percent negligent. The court of appeals remanded the case for a new trial, holding that because Father did not offer his land for use by the public, the Recreational-Use Statute did not apply. The Supreme Court affirmed, holding that where the usage of Father’s property was limited to immediate family, section 604A.22 did not apply to this case because the land was not offered for public use. View "Ouradnik v. Ouradnik" on Justia Law

At issue was the proper method for calculating the quantum meruit value of an attorney’s services when a client terminates the contingent-fee agreement before a matter concludes.Respondent retained Appellant-law firm under a contingent-fee agreement to assist with asbestos litigation. Two months before settling a claim upon which Appellant had worked for about ten years, Respondent discharged Appellant. The district court dismissed Appellant’s attempt to recover a portion of the settlement funds, concluding that Appellant failed to prove the value of the services that it had provided. The court of appeals reversed, holding that the district court applied the incorrect test for determining quantum meruit. The Supreme Court affirmed as modified, holding (1) district courts should use eight factors to determine the quantum meruit value of a discharged contingent-fee attorney’s services; and (2) a remand was necessary so that the district court may consider the contingent-fee argument between the parties, in addition to the other relevant factors identified herein. View "Faricy Law Firm, P.A. v. API, Inc. Asbestos Settlement Trust" on Justia Law

The Supreme Court affirmed Appellant’s conviction of two counts of first-degree premeditated murder for the shooting deaths of his long-time girlfriend and his girlfriend’s fifteen-year-old daughter.On appeal, Appellant argued that the State failed to present sufficient to establish premeditation and that the district court erred by declining to instruct the jury on first-degree heat-of-passion manslaughter. The Supreme Court disagreed, holding (1) there was sufficient evidence presented at trial to sustain Defendant’s convictions; and (2) Appellant was not prejudiced by the district court’s decision not to instruct the jury on first-degree heat-of-passion manslaughter. View "State v. Galvan" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the district court concluding that a grain-handling contract between the parties in this case that was to “continue indefinitely” was perpetual in duration, not indefinite, and therefore not terminable at will.Chippewa Valley Ethanol Company, LLLP (CVEC) sought to end its contract with Glacial Plains Cooperative on the ground that it was a contract of indefinite duration, terminable at will be either party. The district court ruled in favor of Glacial Plains, finding that CVEC had wrongfully terminated the grain-handling contract. The court of appeals affirmed, ruling that the intent of the parties should prevail over the general rule that contract without definite duration are terminable at will upon reasonable notice. The Supreme Court reversed and remanded for further proceedings, holding (1) the parties’ contract was one of indefinite duration and was therefore terminable at will by either party upon reasonable notice after a reasonable time as passed; and (2) it is for the district court to weigh the evidence and apply the law to determine whether a reasonable time has passed such that the contract may be terminated at will with reasonable notice. View "Glacial Plains Cooperative v. Chippewa Valley Ethanol Co." on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree murder, holding that any error in the admission into evidence of testimony from Defendant’s physicians and a burn expert did not substantially influence the verdict.During trial, the district court ruled that Defendant waived his medical privilege. On appeal, Defendant argued that the admission of information from his medical records and the testimony from his treating physicians was erroneous and prejudicial. The Supreme Court held (1) Defendant forfeited review of the admission of the medical records; and (2) even if the district court’s admission of the medical information was erroneous, Defendant was not entitled to relief under the plain error standard because he did not demonstrate that the admission of the evidence affected his substantial rights. View "State v. Vasquez" on Justia Law

The Supreme Judicial Court affirmed the district court’s summary denial of Appellant’s ninth petition for postconviction relief, holding that Appellant’s petition was time barred or otherwise rested upon a meritless legal theory.Appellant was convicted of first- and second-degree murder. Thirty years later, Appellant filed the instant petition for postconviction relief, arguing that he was actually innocent because the forensic scientist was unable to match his DNA profile to the male DNA found on the victim’s body. The district court summarily denied the petition, determining that lab reports did not establish Appellant’s actual innocence. The Supreme Judicial Court affirmed, holding that the district court did not abuse its discretion by summarily denying Appellant’s petition for postconviction relief without holding an evidentiary hearing. View "Wayne v. State" on Justia Law

The common law governs provisions of an antenuptial agreement that do not fall within the safe harbor of Minn. Stat. 519.11(1), and the multifactor Kinney test is the common-law test applicable to antenuptial agreements. See In re Estate of Kinney, 733 N.W.2d 118 (Minn. 2007).Wife petitioned for dissolution and moved to set aside the antenuptial agreement she signed just before her marriage. The district court invalidated the agreement, concluding that it was procedurally unfair because Wife did not have an adequate opportunity to meet with legal counsel of her own choice and that it was substantively unfair and the time it was made and executed. The court of appeals affirmed on different grounds, concluding (1) to the extent the district court relied on Minn. Stat. 519.11 for evaluating procedural fairness, the court erred; (2) agreements that purport to distribute marital property, such as the agreement in this case, must be evaluated under the common law; and (3) the agreement was procedurally unfair. The Supreme Court affirmed after applying the Kinney factors to the entire agreement, holding that this agreement did not satisfy the common law test for procedurally fairness, and therefore, the agreement was invalid and unenforceable. View "Kremer v. Kremer" on Justia Law

In a proceeding to terminate parental rights that is governed by the Indian Child Welfare Act (ICWA) and the Minnesota Indian Family Preservation Act (MIFPA), qualified expert witness testimony is required to support the determination that continued custody of the child by the parent is likely to result in serious emotional or physical damage to the child.The district court terminated the parental rights of Mother and Father, concluding that ICWA and MIFPA applied to the proceedings and that the laws’ requirements had been satisfied. The court of appeals reversed in part, holding that the district court erred in failing expressly to find under ICWA and MIFPA that continued custody of the child by the parent was likely to result in serious emotional or physical damage to the child. On appeal, the district court stated as much in a one-sentence addendum to its findings of fact and conclusions of law. The court of appeals affirmed the district court’s termination decision. The Supreme Court reversed in part, holding that the district court erred in terminating Father’s parental rights because the qualified expert witness’s testimony did not support the court’s determination that continued custody of the children by Father would likely result in serious damage to the children. View "In re Welfare of Children of S.R.K. & O.A.K." on Justia Law