Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the district court’s grant of summary judgment in favor of Defendant in this products liability action, holding that this was a “close case” in which foreseeability must be resolved by the jury.Plaintiff was injured by a high-density extruder manufactured by Defendant. Plaintiff brought a products liability action against Defendant, alleging failure-to-warn and design-defect claims. The district court granted Defendant’s motion for summary judgment, concluding that Defendant did not owe a duty of care to Plaintiff because Plaintiff’s injury was not reasonably foreseeable. The court of appeals affirmed. The Supreme Court reversed and remanded, holding that, viewing all of the evidence and inferences arising from it in the light most favorable to Plaintiff, reasonable persons might differ as to the foreseeability of Plaintiff’s injury under the circumstances. View "Montemayor v. Sebright Products, Inc." on Justia Law

Minn. R. Evid. 1101 requires application of the Minnesota Rules of Evidence to restitution hearings.After a jury trial, Defendant was found guilty of aggravated forgery. At a restitution hearing, Defendant objected to the admissibility of certain e-mails on hearsay grounds. The trial court overruled the objection, concluding that the Rules of Evidence did not apply. The court of appeals affirmed the district court’s evidentiary rulings, concluding that the evidentiary rules do not apply to restitution hearings because the obligation to pay restitution is a part a sentence and the Rules of Evidence do not apply to sentencing proceedings. The Supreme Court reversed, holding that the Rules of Evidence apply to all cases and proceedings unless the rules provide otherwise, and because the language of rule 1101(b)(3) does not preclude their application to restitution hearings, the Minnesota Rules of Evidence apply to such hearings. View "State v. Willis" on Justia Law

The Workers’ Compensation Court of Appeals (WCCA) clearly and manifestly erred by rejecting the findings of the compensation judge and overturning the determination that Respondent failed to establish her claim for benefits by a preponderance of the evidence. Respondent filed a claim for workers’ compensation benefits after falling and injuring her shoulder while rushing up a staircase at the workplace of her employer. The compensation judge denied the claim. The WCCA reversed the compensation judge’s decision. The Supreme Court reversed the WCCA’s decision and reinstated the compensation judge’s decision, holding (1) the WCCA impermissibly substituted its own view of the evidence for that of the compensation judge; and (2) the findings of the compensation judge were supported by substantial evidence that a reasonable mind would accept as adequate. View "Kubis v. Community Memorial Hospital Ass’n" on Justia Law

The Supreme Court affirmed Defendant’s first-degree murder conviction in connection with the death of his two-year-old niece.This appeal followed from Defendant’s third trial, which involved the same five counts of murder as Defendant’s second trial. The jury found Defendant guilty of five counts of murder. The district court sentenced Defendant on the first count - first-degree murder while committing criminal sexual conduct - imposing the mandatory sentence of life in prison without the possibility of release. The Supreme Court affirmed but remanded to the district court for correction of the sentencing order, holding (1) two alleged errors in the district court’s evidentiary rulings did not affect the verdict; (2) the prosecutor did not commit plain error during closing argument; (3) the alleged errors, when considered cumulatively, did not deny Defendant a fair trial; and (4) the district court’s sentencing order erroneously stated that Defendant was convicted of all five murder charges. View "State v. Fraga" on Justia Law

Anibal Sanchez, an undocumented worker, brought suit against Dahlke Trailer Sales, Inc. under the workers’ compensation antiretaliation statute, alleging that Dahlke discharged him because he sought workers’ compensation benefits. The district court granted summary judgment to Dahlke, finding as a matter of law that Sanchez’s unpaid leave was a result of his immigration status and not his workers’ compensation claim. The court of appeals reversed. The Supreme Court affirmed and remanded the case for further proceedings, holding (1) Sanchez raised a genuine issue of material fact as to whether Dahlke discharged him and as to whether the discharge was motivated by Sanchez seeking workers’ compensation benefits; and (2) federal immigration law does not preempt an undocumented worker’s claim that his employer discharged him in retaliation for seeking workers’ compensation benefits. View "Sanchez v. Dahlke Trailer Sales, Inc." on Justia Law

The district court’s denial of Mother’s motion to “reinstate” joint custody of the parties’ children, though appealable, erroneously modified custody without complying with the requirements of Minn. Stat. 518.18.After dissolving their marriage, Mother and Father agreed to share joint legal and physical custody of their two children. The district court adopted the parties’ agreement. Thereafter, the district court issued a series of orders granting Father temporary sole custody of the children. When the parties did not resume joint physical custody more than one year later, Mother moved to reinstate joint custody. The district court denied the motion. The court of appeals affirmed the district court’s order. The Supreme Court reversed, holding that the district court erred when it modified the custody arrangement established by the judgment and decree. The court remanded the case to reinstate the original custody order or, upon a motion to modify, for an evidentiary hearing. View "Crowley v. Meyer" on Justia Law

The Workers’ Compensation Court of Appeals (WCCA) was correct in concluding that Respondent’s injury was compensable.Respondent, who was employed by the University of Minnesota, slipped and fell on any icy sidewalk when walking from her workplace to a parking ramp owned and operated by the university. The compensation judge denied Respondent’s claim for workers’ compensation benefits, concluding that Respondent’s injury did not “arise out of” her employment. The WCCA reversed, concluding that Respondent was in the course of her employment when she was injured. The Supreme Court affirmed, holding that Respondent’s injury was compensable because it both arose out of, and was in the course of, her employment. View "Hohlt v. University of Minnesota" on Justia Law

Defendant was charged with two counts of second-degree intentional murder. Defendant filed a petition to plead guilty to both counts, but the petition was denied based on the State’s notice, right before the guilty-plea hearing, of its intent to seek a grand-jury indictment on first-degree murder charges. Thereafter, a grand jury returned an indictment charging Defendant with six counts of first-degree murder. The State dismissed the second-degree murder charges. Defendant pleaded guilty to one count of first-degree premeditated murder and one count of first-degree murder while committing a burglary. Defendant filed a petition for postconviction relief requesting that he be allowed to withdraw his guilty plea and instead plead guilty to the original second-degree murder charges. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied Defendant’s petition for postconviction relief without holding an evidentiary hearing because Defendant failed to establish that withdrawal was necessary to correct a manifest injustice. View "Dikken v. State" on Justia Law

The Workers’ Compensation Court of Appeals (WCCA) abused its discretion when it granted Eddie Hudson’s petition to vacate an award of workers’ compensation benefits. Hudson was injured while working for Trillium Staffing and filed a workers’ compensation claim. The parties eventually settled. About one year later, Hudson filed a petition to vacate the award. The Workers’ Compensation Court of Appeals (WCCA) granted the petition, finding that Hudson’s medical condition had substantially changed in a way that clearly was not, and could not reasonably have been, anticipated at the time of the award. The Supreme Court reversed, holding that the WCCA abused its discretion when it granted Hudson’s petition because the medical opinion underlying the WCCA’s decision lacked foundation and therefore did not establish a substantial change in Hudson’s medical condition. View "Hudson v. Trillium Staffing" on Justia Law

In this negligence lawsuit filed against Kraemer Construction, Inc., the Supreme Court held that Kraemer and Ulland Brothers, Inc. were engaged in a common enterprise as a matter of law when Richard Washburn was killed and that the election of remedies provision required dismissal of the suit.Jessica Kelly, as trustee for the next-of-kin of Washburn, filed this lawsuit against Kraemer for its alleged negligence in causing Washburn’s death by electrocution at a construction site. Kraemer moved for summary judgment, arguing that it was engaged in a common enterprise with Ulland, Washburn’s employer, when Washburn was killed and that the election-of-remedies provision of the Minnesota Workers’ Compensation Act prevented Kelly from bringing a civil action against Kraemer when her children had already recovered workers’ compensation benefits from Ulland. The court of appeals reversed the district court’s denial of summary judgment and remanded for entry of summary judgment in favor of Kraemer. The Supreme Court affirmed, holding that Kraemer and Ulland were engaged in a common enterprise and that the election of remedies provision required dismissal. View "Kelly v. Kraemer Construction, Inc." on Justia Law