Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed a postconviction order that summarily denied Appellant’s public-trial claim on the grounds that the claim was barred by the rule announced in State v. Knaffla, 243 N.W.2d 737 (Minn. 1976).Appellant was convicted of one count of first-degree murder and two counts of attempted first-degree murder. During trial, the district court required spectators to present photographic identification before entering the courtroom. In his petition for postconviction relief Appellant asserted that the photographic-identification rule denied him his right to a public trial provided by the federal and state constitutions and that his appellate counsel was ineffective for not seeking a stay to expand the record regarding the courtroom “closure.” Relying on the rule announced in Knaffla, the postconvcition court summarily denied the petition for postconviction relief. The Supreme Court affirmed, holding (1) because Appellant’s public-trial claim was raised by Appellant and rejected by the Supreme Court on direct appeal, the postconviction court properly concluded that Knaffla barred the claim; and (2) Appellant forfeited appellate review of his argument that the interests-of-justice exception applied in his case. View "Taylor v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers’ Compensation Court of Appeals (WCCA) upholding the decision of the compensation judge ordering that Atlas Staffing, Inc. and its insurer, Meadowbrook Claims Services, pay workers’ compensation benefits to Anthony Gist. The compensation judge found that Gist’s exposure to silica, a known cause of end stage renal disease (ESRD), during his employment with Atlas was a substantial contributing factor to his kidney disease.In the consolidated appeals brought by Appellants and Fresenius Medical Care, which treated Gist after Appellants denied coverage and accepted payments from Medicaid and Medicare for the costs of that treatment, the Supreme Court held (1) the compensation judge did not abuse her discretion by relying on a certain medical report to find that work-related silica exposure was a substantial contributing factor to Gist’s kidney failure; (2) under 42 C.F.R. 447.15, a provider cannot recover payment from third parties for any services billed to Medicaid after the provider has accepted payment from Medicaid for those services; and (3) the WCCA erred when it dismissed Fresenius’s cross-appeal as untimely. View "Gist v. Atlas Staffing, Inc." on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder and his sentence of life in prison without the possibility of release.The State in this case initially filed a complaint charging defendant with second-degree intentional murder. Defendant attempted to plead guilty to the charge, but the district court refused to accept the plea when it learned that the State had amended its complaint to charge first-degree premeditated murder. Contrary to Defendant’s arguments on appeal, the Supreme Court held (1) the district court did not abuse its discretion under the circumstances of this case when it did not accept Defendant’s straight guilty plea to second-degree intentional murder; and (2) sufficient evidence supported the district court’s conclusion of law that the State proved premeditation beyond a reasonable doubt. View "State v. Petersen" on Justia Law

The “actual notice” provision of the Civil Damages Act, see Minn. Stat. 340A.802(2), popularly known as the Dram Shop Act, requires actual notice of sufficient facts to put a liquor licensee on inquiry notice of a possible claim, not actual notice of a possible claim. In addition, the statute’s plain language does not require notice of certain indispensable facts but, rather, requires notice only of “sufficient facts.” Lastly, actual notice to a licensee’s liquor-liability attorney is notice to the licensee under section 340A.802(2).Appellants brought claims against Respondent, a liquor licensee, under the Civil Damages Act for damages arising out of the death of Mary Jo Meyer-Buskey in an automobile accident caused by a drunk driver. The district court granted summary judgment for Respondent, finding that Appellants failed to provide timely notice of their claims and that the correspondence of Appellants’ attorney with Respondent’s liquor-liability attorney did not qualify as “actual notice” under section 340A.802(2). The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred in granting summary judgment to Respondent. View "Buskey v. American Legion Post #270" on Justia Law

Law enforcement officers did not violate Defendant’s Fifth Amendment privilege against self-incrimination when, after Defendant invoked his privilege against self-incrimination, they later asked him if he was willing to sign a written consent to the taking of a DNA sample and explained to him why they sought the sample.Defendant was charged with possession of a firearm by an ineligible person and possession of a short-barreled shotgun. Defendant filed a motion to suppress DNA evidence and his admission that he had handled the shotgun, claiming that the officers conducted a second custodial interrogation after he had invoked his privilege against self-incrimination. The district court denied the motion. The Supreme Court affirmed, holding that the officers did not violate Defendant’s constitutional privilege against self-incrimination because, although Defendant’s statements that he had already handled the shotgun were incriminating testimonial communications, none of the officers’ actions were reasonably likely to elicit an incriminating testimonial communication. Therefore, a Miranda warning was not required. View "State v. Heinonen" on Justia Law

In this case regarding the determination of the tax court valuing Minnesota Energy Resources Corporation’s (MERC) natural gas pipeline distribution system for the years 2008 through 2012, the Supreme Court affirmed the decision of the tax court on remand, holding that the tax court followed the Court’s instructions on remand and properly applied the Court’s clarified standard to MERC’s claim of external obsolescence. On remand, the tax court found that MERC failed to demonstrate that external obsolescence affected the value of its property. The Supreme Court affirmed, holding (1) the tax court correctly evaluated whether MERC’s evidence of external obsolescence was credible, reliable, and relevant; and (2) the tax court’s decision was justified by the evidence and in conformity with law. View "Minnesota Energy Resources Corp. v. Commissioner of Revenue" on Justia Law

In this case where a petitioner’s former attorneys appealed an order of the district court dismissing a postconviction petition as moot following the death of the petitioner, the Supreme Court dismissed the appeal, holding that the attorneys did not have standing to seek review of the district court’s order.Here, Petitioner died after filing an amended petition for postconviction relief. The district court granted the State’s motion to dismiss, concluding that the petition was technically moot due to Petitioner’s death and that the significant-public-interest exception to the mootness doctrine was not satisfied. Petitioner’s former attorneys appealed. The Supreme Court held that it lacked appellate jurisdiction and dismissed the appeal because the attorneys, whose attorney-client relationship with Petitioner terminated on his death and who were not aggrieved parties themselves, lacked standing. View "Glaze v. State" on Justia Law

A district court “participates” in a plea bargaining negotiation (see State v. Johnson, 156 N.W.2d 218 (Minn. 1968) when it provides unsolicited comments regarding the propriety of the parties’ competing settlement offers. When a defendant successfully challenges the validity of a guilty plea because of the district court’s participation, the plea is only invalid if it was involuntary under the totality of the circumstances.The district court in Appellant’s case made unsolicited comments about the propriety of the parties’ competing settlement offers before the parties reached an agreement for the court to accept or reject. Appellant later filed a petition for postconviction relief alleging that the court’s participation in the plea negotiations made her plea invalid and required a remedy of automatic plea vacated. The postconviction court disagreed and denied relief. The court of appeals affirmed. Because the law in existence at the time Appellant filed her postconviction petition did not require a defendant to establish that her guilty plea was involuntary, the Supreme Court reversed and remanded to the district court to give Appellant an opportunity to amend her postconviction petition in light of the holdings announced today. View "Wheeler v. State" on Justia Law

A seller’s fraudulent statements about the fitness of a vehicle for the purpose for which it was purchased make disclaimers in purchase documents stating that the buyer purchased the vehicle “as is” ineffective.The district court in this case awarded relief to the buyer on both fraud and breach of warranty theories. The Supreme Court affirmed, holding (1) the buyer’s fraudulent statements about the fitness of the vehicle being sold for the purpose for which the vehicle was purchased made the “as is” disclaimers of implied warranties in the purchase documents ineffective under Minn. Stat. 336.2-316(3)(a); and (2) under the Uniform Commercial Code, a party may seek remedies for fraud, including breach of warranty, even after the rescission of a purchase contract, and therefore, the district court did not err in awarding damages under both fraud and breach of an implied warranty theories of liability. View "Sorchaga v. Ride Auto, LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court’s denial of Father’s request for additional parenting time to provide before- and after-school child care for the parties’ son, K.T., while Mother was working.The parties stipulated to joint legal and physical custody with equal parenting time, and the district court approved the parenting time. Ten days later, Father filed a motion for additional parenting time to provide child care for K.T. before and after school on Mother’s parenting days. The district court denied the request. Father appealed, arguing that the district court based its decision on irrelevant or repealed factors and that the district court erred by failing to make detailed findings on the newly amended best-interest factors listed in Minn. Stat. 518.17(1)(a). The court of appeals affirmed. The Supreme Court affirmed, holding (1) parenting time modifications under Minn. Stat. 518.175(8) do not require the same detailed, specific findings that an order establishing custody or parenting time now requires; and (2) the district court did not rely on factors that were either repealed or irrelevant. View "Hansen v. Todnem" on Justia Law