Justia Minnesota Supreme Court Opinion Summaries

In a complaint seeking an injunction for breach of contract, the district court was not required to find irreparable harm based solely on the language of a private agreement and did not abuse its discretion by declining to grant an injunction in light of the absence of evidence of irreparable harm.St. Jude Medical sued Heath Carter and Boston Scientific Corporation after Carter left his job at St. Jude to work for Boston Scientific, alleging that Carter had violated his employment agreement with St. Jude. The agreement stated that if Carter breached its terms, St. Judge would suffer irreparable injury, and St. Jude would be entitled to an injunction against Carter and his new employer because St. Jude’s remedy at law for damages would be inadequate. The district court concluded that St. Jude was not entitled to an injunction because, although Carter breached the agreement, St. Jude failed to demonstrate that it would suffer irreparable harm from that breach. The court of appeals reversed, ruling that the district court erred by failing to consider the terms of the agreement when deciding whether to enjoin Carter. The Supreme Court reversed, holding that the district court was not required to exercise its equitable authority simply by reason of the contract language. View "St. Jude Medical, Inc. v. Carter" on Justia Law

The Supreme Court has applied the rule of contra proferentem - “a doctrine that ambiguities in a contract are to be construed unfavorably against the drafter” - only after an attempt is made to determine the parties’ intent behind an ambiguous term, and only if a preponderance of the evidence does not prove the parties’ intent should the jury construe ambiguous terms against the drafter.In this breach of contract case, the district court instructed the jury to determine whether two contracts were ambiguous and, if so, to both determine the intent of the parties and construe ambiguous terms against the drafter. The court of appeals reversed and remanded for a new trial, determining that the canon of contra proferentem was to be applied only after the evidence failed to reveal the mutual intent of the parties. The Supreme Court held that the jury instruction in this case materially misstated the law twice by directing the jury to (1) determine whether the contracts at issue were ambiguous, rather than instructing the jury that the contracts were ambiguous; and (2) both determine the intent of the parties and construe ambiguous terms against the drafter without specifying which task must be completed first. View "Staffing Specifix, Inc. v. TempWorks Management Services, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals declaring the City of Rochester’s competitive bidding process and the resulting contract awarded to First Transit invalid.The City owned a fleet of buses operated by First Transit, Inc. since 2012. Until 2012, those buses were operated by Rochester City Lines Company (RCL). In the instant case, RCL challenged the City’s competitive bidding process, which resulted in the bus operation contract being awarded to First Transit. The City’s appointed moderator rejected RCL’s protest. The court of appeals, however, ruled that the City’s request for proposals (RFP) appeared impermissibly biased against RCL. The Supreme Court reversed and remanded the case, holding that RCL forfeited any appearance-of-bias argument. View "Rochester City Lines Co. v. First Transit, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals declaring the City of Rochester’s competitive bidding process and the resulting contract awarded to First Transit invalid.The City owned a fleet of buses operated by First Transit, Inc. since 2012. Until 2012, those buses were operated by Rochester City Lines Company (RCL). In the instant case, RCL challenged the City’s competitive bidding process, which resulted in the bus operation contract being awarded to First Transit. The City’s appointed moderator rejected RCL’s protest. The court of appeals, however, ruled that the City’s request for proposals (RFP) appeared impermissibly biased against RCL. The Supreme Court reversed and remanded the case, holding that RCL forfeited any appearance-of-bias argument. View "Rochester City Lines Co. v. First Transit, Inc." on Justia Law

State law did not preempt a proposal to amend the charter of the City of Bloomington to require voter approval before the City can implement organized collection of solid waste.Appellants petitioned the City for a ballot initiative seeking the enactment of an ordinance that would require voter approval before the City could implement organized waste collection. The City declined to place Appellants’ proposed amendment on a ballot on the ground that Minn. Stat. 115A.94 preempted the field of regulation by the process by which a city organizes waste collection. The district court granted summary judgment for the City. The court of appeals affirmed. The Supreme Court reversed, holding (1) the legislature did not intend to occupy the field of regulation of the process of organizing collection of solid waste; and (2) therefore, Appellants’ proposed charter amendment was not preempted by state law. View "Jennissen v. City of Bloomington" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the district court’s denial of Father’s motion to increase his parenting time to every other week, holding that Father’s proposed modification was a de facto motion to modify physical custody, and therefore, the endangerment standard applied.Father had parenting time every other weekend with his minor child, and, during summer months, the parties alternated weeks with the child. When Father brought a motion to expand the alternating week schedule to the entire year the district court treated the motion as a motion to modify physical custody. The court applied the endangerment standard in Minn. Stat. 518.18(d)(iv) and, finding that Father did not present a prima facie case of endangerment, denied the motion. The court of appeals reversed, holding that Father’s motion was no a motion to modify custody. The Supreme Court reversed, holding that Father’s motion was a substantial change that would modify the parties’ custody arrangement. View "Christensen v. Healey" on Justia Law

The Supreme Court affirmed the decision of the court of appeals interpreting Minn. Rev. Stat. 524.3-101 to allow real property to devolve immediately upon a testator’s death to a residual devisee.Plaintiff, in her capacity as personal representative to her father’s estate, sued Defendants to quiet title to residential property owned by her father at his death. Plaintiff’s brother, John, conveyed his interest in the property by quitclaim deed to Minnesota Premier Properties a few days after Wells Fargo bought the foreclosed property at a sheriff’s sale after the decedent’s death. The district court granted summary judgment to Plaintiff, concluding that John did not have an interest to convey to Premier through the quitclaim deed. The court of appeals reversed, holding that, under section 524.3-10, a valid, transferable ownership interest in real property devolves immediately upon a testator’s death to a person to whom the property is devised by the testator’s will. The Supreme Court affirmed, holding that the court of appeals did not err in interpreting the statute. View "Laymon v. Minnesota Premier Properties, LLC" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the postconviction court’s denial of Petitioner’s second petition for postconviction relief without holding an evidentiary hearing.Petitioner was found guilty of first-degree premeditated murder and sentenced to life in prison without the possibility of release. After his first postconviction petition was summarily denied, Petitioner filed his second postconviction petition, alleging the existence of sixteen pieces of newly discovered evidence. The postconviction court denied the second petition without holding an evidentiary hearing, concluding that the petition was untimely because the facts alleged in the petition did not satisfy the statutory newly-discovered-evidence exception. The Supreme Court reversed in part, holding (1) the postconviction court abused its discretion by making improper credibility determinations without holding an evidentiary hearing; and (2) the facts alleged in support of Petitioner’s remaining claims did not satisfy the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Petitioner’s petition for postconviction relief, holding that the postconviction court did not abuse its discretion.Petitioner was found guilty of first-degree premeditated murder and first-degree felony murder. Petitioner was sentenced to life imprisonment without the possibility of release for the murder conviction. The Supreme Court affirmed. Petitioner later filed a petition for postconviction relief, alleging six grounds for postconviction relief. The postconviction court rejected the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Petitioner’s claims were either procedurally barred or failed as a matter of law. View "Fox v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the district court’s grant of partial summary judgment in favor of Father on Son’s personal injury suit, holding that the Recreational-Use Statute, Minn. Stat. 604A.20-.27, did not apply to the facts of this case.Son was injured after he fell from a deer stand on Father’s property. The district court ruled that Father was entitled to recreational-use immunity, which allowed Son to proceed to trial to seek recovery under the trespasser exception to the statute. Based solely on the trespasser theory, the jury concluded that Son was ninety-five percent negligent. The court of appeals remanded the case for a new trial, holding that because Father did not offer his land for use by the public, the Recreational-Use Statute did not apply. The Supreme Court affirmed, holding that where the usage of Father’s property was limited to immediate family, section 604A.22 did not apply to this case because the land was not offered for public use. View "Ouradnik v. Ouradnik" on Justia Law