Justia Minnesota Supreme Court Opinion Summaries

The limited right to counsel recognized in Friedman v. Commissioner of Public Safety, 473 N.W. 2d 828 (Minn. 1991), applies only to implied-consent cases.The district court in this case suppressed the results of a urine sample provided by Defendant at a jail after his arrest for driving while impaired (DWI) because the sheriff’s deputy, when asking Defendant if he would consent to urine testing, failed to read the implied-consent advisory that would have advised Defendant of his right to counsel. The court concluded that, by failing to read the advisory, the deputy failed to allow Defendant to vindicate his right to counsel prior to testing. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the officer did not read the implied-consent advisory in this case, under Friedman, the limited right to counsel was not triggered; and (2) therefore, the district court erred in suppressing the urine test results on that ground. View "State v. Hunn" on Justia Law

The clear-and-convincing standard applies when determining the existence of an oral contract for the conveyance of farmland when only money damages are sought for the claimed breach of that contract.Plaintiff argued that the Estates of his parents were obligated under an oral contract for the sale of land to convey farm property to him. After a second trial, the jury found by a preponderance of the evidence that an oral contract existed between Plaintiff and his parents and awarded Plaintiff damages for the breach of that contract. The Estates moved for judgment as a matter of law and a new trial, arguing that the district court instructed the jury on the incorrect standard of proof. The district court denied the motion. The court of appeals affirmed. The Supreme Court reversed and remanded the matter to the district court for a new trial, holding (1) the clear and convincing evidence is required to prove that an oral contract for the sale of land existed, regardless of whether the party seeks damages or specific performance; and (2) therefore, the district abused its discretion in denying Plaintiff’s motion for a new trial. View "Christie v. Estate of Dilman Christie" on Justia Law

Claims brought against the manufacturer of a component part of an improvement to real property fell under an exception to the ten-year statute of repose because the improvement was “machinery installed upon real property.” See Minn. Stat. 541.051.Appellant manufactured the motor in a home’s heat-recovery ventilator. Sixteen years after the ventilator was installed, a fire started in the ventilator, causing property damage to the home. Respondent, the insurer of the homeowners, brought this subrogation action against Appellant. The district court granted summary judgment for Appellant, concluding that the ten-year statute of response for improvements to real property barred every claim except the claim alleging a post-sale duty to warn, which claim it dismissed upon summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) under the plain language of section 541.051, the ventilator containing Appellant’s motor was “machinery installed upon real property,” and therefore, the court of appeals properly reinstated Respondent’s breach of warranty, negligence, and product liability claims; and (2) Appellant did not have a duty to warn consumers of its product’s alleged defect after the time of sale. View "Great Northern Insurance Co. v. Honeywell International, Inc." on Justia Law

Claims brought against the manufacturer of a component part of an improvement to real property fell under an exception to the ten-year statute of repose because the improvement was “machinery installed upon real property.” See Minn. Stat. 541.051.Appellant manufactured the motor in a home’s heat-recovery ventilator. Sixteen years after the ventilator was installed, a fire started in the ventilator, causing property damage to the home. Respondent, the insurer of the homeowners, brought this subrogation action against Appellant. The district court granted summary judgment for Appellant, concluding that the ten-year statute of response for improvements to real property barred every claim except the claim alleging a post-sale duty to warn, which claim it dismissed upon summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) under the plain language of section 541.051, the ventilator containing Appellant’s motor was “machinery installed upon real property,” and therefore, the court of appeals properly reinstated Respondent’s breach of warranty, negligence, and product liability claims; and (2) Appellant did not have a duty to warn consumers of its product’s alleged defect after the time of sale. View "Great Northern Insurance Co. v. Honeywell International, Inc." on Justia Law

The Supreme Court reversed the decisions of the court of appeals and district court that Respondent’s due process rights were violated when he was read an inaccurate implied consent advisory after his arrest on suspicion of driving while impaired.Respondent refused to submit to either a urine or a blood test. Thereafter, the Commissioner of Public Safety revoked Respondent’s driver’s license for refusing to submit to a test. Relying on McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991), the district court rescinded the revocation after finding that the implied consent advisory violated Respondent’s due process rights because it incorrectly stated that refusal to submit to a urine test was a crime. The court of appeals affirmed on the basis that the threat of legally impossible criminal charges for refusal to submit to a urine test violated due process. The Supreme Court reversed, holding that because Respondent did not rely on the implied consent advisory to his detriment, and instead refused to submit to testing, no due process violation occurred under McDonnell. View "Johnson v. Commissioner of Public Safety" on Justia Law

Appellant failed to establish that he was prejudiced by the implied consent advisory read to him after he was arrested on suspicion of driving while impaired, and therefore, Appellant was not entitled to a rescission of his license revocation under McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991).Appellant submitted to a blood test, and the test results showed an alcohol concentration above the legal limit. Appellant’s driver’s license was subsequently revoked. The district court sustained the revocation on the basis that Appellant voluntarily consented to the blood test. The Supreme Court affirmed, holding that Appellant was not entitled to a rescission of his license revocation under McDonnell because he did not even claim, much less establish, that he prejudicially relied on the implied consent advisory. View "Morehouse v. Commissioner of Public Safety" on Justia Law

A defendant who files a motion under Minn. R. Crim. P. 27.03, subd. 9 to correct a sentence after the time for direct appeal has passed bears the burden to prove the sentence was based on an incorrect criminal history score.The Supreme Court affirmed the judgments of the district courts denying Appellant’s motions to correct his sentence under Minn. R. Crim. P. 27.03(9), which Appellant filed after the time to file a direct appeal had expired. In his motions, Appellant argued that two Minnesota district courts miscalculated his criminal history score because those courts treated his two Illinois drug-related convictions as felonies. The court of appeals affirmed the denial of the motions. The Supreme Court affirmed, holding that Appellant had the burden to prove that the Illinois convictions were improperly included in his criminal history score and that Appellant failed to meet this burden. View "Williams v. State" on Justia Law

At issue was whether an indemnity clause in a rental agreement required the renter to indemnify the rental company for the rental company’s negligence.The Tower Tap & Restaurant entered into an agreement to rent folding picnic tables from London Road Rental Center, Inc. for an event. Plaintiff injured his hip at Tower Tap’s event after one of the rented tables collapsed on him. Plaintiff sued Tower Tap and London Road. London Road filed a cross-claim against Tower Tap, seeking contractual indemnity based on the indemnity clause in the rental agreement. The district court granted summary judgment to London Road, concluding that the clause unequivocally covered liability for London Road’s own negligence. The court of appeals affirmed. The Supreme Court reversed, holding that the indemnity clause did not include express language that clearly and unequivocally showed the parties’ intent to transfer such liability to Tower Tap. View "Dewitt v. London Road Rental Center, Inc." on Justia Law

The legislative amendments to the State Auditor’s responsibilities over audits of Minnesota counties do not violate either the Separation of Powers Clause, Minn. Const. art. III, 1 or the Single Subject Clause, Minn. Const. art. IV, 17.In 2015, a new statute was enacted that governed the State Auditor’s county-audit responsibilities. The statute allowed counties to choose to have the required audit performed by either a Certified Public Accounting (CPA) firm or the State Auditor. The State Auditor brought this suit arguing that the statute violated the Minnesota Constitution. The district court concluded that the legislative modification of the State Auditor’s duties was constitutional. The court of appeals affirmed. The Supreme Court affirmed, holding that the State’s Auditor’s challenges under the Separation of Powers Clause and the Single Subject Clause failed. View "Otto v. Wright County" on Justia Law

At issue was whether Hennepin County properly refused to comply with part of Appellant’s government-data request under the Minnesota Government Data Practices Act (the Data Practices Act).The Supreme Court held (1) there was substantial evidence in the record to support the Administrative Law Judge’s (ALJ) conclusion that Hennepin County’s established procedures do not “insure” appropriate and prompt responses to requests for government data under the Data Practices Act; (2) there was not substantial evidence in the record to support the ALJ’s conclusion that the County did not maintain records containing government data in an arrangement and condition making them easily accessible for convenient use in violation of the Data Practices Act; and (3) the Court did not have appellate jurisdiction to decide whether Appellant’s request was valid or whether the County may refuse to comply with a request that the County deems “unduly burdensome.” View "Webster v. Hennepin County" on Justia Law