Justia Minnesota Supreme Court Opinion Summaries

In this arbitration dispute, the district court erred by directing the entry of final judgment rather than staying the proceeding, and the court of appeals, faced with a final appealable judgment, should have vacated the judgment and entered a stay of the underlying action pending completion of the arbitration.Plaintiff sued Defendants to stop arbitration proceedings after Defendants demanded arbitration and an arbitrator determined that the dispute was arbitrable. The district court granted summary judgment for Defendants and compelled arbitration. Instead of staying the underlying action, the district court directed the entry of judgment. Plaintiff appealed, arguing that the district court’s order was a final judgment because it dismissed, rather than stayed, the underlying proceeding. The court of appeals disagreed and dismissed the appeal as taken from a nonfinal order and judgment. The Supreme Court reversed, holding (1) the district court erred by directing the entry of final judgment rather than staying the proceeding, as required by Minn. Stat. 572B.07(f); and (2) the proper course for the court of appeals, faced with a final judgment that was appealable under Minn. R. Civ. App. P. 103.03(a), was to direct the district court to vacate the judgment and enter a stay of the underlying action pending completion of the arbitration. View "City of Rochester v. Kottschade" on Justia Law

Defendant pleaded guilty to terroristic threats. As part of the factual basis for his plea, Defendant admitted that he posted five threatening tweets directed at law enforcement officers. Defendant filed a motion for a downward durational sentencing departure, which was warranted by his remorse, his intoxication, and the less serious nature of social media threats. The district court granted Defendant’s request. The Supreme Court vacated Defendant’s sentence and remanded to the district court for further proceedings, holding (1) Defendant’s “mental state” was not a proper reason to impose a downward durational sentencing departure; (2) the record did not reflect any offense-related remote that would provide an alternative ground to support the downward durational sentencing departure; and (3) the circumstances surrounding Defendant’s use of a social media platform to publish his threats did not mitigate his culpability. View "State v. Rund" on Justia Law

Minn. Stat. 554.02, a section of Minnesota’s anti-SLAPP law, is unconstitutional as applied to claims at law alleging torts.Petitioners sued Asian Women United of Minnesota (AWUM), a nonprofit organization, seeking to recover under a number of legal theories of injuries allegedly inflicted by AWUM through four previous lawsuits. AWUM moved for dismissal under Minnesota’s anti-SLAPP law. Minn. Stat. 554.01-.06. The district court dismissed all of Petitioners’ claims with the exception of their claim for malicious prosecution. The district court concluded that Minn. Stat. 554.02 - the section of the law that governs motions “to dispose of a judicial claim” - violated Petitioners’ right to a jury trial by requiring the trial judge to find facts. As a result, the district court denied AWUM’s motion to dismiss. The Supreme Court affirmed, holding that section 554.02 is unconstitutional when it requires a district court to make a pretrial finding that speech or conduct is not tortious under Minn. Stat. 554.03, as was the case here. View "Leiendecker v. Asian Women United of Minnesota" on Justia Law

Defendant was found guilty of possession of a firearm by an ineligible person. The court of appeals reversed, concluding that the evidence was insufficient to support the conviction. The State petitioned for review, arguing that the court of appeals erred in its application of law and asking the Supreme Court to abandon the separate standard of review for convictions based on circumstantial evidence. The Supreme Court affirmed, holding (1) the court of appeals correctly applied the law and properly found that the State presented insufficient evidence to support Defendant’s conviction; and (2) the State has not established a compelling reason for the court to overrule an approximately century-old rule governing the review of convictions based on circumstantial evidence. View "State v. Harris" on Justia Law

Appellant was convicted of first-degree murder committed for the benefit of a gang. The Supreme Court affirmed. The day before the postconviction statute of limitations expired, Appellant filed his second petition for postconviction relief and, over the next six months, filed various addenda and attachments to his second petition. Appellant also filed a third petition raising additional claims and filed a motion requesting re-testing of certain trial evidence. Without holding an evidentiary hearing, the postconviction court denied both petitions and Appellant’s other requests, determining that his claims were untimely filed or procedurally barred, or failed on the merits. The Supreme Court affirmed, holding that each of the claims Appellant raised in his second and third petitions for postconviction relief, as well as the claims raised in the addenda to the second petition, failed. View "Brown v. State" on Justia Law

Appellant, a juvenile offender, challenged the district court’s imposition of three consecutive sentences of life imprisonment with the possibility of release after thirty years on each sentence for his three murder convictions. Appellant argued, among other things, that the rule announced in Miller v. Alabama and clarified in Montgomery v. Louisiana should apply to his case because his consecutive sentences were, in the aggregate, the functional equivalent of life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) this court declines to extend the Miller/Montgomery to include Appellant or other similarly situated offenders because the United States Supreme Court has not squarely addressed the issue of whether consecutive sentences should be viewed separately when conducting a proportionality analysis; and (2) Appellant’s three consecutive sentences do no unfairly exaggerate the criminality of his conduct. View "State v. Ali" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree felony murder rendered after a jury trial. The district court sentenced Defendant to life imprisonment with the possibility of release after thirty years. Specifically, the Court held (1) the State presented sufficient evidence to prove beyond a reasonable doubt that the killing of the victim occurred while Defendant was attempting to commit an aggravated robbery; and (2) the district court did not commit plain error by failing to include language requiring a causal relationship between the killing and the attempted robbery in the jury instruction on first-degree felony murder. View "State v. Webster" on Justia Law

Based on the plain language of Minn. Stat. 176.101, subd. 1(i), the Supreme Court held that an offer to return to work with the same employer is not “consistent with” an employee’s rehabilitation plan stating that the employee’s vocational goal is to return to work with a different employer in the same industry. The Court affirmed the decision of the Workers’ Compensation Court of Appeals that reversed the compensation judge’s decision to discontinue temporary total disability (TTD) compensation to the employee at issue in this case, holding that the employer was not entitled to discontinue TTD benefits because its job offer was not consistent with the employee’s plan of rehabilitation. View "Gilbertson v. Williams Dingmann, LLC" on Justia Law

This tax dispute arose out of a failed real estate investment that resulted in significant tax consequences for Germaine Harmon, the widow of one of the original investors. Harmon challenged the Commissioner of Revenue’s assessment of her 2010 Minnesota income-tax liability, which the Commissioner based on a Schedule K-1 filed by the partnership in charge of the foreclosed real estate investment. The Supreme Court affirmed the tax court’s grant of summary judgment in favor of the Commissioner, holding that the tax court did not err by determining that Harmon failed to overcome the presumption of validity of the Commissioner’s assessment of taxes. View "Harmon v. Commissioner of Revenue" on Justia Law

In 2015, Appellant was charged with two counts of first-degree driving while impaired (DWI). Appellant contested the use of his 1998 conviction for criminal vehicular operation resulting in substantial bodily harm to enhance his 2015 DWI charge to a first-degree offense. The district court found sufficient probable cause for enhancement. Thereafter, Appellant pleaded guilty to one count of first-degree driving while impaired. Appellant appealed, arguing that he was entitled to withdraw his plea because his 1998 conviction was not included in the list of predicate felonies in Minn. Stat. 169A.24 that enhance a DWI charge to a first-degree DWI. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a criminal vehicular operation conviction from a year not specifically listed in the current version of the first-degree DWI statute can be used to enhance a DWI charge to a first-degree offense; and (2) accordingly, Appellant’s plea was established with an accurate factual basis. View "State v. Boecker" on Justia Law