Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s convictions for two counts of first-degree murder, two counts of second-degree murder, and one count of attempted second-degree murder, holding that any alleged errors, whether separate or cumulative, were harmless.On appeal, Defendant argued that the district court erred by allowing the State to depose a material witness before trial, admitting a redacted transcript of the deposition at trial, and admitting evidence that, one week before the murders, Defendant had pointed a gun at two of the victims and threatened to kill everybody in the apartment. The Supreme Court held that Defendant failed to demonstrate a reasonable possibility that any of the alleged errors substantially affected the verdict, and therefore, Defendant was not entitled to a new trial. View "State v. Williams" on Justia Law

In this case involving the constitutionality of the Minnesota Unclaimed Property Act the Supreme Court held (1) owners of interest-bearing bank accounts have a constitutionally protected property right that is taken when the State does not compensate the owners for lost interest after transferring and holding unclaimed property under the Act; and (2) the notice provided under the Act to owners of such property valued over $100 is sufficient to satisfy the requirements of due process.Appellants in this case were four property owners whose property was presumed abandoned under the Act and transferred to the State. Appellants alleged that they did not receive sufficient notice that their property had been remitted to the State, in violation of their due process rights, and that the Act effected an unconstitutional taking because they did not receive constructive interest on the unclaimed property after it was delivered to the State. The Supreme Court held that the State was not required to pay interest to some of Appellants in this case because the unclaimed property at issue was not interest bearing and that the notice provided to Appellants under the Act met the requirements of procedural due process. View "Hall v. State" on Justia Law

The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court’s conclusion that Respondent untimely filed his complaint challenging the forfeiture of his vehicle but reversed the district court’s conclusion that the insurance proceeds payable to Respondent under an insurance policy covering property damage to the vehicle were subject to forfeiture under Minn. Stat. 169A.63. The court held (1) Respondent’s complaint was time barred; (2) insurance payments are not subject to forfeiture under section 169A.63; and (3) therefore, the dismissal of Respondent’s complaint to the extent it challenged the forfeiture of the insurance proceeds was proper, but as to insurance payments, the complaint was dismissed for the wrong reasons. View "Briles v. 2013 GMC Terrain" on Justia Law

At issue on certiorari was what evidence a tax court may rely upon in deciding whether the taxpayer has overcome the presumptive validity of the county’s assessment.Here, Taxpayer contested the County’s assessment of the fair market value of Taxpayer’s parking ramp. The tax court denied the County’s motion to dismiss, basing its decision on evidence presented in the County’s case. The Supreme Court affirmed, holding (1) the tax court erred in considering the County’s evidence to decide the motion to dismiss because the relevant law permits only the Taxpayer’s evidence to be considered; but (2) the tax court did not abuse its discretion by holding, in the alternative, that Taxpayer’s evidence overcame the presumptive validity of the assessment. View "Court Park Co. v. County of Hennepin" on Justia Law

A person is “carry[ing] a pistol on or about the person’s clothes or person” for purposes of Minn. Stat. 624.7142(1)(4) when that person is driving a vehicle with a handgun in the center console.During an inventory search of Defendant’s vehicle after his arrest on suspension of driving while under the influence of alcohol, police discovered a loaded handgun in the center console. Defendant was charged with carrying a pistol on or about his clothes or person while under the influence of alcohol, in violation of section 624.7142(1)(4). The district court dismissed the charge for lack of probable cause, concluding that the phrase “carrying on or about the person’s clothes or person” does not extend to a pistol within the closed center console. The court of appeals affirmed. The Supreme Court reversed, holding that a pistol is carried “on or about” one’s person or clothing if there is either a physical nexus between the person and the pistol or if the pistol is carried within arm’s reach of the person. View "State v. Prigge" on Justia Law

A passenger who grabs the steering wheel of a moving vehicle is “operating” the motor vehicle under the criminal-vehicular-operation statute, Minn. Stat. 609.2113(1).Defendant was charged with criminal vehicular operation after he grabbed the steering wheel of a moving vehicle, causing the vehicle to crash and inflict great bodily harm on the three other occupants of the vehicle. Defendant moved to dismiss the complaint, arguing that he was not “operating” the motor vehicle for purposes of the statute. The district court disagreed, concluding that Defendant had operated the vehicle when he turned the steering wheel. The court of appeals affirmed. The Supreme Court affirmed, holding that the plain meaning of the term “operating” in section 609.2113(1) unambiguously included Defendant’s conduct. View "State v. Henderson" on Justia Law

Contrary to the holding of the district court, Appellant filed a timely legal-malpractice claim under Minn. Stat. 541.05(1)(5).Respondent, Appellant’s attorney, prepared an antenuptial agreement for Appellant and his then-fiancee, Cynthia Gatliff, but the agreement did not include statutorily required witness signatures, making it unenforceable. One year after Appellant married Gatliff, Respondent drafted a will for Appellant that incorporated the antenuptial agreement by reference. When Gatliff later filed for divorce, she alleged that the antenuptial agreement was invalid due to its lack of witness signatures. Appellant subsequently sued Respondent for legal malpractice. While the invalid execution of the antenuptial agreement fell outside the six-year limitations period for malpractice claims, Appellant argued that subsequent representations by Respondent that the anteuptial agreement was valid were separate legal-malpractice claims that each triggered their own statute of limitations periods. The district court granted Respondent’s motion for judgment on the pleadings, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant sufficiently alleged that Respondent’s will drafting formed the basis for a separate malpractice claims within the limitations period. View "Frederick v. Wallerich" on Justia Law

Contrary to the holding of the district court, Appellant filed a timely legal-malpractice claim under Minn. Stat. 541.05(1)(5).Respondent, Appellant’s attorney, prepared an antenuptial agreement for Appellant and his then-fiancee, Cynthia Gatliff, but the agreement did not include statutorily required witness signatures, making it unenforceable. One year after Appellant married Gatliff, Respondent drafted a will for Appellant that incorporated the antenuptial agreement by reference. When Gatliff later filed for divorce, she alleged that the antenuptial agreement was invalid due to its lack of witness signatures. Appellant subsequently sued Respondent for legal malpractice. While the invalid execution of the antenuptial agreement fell outside the six-year limitations period for malpractice claims, Appellant argued that subsequent representations by Respondent that the anteuptial agreement was valid were separate legal-malpractice claims that each triggered their own statute of limitations periods. The district court granted Respondent’s motion for judgment on the pleadings, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant sufficiently alleged that Respondent’s will drafting formed the basis for a separate malpractice claims within the limitations period. View "Frederick v. Wallerich" on Justia Law

The Supreme Court affirmed the denial of Appellant’s third petition for postconviction relief, which asserted several claims based on facts alleged in two sworn affidavits, holding that the affidavits were legally insufficient to establish that Appellant was innocent of the offenses of which he was convicted. The postconviction court summarily denied the postconviction petition because it was filed after the statute of limitations in Minn. Stat. 590.01(4)(a) had expired and failed to meet the newly-discovered-evidence exception in Minn. Stat. 590.01(4)(b)(2). The Supreme Court affirmed, holding that the facts were legally insufficient to show that Appellant met the newly-discovered-evidence exception, and therefore, the district court did not abuse its discretion when it summarily denied the petition as untimely filed. View "Henderson v. State" on Justia Law