Justia Minnesota Supreme Court Opinion Summaries

A facsimile transmission is not a “delivery” under Minn. R. Civ. P. 3.01(c), which requires that a summons be “delivered” to the sheriff before an action is commenced, because Rule 3.01(c) contemplates personal delivery to the office of the sheriff.In this case, Plaintiff faxed a summons and complaint to the sheriffs in two counties. Deputy sheriffs from both counties personally served Defendants. Defendants moved to dismiss the action, arguing that facsimile transmission did not constitute “delivery” of the summons under Rule 3.01(c). The district court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding that the sheriffs completed service of process on each of the defendants, thus commencing Plaintiff’s action under Rule 3.01(a). View "Cox v. Mid-Minnesota Mutual Insurance Co." on Justia Law

The Supreme Court reversed the postconviction court’s summary denial of Appellant’s pro se petition for postconviction relief, in which Appellant argued that his trial counsel was ineffective and that the prosecutor improperly refused to renew her initial plea offer.Appellant was convicted of first-degree felony murder. After Appellant filed his pro se petition for postconviction relief, Appellant asked the postconviction court to appoint counsel. The postconviction court referred Appellant’s request for counsel to the state public defender, which declined to represent Appellant. The district court then denied Appellant’s postconviction petition without holding an evidentiary hearing. The Supreme Court reversed, holding (1) Appellant was entitled to an appointed attorney for postconviction proceedings because he did not have a “review” on direct appeal; and (2) therefore, the postconviction court erred in not granting Appellant’s request for counsel. View "State v. Eason" on Justia Law

The Supreme Court reversed the postconviction court’s summary denial of Appellant’s pro se petition for postconviction relief, in which Appellant argued that his trial counsel was ineffective and that the prosecutor improperly refused to renew her initial plea offer.Appellant was convicted of first-degree felony murder. After Appellant filed his pro se petition for postconviction relief, Appellant asked the postconviction court to appoint counsel. The postconviction court referred Appellant’s request for counsel to the state public defender, which declined to represent Appellant. The district court then denied Appellant’s postconviction petition without holding an evidentiary hearing. The Supreme Court reversed, holding (1) Appellant was entitled to an appointed attorney for postconviction proceedings because he did not have a “review” on direct appeal; and (2) therefore, the postconviction court erred in not granting Appellant’s request for counsel. View "State v. Eason" on Justia Law

At issue in this case was whether Defendant committed burglary when he entered another guest’s hotel room without that guest’s consent and committed a crime in that room.The Supreme Court affirmed the judgment of the district court finding Defendant guilt of first-degree burglary. On appeal, Defendant argued that the State failed to prove the essential element of burglary that he entered a building without consent. Specifically, Defendant argued that, as a paying guest at the hotel, he had consent to enter the hotel building and, therefore, could not commit burglary while in the hotel. The Supreme Court disagreed, holding that when Defendant entered the victim’s hotel room he exceeded the scope of his consent to be present in the hotel building. Therefore, the evidence was sufficient to sustain Defendant’s conviction. View "State v. Lopez" on Justia Law

At issue in this case was whether Defendant committed burglary when he entered another guest’s hotel room without that guest’s consent and committed a crime in that room.The Supreme Court affirmed the judgment of the district court finding Defendant guilt of first-degree burglary. On appeal, Defendant argued that the State failed to prove the essential element of burglary that he entered a building without consent. Specifically, Defendant argued that, as a paying guest at the hotel, he had consent to enter the hotel building and, therefore, could not commit burglary while in the hotel. The Supreme Court disagreed, holding that when Defendant entered the victim’s hotel room he exceeded the scope of his consent to be present in the hotel building. Therefore, the evidence was sufficient to sustain Defendant’s conviction. View "State v. Lopez" on Justia Law

The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone.The police lawfully seized a cellphone from Defendant and attempted to execute a valid warrant to search the cellphone, which had a fingerprint-scanner security lock that prevented the search. When Defendant refused to block the cellphone with his fingerprint the district court ordered Defendant to provide his fingerprint so the police could search the cellphone’s contents. The court of appeals affirmed, concluding that providing a fingerprint was not privileged under the Fifth Amendment. The Supreme Court affirmed, holding that because providing the fingerprint elicited only physical evidence from Defendant and did not reveal the contents of his mind, no violation of the Fifth Amendment privilege against self-incrimination occurred. View "State v. Diamond" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder, holding that there was no abuse of discretion.On appeal, Defendant argued that the district court abused its discretion when it (1) declined to excuse a juror who, after the trial began, realized that she knew a witness and had been exposed to news coverage of the shooting; and (2) improperly excluded reverse-Spreigl alternative-perpetrator evidence. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion in declining to remove the juror at issue from the jury; and (2) the district court did not abuse its discretion by excluding the reverse-Spreigl evidence. View "State v. Curtis" on Justia Law

Applying Minn. R. Civ. P. 6.02 to extend the lis pendens deadline in Minn. Stat. 582.043(7)(b) is prohibited because to do so would impermissibly modify the substantive rights provided by the statute.The Supreme Court answered in the negative a question certified to it by the United States Court of Appeals for the Eighth Circuit as to whether the lis pendens deadline may be extended upon a showing of excusable neglect under Rule 6.02. At issue was whether the lis pendens recording requirement was procedural or substantive in nature. The Supreme Court held that to extend the lis pendens deadline using Rule 6.02 would be an impermissible intrusion into matters of substantive law. View "Litterer v. Rushmore Loan Management Services, LLC" on Justia Law

Appellant BCBSM, Inc. (“Blue Cross”) denied respondent James Linn’s insurance claim because the requested treatment was not considered medically necessary under the parties’ health-plan contract. After Blue Cross denied the claim, an external-review entity determined that the treatment was, in fact, medically necessary for Linn’s condition. Blue Cross paid the claim, but Linn and his wife sued Blue Cross for breach of contract. The district court granted summary judgment for Blue Cross, concluding that the treatment was not medically necessary under the contract’s plain terms and that Blue Cross fulfilled its contractual obligations when it paid for the treatment following the external review. The court of appeals reversed. Because the Minnesota Supreme Court concluded: (1) external-review decisions were independent determinations of medical necessity that did not supersede contractual definitions of medical necessity; and (2) the health-plan contract plainly excluded coverage for Linn’s claim for treatment, the Court reversed. View "Linn v. BCBSM, Inc." on Justia Law

Appellant Emile Rey pleaded guilty to one count of identity theft involving eight or more direct victims. The district court ordered Rey to pay the mandatory-minimum restitution of $1,000 to each of his 66 direct victims, totaling $66,000. Rey appealed, asserting that the mandatory-minimum restitution he was ordered to pay violated his procedural and substantive due process rights and was an unconstitutional fine. The court of appeals affirmed. Rey asked the Minnesota Supreme Court to declare the statute unconstitutional, vacate the restitution order, and remand the matter for a restitution hearing or a Blakely trial. The Court declined, and affirmed the restitution order. View "Minnesota v. Rey" on Justia Law