Justia Minnesota Supreme Court Opinion Summaries

At issue was whether State v. Her, 862 N.W.2d 692 (Minn. 2015), applies retroactively to sentences that were imposed and became final before Her was decided. In Her, the Supreme Court ruled that the fact that a defendant was a risk-level-III offender at the time of the offense of failing to register as a predatory offender must be admitted by the defendant or found by a jury beyond a reasonable doubt before a court may impose a ten-year period of conditional release as part of the defendant’s sentence. The district court in this case granted Respondent’s motion to correct his sentence, concluding that Respondent’s ten-year conditional-release term was illegal because Her applied to the sentence. The Supreme Court reversed, holding that Her announced a new rule of constitutional criminal procedure that does not apply to the collateral review of Respondent’s sentence. View "State v. Meger" on Justia Law

The part of Minnesota’s disorderly-conduct statute that prohibits “disturb[ing]” assemblies or meetings, Minn. Stat. 609.72(1)(2), violates the First Amendment.Defendant was convicted of disorderly conduct under section 609.72(1)(2) after a jury trial. On appeal, Defendant argued that the statute violates the First Amendment because it is unconstitutionally overbroad, unconstitutionally vague, and unconstitutional as applied. The court of appeals affirmed, concluding that the constitute was constitutional and was not subject to standard overbreadth analysis. The Supreme Court reversed, holding that the statute suffers from substantial overbreadth and that there is no reasonable narrowing construction of the statute. View "State v. Hensel" on Justia Law

The deadline for an appeal in a juvenile protection proceeding is based on the district court’s service of notice by mail. In this case, because the appeal was filed by that deadline, the court of appeals erred in dismissing the appeal as untimely. Here, the district court terminated L.A.’s parental rights after allegations were made that L.A. was in need of protection or services. L.A. filed a notice of appeal. The court of appeals dismissed the appeal as untimely. The Supreme Court vacated the opinion of the court of appeals, holding that L.A.'s appeal was timely filed because nothing in the plain language of the rules told him that he could not rely on the service upon him by mail when calculating the deadline for filing his appeal. View "In re Welfare of Child of R.K." on Justia Law

An individual may commit motor vehicle theft without moving the vehicle.Defendant was charged with theft of a motor vehicle under Minn. Stat. 609.52(2)(a)(17) even though he never moved the vehicle. The district court dismissed the charge for lack of probable cause, concluding that the word “takes” in the statute required Defendant to move the vehicle. The court of appeals affirmed the dismissal of the motor vehicle theft charge due to the absence of any evidence that Defendant moved the vehicle at issue. The Supreme Court reversed, holding that to “take” a motor vehicle under section 609.52(2)(a)(17), an individual must only adversely possess it. View "State v. Thonesavanh" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the court of appeals’ reversal of the district court’s grant of Company’s motion to dismiss Shareholder’s class action challenge to a merger transaction. The district court concluded (1) some claims were derivative, rather than direct, and were therefore subject to the demand and pleading requirements of Minn. R. Civ. P. 23.09; and (2) Shareholder failed to comply with Rule 23.09. The court of appeals reversed with the exception of one claim, concluding that most of the claims were direct, and therefore, Rule 23.09 did not apply. The Supreme Court clarified the test for distinguishing between direct and derivative claims and held that the district court did not err in dismissing some claims but erred in dismissing others. View "In re Medtronic, Inc. Shareholder Litigation" on Justia Law

The Supreme Court affirmed Defendant’s conviction, rendered after a jury trial, of first-degree premeditated murder on an accomplice-liability theory. The court held (1) the district court did not commit clear error by denying Defendant’s Batson objection to the State’s peremptory challenge to exclude a black prospective juror trial because Defendant failed to establish a prima facie case of racial discrimination; and (2) the district court did not abuse its discretion or violate Defendant’s right to present a complete defense by refusing to allow Defendant to develop an alternative theory to explain why the murder weapon was found in a storage unit rented to an alleged accomplice. View "State v. Wilson" on Justia Law

The Supreme Court affirmed the sentence imposed by the district court for Defendant’s convictions for third- and fourth-degree criminal sexual conduct on an accomplice-liability theory. The district court granted Defendant’s motion for a downward dispositional departure, stayed execution of a 140-month sentence for fifteen years, and required Defendant to comply with several probationary conditions. The court of appeals affirmed, concluding that an offender’s minor or passive role is an adequate reason for a downward dispositional departure and that the record supported the district court’s finding that Defendant played a minor or passive role in the third- and fourth-degree criminal sexual conduct. The Supreme Court affirmed, holding that the district court did not abuse its discretion by finding that Defendant’s minor or passive role in the offense was a substantial and compelling reason to depart from the Minnesota Sentencing Guidelines. View "State v. Stempfley" on Justia Law

The court of appeals reversed the jury verdict for Appellant and awarded Respondent’s request to tax costs and disbursements for the appeal. Most of the award was for the interest that Respondent incurred on a loan that it obtained to enable it to post a supersedes bond, which was used to secure the judgment on the jury’s verdict during the appeal. Appellant sought review of the court of appeals’ taxation decision, arguing that the interest was not taxable on appeal. The Supreme Court granted a writ of prohibition and reversed the court of appeals’ decision to allow taxation of borrowing costs, holding that Minn. R. Civ. App. P. 139 does not permit the taxation of borrowing costs under the circumstances of this case. View "Klapmeier vs. Cirrus Industries, Inc." on Justia Law

The 2013 amendment to the Minnesota Whistleblower Act defining the term “good faith” eliminated the judicially created requirement that the putative whistleblower act with the purpose of “exposing an illegality.”Appellant filed a complaint in the United States District Court for the District of Minnesota alleging that Employer wrongfully terminated his employment in violation of the Minnesota Whistleblower Act. Employer argued in response that Defendant’s conduct was not protected under the Act. Employer based this argument on the Supreme Court’s interpretation of the Act in Obst v. Microtron, Inc., 614 N.W.2d 196, 202 (Minn. 2000), in which the court held that “good faith” requires a putative whistleblower to act with the purpose of “exposing an illegality.” Appellant argued in response that Obst is no longer good law following a 2013 amendment to the Act that defines “good faith” to mean “conduct that does not violate section 181.932, subdivision 3.” The district court certified the question to the Supreme Court as to whether the 2013 amendment abrogated the Supreme Court’s prior interpretation of “good faith.” The Supreme Court answered the certified question in the affirmative. View "United States District Court, District of Minnesota v. Edwards Lifesciences, LLC" on Justia Law

The Supreme Court affirmed the Workers’ Compensation Court of Appeals’ (WCCA) reversal of the compensation judge’s dismissal of Respondent’s request for benefits under the Minnesota Workers’ Compensation Act (Minnesota Act).At the time of his injury, Respondent was performing longshoreman work. The compensation judge concluded that the Longshore and Harbor Workers’ Compensation Act provided Respondent’s exclusive remedy and that the case should be dismissed under the doctrine of forum non conveniens. The WCCA reversed, determining that the compensation judge’s dismissal for lack of jurisdiction was contrary to law and that the compensation judge lacked authority to dismiss Plaintiff’s claims under the doctrine of forum non conveniens. The Supreme Court affirmed, holding that the compensation judge had jurisdiction to hear Respondent’s claims brought under the Minnesota Act and that the judge abused his discretion by dismissing Respondent’s claims under the doctrine of forum non conveniens. View "Ansello v. Wisconsin Central, Ltd." on Justia Law