Justia Minnesota Supreme Court Opinion Summaries

Minnesota’s water’s edge rule, Minn. Stat. 290.17(4)(f), does not prohibit the inclusion in “net income” the income of a foreign entity that elects under federal tax law to be disregarded as a separate entity.At issue in this appeal from the tax court was whether the consequences of an election made under federal tax law by a foreign entity owned by Ashland Inc., a domestic unitary business, must be recognized in determining Ashland’s Minnesota tax liability. The Commissioner of Revenue concluded that the income and apportionment factors of the foreign entity were improperly included in Ashland’s combined return and so excluded them in calculating Ashland’s Minnesota tax liability. The tax court granted Ashland’s motion for summary judgment, concluding that the consequences of the federal election were properly included in the determination of Ashland’s net income on its Minnesota tax returns. The Supreme Court affirmed, holding that the tax court did not err in its conclusion. View "Ashland Inc. & Affiliates v. Commissioner of Revenue" on Justia Law

The Supreme Court vacated Defendant’s sentence of 135 months in prison for his conviction for first-degree possession of methamphetamine, holding that resentencing was required under sentencing grid as amended by the Drug Sentencing Reform Act (DSRA). The DSRA, which took effect after Defendant committed his offense, reduced the presumptive sentencing range under the Minnesota Sentencing Guidelines drug offender sentencing grid for Defendant’s crime. The Supreme Court held that Defendant must be resentenced under the DSRA-amended sentencing grid, holding that the amelioration doctrine required that Defendant be resentenced. View "State v. Otto" on Justia Law

The Supreme Court reversed the court of appeals affirming the district court’s dismissal of the State’s amended complaint against Minnesota School of Business and Globe University (the Schools). The State alleged that the Schools charged usurious interest rates and made loans without the required license for making private student loans at interest rates of up to eighteen percent. The State’s amended complaint sought permanent statutory injunctive relief to stop the Schools from engaging in unlicensed and usurious lending. The district court granted summary judgment for the Schools. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Schools charged usurious interest rates in violation of Minn. Stat. 334.01(1); and (2) the Schools were required to obtain a lending license under Minn. Stat. 56.01(a), and their failure to do so meant that they engaged in unlicensed lending. View "State v. Minnesota School of Business, Inc." on Justia Law

The Supreme Court affirmed Appellant’s conviction for two counts of theft by false representation, holding that, even assuming that the trial court’s omission of the phrase “with intent to defraud” from the jury instructions on the elements of theft by false representation was error, the error was harmless. Appellant's convictions were based on her acts of submitting timesheets and receiving payments for personal care assistant services that she did not perform. The court of appeals affirmed the convictions, concluding that, when viewed as a whole, the district court’s jury instructions fairly and adequately explained the law. The Supreme Court agreed, holding that any alleged error in the jury instructions was harmless beyond a reasonable doubt. View "State v. Schoenrock" on Justia Law

The Supreme Court vacated Defendant’s sentence of 161 months in prison for his conviction of first-degree possession of methamphetamine, holding that resentencing was required under sentencing grid as amended by the Drug Sentencing Reform Act (DSRA). The DSRA, which took effect while Defendant’s case was on appeal, reduced the presumptive sentencing range under the Minnesota Sentencing Guidelines drug offender sentencing grid for Defendant’s crime. The Supreme Court held that Defendant must be resentenced under the DSRA-amended sentencing grid because the amelioration doctrine applied to Defendant, whose conviction was not yet final when the DSRA took effect. View "State v. Kirby" on Justia Law

In a reciprocal discipline case, the identical discipline in Minnesota to “exclusion from practice” before the U.S. Patent and Trademark Office (USPTO) is an indefinite suspension from the practice of law with no right to petition for reinstatement for a minimum of five years.In this case, the USPTO imposed on Alan Stewart, a Minnesota attorney, what its regulations call “exclusion from practice” for misappropriating unearned fees, among other things. The Director of the Office of Lawyers Professional Responsibility petitioned to impose reciprocal discipline in Minnesota and argued that the identical discipline in Minnesota was disbarment. The Supreme Court indefinitely suspended Stewart with no right to petition for reinstatement for a minimum of five years, holding that the USPTO’s discipline procedures were fundamentally fair and that a five-year suspension would not be unjust or substantially different from the discipline warranted in Minnesota. View "In re Petition for Disciplinary Action against Alan Richard Stewart" on Justia Law

At issue in this case was the permissibility of preaward interest on an insurance appraisal award under the preaward interest statute, Minn. Stat. 549.09, subd. 1(b). Cincinnati Insurance Company issued James Poehler a homeowner’s insurance policy that provided replacement cost coverage for Poehler’s home and personal property. After a fire damaged Poehler’s property, Poehler demanded an appraisal under the appraisal clause of the policy. The appraisers issued an award, determining that Poehler’s total loss was more than what Cincinnati had paid by the time of the appraisal hearing. The district court confirmed the appraisal award and granted Poehler preaward interest. The court of appeals reversed, concluding that the preaward interest statute does not apply to appraisal awards pursuant to an insurance policy in the absence of “an underlying breach of contract or actionable wrongdoing.” The Supreme Court reversed, holding (1) section 549.09 does not require a finding of wrongdoing for the recovery of a reward interest on appraisal awards; (2) the loss payment provision in Cincinnati’s insurance policy did not preclude Poehler from recovering preaward interest on the appraisal award; and (3) the loss payment provision in Minn. Stat. 65A.01, the Minnesota standard fire insurance policy, did not apply in this case. View "Poehler v. Cincinnati Insurance Co." on Justia Law

The Supreme Court reversed Appellant’s conviction of first-degree driving while impaired, holding that Appellant’s 2005 gross-misdemeanor conviction of criminal vehicular operation was not a qualified prior impaired driving incident and was therefore improperly used to enhance Appellant’s offense to a first-degree crime. Appellant’s current offense of driving while impaired was enhanced to a first-degree crime based on the existence of three prior impaired-driving convictions, including the 2005 conviction at issue. The court of appeals affirmed, ruling that Appellant’s current offense was properly charged and adjudicated as a first-degree crime because his 2005 conviction was a qualifying offense. In reversing the court of appeals, the Supreme Court held that the evidence was insufficient to convict Appellant of first-degree driving while impaired because, under the plain language of Minn. Stat. 169A.03, subd. 20, Appellant’s 2005 criminal vehicular operation conviction did not qualify as a prior impaired driving conviction. View "State v. Smith" on Justia Law

The Supreme Court declined Appellants’ invitation to depart from the United States Supreme Court’s decision in Camara v. Municipal Court, 387 U.S. 523 (1967) and hold that Minnesota’s constitution requires that an administrative search warrant be supported by probable cause of the sort required in a criminal investigation. Camara held that an administrative warrant satisfies the probable cause requirement if reasonable legislative or administrative standards for conducting an unconsented-to rental housing inspection are satisfied with respect to a particular dwelling. In this case, the City of Golden Valley petitioned the district court for an administrative search warrant to search rental property for compliance with the city code. The district court denied the petition for the administrative search warrant, concluding that the issuance of such a search warrant was foreclosed without suspicion of a code violation. The court of appeals reversed. The Supreme Court affirmed, holding that the Minnesota Constitution does not require individualized suspicion of a code violation to support an administrative search warrant for a rental housing inspection. View "City of Golden Valley v. Wiebesick" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) to reverse the denial of Respondent's claim for ankle-fusion surgery.Respondent, who was injured during the course of her employment, filed a workers’ compensation claim petition for ankle-fusion surgery. The compensation judge denied Respondent’s claim for the ankle-fusion surgery. The WCCA reversed. Respondent’s employer appealed, arguing that the WCCA exceeded the scope of its review when it reversed the compensation judge’s decision to deny benefits to Respondent. The Supreme Court reversed, holding that the compensation judge’s finding was “supported by evidence that a reasonable mind might accept as adequate,” and therefore, the WCCA clearly and manifestly erred in rejecting this finding. View "Mattick v. Hy-Vee Foods Stores" on Justia Law