Justia Minnesota Supreme Court Opinion Summaries

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

Failing to register is a continuing crime that includes the entire range of dates on which Defendant failed to register in this case, and a jury was not required to find the date of Defendant’s current offense.Defendant was convicted of knowingly failing to register as a predatory offender. Under the Minnesota Sentencing Guidelines, prior felony sentences are used to calculate criminal history scores unless a period of fifteen years has elapsed between “the date of the current offense” and the expiration of the prior felony sentence (see Minn. Stat. 243.166). Defendant argued that “the date of the current offense” for his crime was the last day the offense occurred and that a jury must decide that date. The court of appeals concluded that “the date of the current offense,” which is a continuing offense, is the first day the offense occurs. The Supreme Court affirmed, holding (1) the district court did not err in including Defendant’s 1996 felony conviction in his criminal history score because fifteen years had not elapsed between the expiration of Defendant’s sentence for his 1996 conviction and the start of his current offense; and (2) Defendant’s sentence did not violate his Sixth Amendment right to a jury trial under Blakely v. Washington, 542 U.S. 296 (2004). View "State v. Washington" on Justia Law

The warrantless search of Defendant’s property violated Defendant’s Fourth Amendment rights in this case.Here, an officer entered Defendant’s property, examined a stolen camper trailer and then, after obtaining Defendant’s consent, searched Defendant’s home. Defendant filed a motion to suppress, arguing that the officer’s examination of the camper was unconstitutional and tainted his subsequent consent to the search of his home. The district court denied the motion to suppress, concluding that because the camper was on a driveway that was impliedly open to the public, the officer’s entry onto Defendant’s property was lawful and that the officer had authority to seize the camper under the plain-view doctrine. The court of appeals reversed. The Supreme Court affirmed, holding (1) the camper was located on property that was afforded the constitutional protections of the home; and (2) the officer’s conduct was beyond the objectively reasonable scope of any implied license to enter Defendant’s property, and therefore, the warrantless search violated Defendant’s Fourth Amendment rights. View "State v. Chute" on Justia Law