Justia Minnesota Supreme Court Opinion Summaries

Jamal L. Smith was convicted of first-degree intentional murder while committing a drive-by shooting, among other charges, for the fatal shooting of Jay Boughton during a road rage incident. Smith was driving a rented Chevrolet Suburban with two passengers from Chicago to Minnesota. During the trip, Smith brandished a pistol in a video, and later, the Suburban was involved in a road rage incident where Smith allegedly pointed a gun at another driver. On the night of the murder, Smith's Suburban paced Boughton's truck on the highway before a single .45-caliber bullet was fired from the Suburban, striking Boughton in the neck and causing his death.The Hennepin County District Court denied Smith's motion to dismiss the indictment based on the racial composition of the grand jury and admitted evidence of Smith's prior bad acts under the immediate episode exception. A jury found Smith guilty, and he was sentenced to life with the possibility of release for the murder charge and a concurrent sentence for possession of ammunition or a firearm after being convicted of a crime of violence. Smith appealed, arguing judicial bias, ineffective assistance of counsel, improper jury pool composition, erroneous admission of prior bad acts, and insufficient evidence to prove he fired the fatal shot.The Minnesota Supreme Court reviewed the case and found that Smith failed to demonstrate judicial bias or ineffective assistance of counsel. The court also held that Smith did not show that Black persons were underrepresented in the jury pool or that any underrepresentation resulted from systematic exclusion. The court ruled that the district court did not abuse its discretion in admitting evidence of Smith's prior bad acts, as it was admissible under the Spreigl exception or as direct or corroborative evidence of a charged crime. Finally, the court concluded that the only reasonable inference from the circumstances proved was that Smith fired the fatal shot. The court affirmed the judgment of convictions. View "State v. Smith" on Justia Law

David Hepfl and Jodine Meadowcroft had a complex romantic history, including two marriages and divorces. After their second divorce, they reconciled in 2016 and decided to build a cabin on Meadowcroft's property, which she had retained as nonmarital property. Hepfl paid for the construction and furnishing of the cabin, as well as additional structures like a dock and outhouse. Their relationship ended again in October 2020, and Meadowcroft obtained an Order for Protection (OFP) against Hepfl. Hepfl then filed a civil action alleging unjust enrichment to recover the cabin and its associated fixtures and furnishings or reasonable payment.The district court ruled in favor of Hepfl, concluding that Meadowcroft would be unjustly enriched if she retained the cabin and its associated items without compensating Hepfl. The court found that Hepfl had no intention of gifting the cabin to Meadowcroft and that his contributions were made with the expectation of shared use. Meadowcroft's motion for amended findings was denied, and she was ordered to pay Hepfl for the construction costs and return or compensate for the additional items.The Minnesota Court of Appeals affirmed the district court's decision, agreeing that Meadowcroft's retention of the cabin would result in unjust enrichment. The court noted that Hepfl's contributions were made with the expectation of shared use and that Meadowcroft's actions induced him to make these expenditures.The Minnesota Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that Hepfl did not need to show that Meadowcroft engaged in morally wrongful conduct to succeed in his unjust enrichment claim. Instead, it was sufficient that Meadowcroft's retention of the cabin and its associated items would be inequitable under the circumstances. The court emphasized that unjust enrichment claims between former partners in a cohabitating, marriage-like relationship should focus on the equities of the situation rather than the conduct of the parties. View "Hepfl v. Meadowcroft" on Justia Law

A state trooper brought his patrol vehicle to a car dealership for service, accompanied by his canine, Diesel. During the visit, Diesel attacked and injured an employee, Cristina Berrier, without provocation. Berrier suffered serious injuries and subsequently sued the Minnesota State Patrol, alleging negligence and later indicating her intention to pursue a claim under Minnesota’s strict liability dog-bite statute, Minn. Stat. § 347.22.The district court denied the State Patrol’s motion to dismiss, concluding that Berrier’s complaint sufficiently pleaded her statutory claim and that the dog-bite statute waived sovereign immunity. The State Patrol appealed, and the Minnesota Court of Appeals reversed, holding that the State Patrol was immune from suit under the doctrine of sovereign immunity. The appellate court did not address whether Berrier adequately pleaded her statutory dog-bite claim.The Minnesota Supreme Court reviewed the case to determine if the dog-bite statute waived sovereign immunity. The court concluded that the language of Minn. Stat. § 347.22, which imposes liability on the "owner" of a dog, was sufficiently plain, clear, and unmistakable to waive sovereign immunity. The court emphasized that the statute’s broad application to any dog owner, including state entities, served the public policy interest of protecting individuals from dog attacks and ensuring their full recovery. Consequently, the court reversed the appellate court’s decision and remanded the case for further proceedings. View "Hennesy vs. Minnesota State Patrol" on Justia Law

In December 2015, Sean Michael Wocelka’s daughter disclosed during a forensic interview that her father had touched her intimate parts using a toy giraffe. The incident occurred shortly before Christmas. Officers found the toy giraffe in Wocelka’s home, and he was charged with three counts of second-degree criminal sexual conduct. At trial, Wocelka’s daughter testified consistently with her initial statement. The jury found Wocelka guilty of two counts of second-degree criminal sexual conduct for the December 2015 incident.The district court convicted Wocelka of one count under Minnesota Statutes section 609.343, subdivision 1(a), which criminalizes sexual contact with a complainant under 13 years old by an actor more than 36 months older. Wocelka petitioned for postconviction relief, arguing that his conduct did not meet the statutory definition of “sexual contact.” The district court denied the petition as untimely and on the merits. The Minnesota Court of Appeals affirmed the district court’s decision on the merits without addressing the timeliness issue.The Minnesota Supreme Court reviewed the case to determine whether the use of an object to make contact with a complainant’s intimate parts constitutes “sexual contact” under Minnesota Statutes section 609.341, subdivision 11(a)(i). The court held that the term “touching” includes bringing an object into contact with the complainant’s intimate parts. Therefore, the court affirmed that Wocelka’s actions met the statutory definition of “sexual contact” and upheld his conviction for second-degree criminal sexual conduct. View "Wocelka vs. State of Minnesota" on Justia Law

Pedro and Aida Alonzo filed a personal injury lawsuit against Richard Menholt and Menholt Farms, alleging negligent selection of an independent contractor. The case arose from an accident where Alberto Lopez, a driver for Braaten Farms, crossed the centerline and collided with Pedro Alonzo's semi-truck, causing serious injuries. Lopez had a suspended license and a history of driving offenses. Menholt Farms had hired Braaten Farms to haul sugar beets, but neither Menholt Farms nor Braaten Farms conducted thorough background checks on Lopez.The district court granted summary judgment in favor of Menholt Farms, recognizing the tort of negligent selection of an independent contractor but finding no genuine issue of material fact regarding Menholt Farms's alleged negligence. The court concluded that Menholt Farms had no duty to inquire into Braaten Farms's hiring practices or Lopez's qualifications. The Minnesota Court of Appeals affirmed the district court's decision, holding that Minnesota does not recognize the claim and that, even if it did, no genuine issue of material fact existed.The Minnesota Supreme Court reviewed the case and recognized the tort of negligent selection of an independent contractor under Minnesota common law. The court noted that the tort is supported by the Restatement (Second) of Torts and is analogous to other recognized claims like negligent hiring. However, the court was evenly divided on whether the district court erred in granting summary judgment, leading to an affirmation of the lower court's decision by default. The court emphasized that the duty of care in selecting an independent contractor depends on the risk involved and the nature of the work, requiring a higher degree of care for more dangerous or specialized tasks. View "Alonzo vs. Menholt" on Justia Law

The case revolves around Harry Jerome Evans, who was convicted of first-degree murder of a peace officer in 2006. The officer, Sergeant Gerald Vick, was shot during an undercover investigation at a bar in Saint Paul. Evans was identified as the shooter by Sergeant Joseph Strong, who was with Vick at the time, and by a trial witness. Evans's cousin, A.K., also testified that Evans had shot Vick. Evans claimed that A.K. was the actual shooter and that Vick was not performing official duties at the time of the shooting due to his intoxication. Evans was sentenced to life in prison without the possibility of release.Evans appealed his conviction multiple times in both state and federal courts. His appeals were consistently denied, with courts rejecting his claims of ineffective assistance of counsel, prosecutorial misconduct, and allegations that A.K. had admitted to being the actual shooter. Evans also filed petitions for postconviction relief and motions to correct his sentence, all of which were denied.In the current petition, Evans sought postconviction relief, arguing that his petition met the newly-discovered-evidence and interests-of-justice exceptions to the statutory time bar. The district court denied the petition, concluding that the facts alleged in the petition did not meet either exception. Evans appealed this decision.The Minnesota Supreme Court affirmed the district court's decision. The court found that Evans's petition did not meet the requirements of the newly-discovered-evidence exception, as the evidence was either not new, not exonerating, or was known or knowable by Evans at the time of trial. The court also found that Evans's petition did not meet the requirements of the interests-of-justice exception, as Evans did not allege that an injustice prevented him from filing his petition in a timely manner. View "Evans vs. State" on Justia Law

The case revolves around a dispute over a family farm in Minnesota. Richard and Paulette Dunn entered into a contract for deed with their son, Rory, for the sale of their family farm. The contract stipulated that Rory could not sell, assign, or otherwise transfer his interest in the farm without the Dunns' written consent. However, Rory died two years later without a will, and his interest in the farm was transferred to his young son by intestate succession. Jeffrey Kuhn, the personal representative of Rory’s estate, intended to divide the property and sell a portion of the farm on the open market. The Dunns responded by cancelling the contract for deed, arguing that the intestate transfer of Rory’s interest to his son without their consent was a breach of the contract.The district court ruled in favor of the Dunns, stating that the intestate transfer of Rory’s interest in the farm violated the consent-to-transfer provision and materially breached the contract for deed. However, the court of appeals reversed this decision, concluding that the intestate transfer of Rory’s estate as a result of Rory’s inaction did not violate the consent-to-transfer provision.The Minnesota Supreme Court was asked to decide whether an intestate transfer of an interest in a family farm breaches a consent-to-transfer provision in a contract for deed. The court held that the intestate transfer of Rory’s interest in the farm violated the consent-to-transfer provision and that this violation was a material breach of the contract for deed. Therefore, the court reversed the decision of the court of appeals. View "Kuhn vs. Dunn" on Justia Law

The case involves Nicholas Sterry, an inmate at the Moose Lake Correctional Facility, who filed a lawsuit against the Minnesota Department of Corrections (DOC) and Correctional Officer Ashley Youngberg. Sterry alleged that Youngberg sexually assaulted and harassed him while he was working in the prison kitchen. The DOC was aware of Youngberg's history of harassment but had not disciplined her prior to the incidents involving Sterry. Sterry's lawsuit included claims of battery, intentional and negligent infliction of emotional distress, and negligence under a theory of vicarious liability.The district court dismissed Sterry's claims, concluding that the DOC was immune from the suit under the Minnesota State Tort Claims Act because Youngberg was not acting within the scope of her employment when the alleged assault occurred. Sterry appealed this decision, and the court of appeals reversed the district court's ruling. The court of appeals found that Sterry's complaint alleged sufficient facts to survive the motion to dismiss, as it was consistent with common law principles of vicarious liability applicable to private employers.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court held that a state employer could be held vicariously liable for an employee’s intentional tort under the Minnesota State Tort Claims Act if the tort is related to the duties of the employee and occurs within work-related limits of time and place. The court also found that Sterry's complaint alleged sufficient facts to survive the DOC's motion to dismiss. The court concluded that Sterry's claim could allow a jury to find that Youngberg was acting within the scope of her employment when the alleged assault occurred, under circumstances where the DOC would be liable under common law for vicarious liability. View "Sterry v. Minnesota Department of Corrections" on Justia Law

The case revolves around a dispute over attorney fees awarded under Minnesota Statutes section 117.031(a) in an eminent domain proceeding. The State of Minnesota, through the Department of Transportation (MnDOT), seized a portion of Joseph Hamlin's property under the "quick take" provision of Minnesota eminent domain law. Hamlin was awarded attorney fees after the compensation he received was more than 40% greater than MnDOT's final offer. The attorney fees awarded exceeded the amount Hamlin owed his attorney under a contingent fee agreement.MnDOT appealed the district court's decision, arguing that the term "reasonable" in section 117.031(a) should limit the attorney fee award to the amount owed in the contingent fee agreement. The district court had applied the lodestar method (a method for calculating attorney fees based on the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate) and awarded Hamlin $63,228 in attorney fees. The court of appeals affirmed the district court's decision, holding that "reasonable attorney fees" in section 117.031(a) are calculated under the lodestar method and are not limited by any existing agreement between the landowner and his attorney.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court reiterated its previous holding in County of Dakota v. Cameron that "reasonable attorney fees" in section 117.031(a) refers to attorney fees calculated by the lodestar method. Therefore, an award of reasonable attorney fees is not capped by a contingent fee agreement. The court concluded that a landowner's fee agreement with their attorney does not limit an award of attorney fees because "reasonable attorney fees" under section 117.031(a) means attorney fees calculated using the lodestar method. View "State v. Schaffer" on Justia Law

The case revolves around the appellant, McKinley Juner Phillips, who was convicted of first-degree premeditated murder and second-degree intentional murder for the stabbing death of his wife, Shavon Phillips. The appellant had conceded at trial that he caused the death of his wife but had requested that the jury be given instructions for first-degree heat-of-passion manslaughter in addition to the instructions for first-degree premeditated murder and second-degree intentional murder. The district court denied the requested instruction, reasoning that the evidence did not support a heat-of-passion instruction.The appellant appealed the district court's decision, arguing that the court committed reversible error by denying the requested instruction. The appellant's argument was based on the premise that the jury's finding of premeditation does not necessarily preclude a finding of heat-of-passion.The Minnesota Supreme Court, however, affirmed the district court's decision. The Supreme Court held that the appellant was not prejudiced by the district court’s decision not to instruct the jury on first-degree heat-of-passion manslaughter because the court gave instructions on both first-degree premeditated murder and second-degree intentional murder and the jury found the appellant guilty of first-degree premeditated murder. The court reasoned that the mental states of premeditation and heat of passion cannot coexist, and since the jury found the appellant guilty of premeditated murder, it would not have found him guilty of heat-of-passion manslaughter. View "Phillips v. State" on Justia Law