Justia Minnesota Supreme Court Opinion Summaries

At issue was whether a former employee’s (Employee) delay in returning his employer’s (Employer) property excused Employer from paying a commission otherwise due to Employee.The district court concluded that a return-of-property clause in the parties’ employment contract was a condition precedent to Employer’s contractual obligation to pay the residual commission, and therefore, Employer was excused from its obligation to pay that commission. The court of appeals applied Restatement (Second) of Contracts 229 and reversed, determining that a loss of the commission would cause a “disproportionate forfeiture." Therefore, the court held that Employee’s failure immediately to return Employer’s property was excused as a matter of law.The Supreme Court affirmed in part and reversed in part, holding (1) because section 229 reflects this Court’s reluctance to enforce forfeitures, the court of appeals properly looked to it for guidance in resolving this case; but (2) on this record, the materiality and proportionality analysis contemplated by section 229 should not be resolved as a matter of law on appeal, and therefore, a remand is necessary. View "Capistrant v. Lifetouch National School Studios, Inc." on Justia Law

The Supreme Court held that separation-of-powers principles do not prevent the judiciary from ruling on whether the Legislature has violated its duty under the Education Clause of the Minnesota Constitution or violated the Equal Protection or Due Process Clauses of the Minnesota Constitution.Appellants brought a putative class-action complaint on behalf of their children, public school students, claiming that the State had violated the Education, Equal Protection, and Due Process Clauses of the Minnesota Constitution. The court of appeals concluded that the claims presented nonjusticiable political questions. The Supreme Court reversed,holding that Appellants’ claims were justiciable.Specifically, the Court held (1) the courts are the appropriate domain for determinations as to whether the Legislature has violated its constitutional duty under the Education Clause; and (2) as to Appellants’ equal protection and due process claims, while the Legislature plays a critical role in education, “it is ultimately the judiciary’s responsibility to determine what our constitution requires and whether the Legislature has fulfilled its constitutional duty.” View "Cruz-Guzman v. State" on Justia Law

The Supreme Court held that the tax court lacked jurisdiction to consider a motion filed in a case arising from a tax petition that was automatically dismissed by operation of law.Ronald and Dee Johnson challenged the County’s assessment of their property taxes. The County automatically dismissed the petition by operation of law because the Johnsons had not paid a portion of their property taxes by the date required by law. The tax court declined to consider the Johnsons’ motion regarding their petition because the petition had been automatically dismissed by statute and had not been reinstated. The Supreme Court affirmed, holding that the tax court correctly concluded that it no longer had jurisdiction over the dismissed petition.Specifically, the Court held (1) the requirements of Minn. Stat. 783.03(1) were met; and (2) the Johnsons’ arguments challenging the constitutionality of section 278.03(1) were without merit. View "Johnson v. County of Hennepin" on Justia Law

The Supreme Court affirmed Appellant’s conviction for first- and second-degree murder on an aiding-and-abetting theory. The Court held (1) even if it was error for the district court to admit into evidence Appellant’s statement to police, the error was harmless beyond a reasonable doubt; (2) the district court plainly erred by giving a no-adverse-inference instruction to the jury without Appellant’s consent, but the error was not prejudicial; and (3) assuming, without deciding, that the prosecutor committed misconduct during closing argument by “indirectly alluding” to Appellant’s failure to testify, the prosecutor’s argument was not prejudicial. View "State v. Johnson" on Justia Law

The tax court correctly dismissed the appeals brought by several cooperatives (the Cooperatives) challenging the valuation orders of the Commissioner of Revenue for the 2014, 2015, and 2016 tax years because the appeals were not filed within the sixty-day deadline for appeals from orders of the Commissioner.On appeal, the Cooperatives argued that the two appeal paths provided by Minn. Stat. 273.372(2) effectively establish the single deadline of April 30 of the year in which the tax becomes payable. The Supreme Court disagreed, holding (1) the Cooperatives’ view that a single filing deadline governs all appeals under section 273.372 fails because the plain language of that statute establishes two different filing deadlines, depending on the appeal path chosen; and (2) the Cooperatives’ notices of appeal were governed only by a sixty-day deadline, and therefore, the tax court properly dismissed the appeals as untimely. View "Lake Country Power Cooperative v. Commissioner of Revenue" on Justia Law

The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that the compensation judge failed fully to consider the extent to which each of Respondent’s employers sought to shift liability to the other employer and that it was error to deny Respondent’s motion for fees under Minn. Stat. 176.191(1).In 2015, Respondent filed a workers’ compensation claim for work-related aggravations to a low-back condition resulting from a work-related injury in 2009. Between the 2009 injury and later aggravations sustained in 2014 and 2015, Respondent’s employer and its insurer changed. When Respondent sought benefits for later aggravations sustained in 2014 and 2015, her 2009-employer and her new employer disputed whether the aggravations were a continuation of the 2009 injury or subsequent injuries for which the new employer and its insurer were liable. The compensation judge held the new employer liable for reasonable benefits for the later injuries but denied Respondent’s claim for fees under section 176.191(1). The WCCA reversed the denial of the motion for fees. The Supreme Court affirmed, holding that the efforts by each employer to shift responsibility to the other employer greatly increased the burden on Respondent’s counsel to provide effective representation, and therefore, Respondent was entitled to receive reasonable attorney fees under the statute. View "Hufnagel v. Deer River Health Care Center" on Justia Law

The Supreme Court held that the forfeiture-of-office provision of the Minnesota Open Meeting Law, under which pubic officials who violate the Open Meeting Law may be removed from office, requires three separate, serial adjudications, other than three concurrently filed actions alleging separate, intentional Open Meeting Law violations.Under Minn. Stat. 13D.06(3), the forfeiture-of-office provision of the Open Meeting Law, Minn. Stat. 13D.01-.07, if public officials are found to have intentionally violated the statute “in three or more actions” they may be removed from office. Residents of the City of Victoria successfully proved that certain officials, collectively, committed thirty-eight Open Meeting Law provisions. These violations were found after a single trial resulting from consolidation of five separate lawsuits filed by the residents. The district court declined to remove the officials from office, concluding that three separate adjudications were required. The Supreme Court affirmed, holding that the forfeiture-of-office provision is not triggered unless three separate, sequential adjudications result in findings of three separate, unrelated Open Meeting Law violations. View "Funk v. O’Connor" on Justia Law

The Supreme Court held that four irrevocable inter vivos trusts (the Trusts) lacked sufficient relevant contacts with Minnesota during the relevant tax year to be permissibly taxed, consistent with due process, on all sources of income as “resident trusts.”The Trusts filed their 2014 Minnesota income tax returns under protest, asserting that Minn. Stat. 290.01(7b)(a)(2), the statute classifying them as resident trusts, was unconstitutional as applied to them. The Trusts sought refunds for the difference between taxation as resident trusts and taxation as non-resident trusts. The Commissioner of Revenue denied the refund claims. The Minnesota Tax Court granted summary judgment for the Trusts, holding that the statutory definition of “resident trust” violates the Due Process Clauses of the Minnesota and United States Constitutions as applied to the Trusts. The Supreme Court affirmed, holding that, for due process purposes, the State lacked sufficient contacts with the Trusts to support taxation of the Trusts’ entire income as residents. View "Fielding v. Commissioner of Revenue" on Justia Law

The Supreme Court affirmed the decision of the Minnesota Tax Court affirming the order of the Commissioner of Revenue that assessed Terrance Sargent’s income tax liability for tax years 2010-2014, holding that Sargent’s arguments on appeal were without merit.On appeal, Sargent argued that Minnesota’s income tax violates the Minnesota Constitution and the United States Constitution on several grounds. The Supreme Court affirmed the Minnesota Tax Court's decision after considering all of Sargent’s arguments, holding that they each were without merit. View "Sargent v. Commissioner of Revenue" on Justia Law

The Commissioner of Revenue properly invoked her alternative-apportionment authority under Minn. Stat. 290.20(1) and applied an alternative apportionment method that fairly reflected the income of Associated Bank, N.A. and its affiliates (the Bank) allocable to Minnesota.The Bank, which included two LLC partnerships under Wisconsin law, objected to the Commissioner’s assessment of additional state corporate franchise tax liability for tax years 2007 and 2008. The Bank had calculated the tax owed based on the relevant statutes for apportioning income to Minnesota. The Commissioner found that applying the general apportionment formula to the LLCs did not “fairly reflect” the Bank’s “taxable net income allocable” to Minnesota. Accordingly, the Commissioner invoked her authority under section 290.20(1) and applied an alternative apportionment method to correct a distortion of reported income. After exhausting its administrative remedies, the Bank appealed to the tax court. Relying on the Supreme Court’s decision in HMN Financial, Inc. v. Commissioner of Revenue, 782 N.W.2d 558 (Minn. 2010), the tax court agreed and reversed the Commissioner’s order. The Supreme Court reversed, holding (1) HMN Financial is not dispositive; and (2) the Legislature plainly gave the Commissioner the authority to use an alternative apportionment method under the circumstances presented here. View "Associated Bank, N.A. v. Commissioner of Revenue" on Justia Law