Justia Minnesota Supreme Court Opinion Summaries

Defendant was charged in May 2013 with two counts of first-degree criminal sexual conduct. When Defendant failed to appear for his first appearance, the district court issued a warrant for his arrest. In February 2015, Defendant was arrested for unrelated reasons. Before his omnibus hearing, Defendant moved to dismiss the charges, claiming that the twenty-one-month delay between the date he was charged and his eventual arrest violated his right to a speedy trial under the United States and Minnesota Constitutions. The district court granted Defendant’s motion and dismissed the charges after applying the four-factor balancing test from Barker v. Wingo. The court of appeals reversed, concluding that the third and fourth Barker factors did not weigh in Defendant’s favor, and therefore, on balance, the State had not violated Defendant’s constitutional right to a speedy trial. The Supreme Court affirmed as modified, holding that although the delay may have been attributable to the State’s negligence, Defendant’s failure to assert his speedy trial right weighed heavily against him and ultimately led to the conclusion that the State did not violate Defendant’s right to a speedy trial. View "State v. Osorio" on Justia Law

Appellant submitted several requests for public government data from Hennepin County and the Hennepin County Sheriff’s Office (collectively, Respondents) under the Minnesota Government Data Practices Act. Respondents responded to all of Appellant’s requests except for a request asking that Respondents perform a computer-aided search of their stored e-emails using twenty separate search terms. Appellant filed a complaint alleging that Hennepin County had violated the Data Practices Act by failing to promptly and substantively respond to his data requests. An administrative law judge (ALJ) concluded that Hennepin County had violated the Data Practices Act and ordered it to produce all requested data. Respondents appealed the decision and obtained a stay from the ALJ pending appeal. Thereafter, Appellant filed a motion to lift the stay. The court of appeals denied the motion. The Supreme Court affirmed, holding that the ALJ’s decision to issue a stay pending appeal was not an abuse of discretion. View "Webster v. Hennepin County" on Justia Law

In 2005, Appellant pleaded guilty to second-degree burglary, a felony. When Appellant was released from probation the conviction was deemed a misdemeanor. In 2015, Appellant filed a petition for expungement. The district court denied the petition, concluding that Appellant was not “convicted of” a misdemeanor and therefore could not petition for expungement under Minn. Stat. 609A.02, subd. 3(a)(3). The court of appeals affirmed. The Supreme Court affirmed, holding that felony convictions later deemed misdemeanors by operation of law under Minn. Stat. 609.13, subd. 1(2) are not eligible for expungement under Minn. Stat. 609A.02, subd. 3(a)(3). View "State v. S.A.M." on Justia Law

Appellants, members of a Minneapolis citizen group, submitted a petition to the Minneapolis City Council for consideration of a question regarding a proposed amendment to the Minneapolis City Charter. The proposed amendment would require City police officers to obtain and maintain professional liability insurance coverage and would impose other conditions for coverage and indemnification. Concluding that the proposed insurance amendment conflicted with and was preempted by state law, the City Council directed the City Clerk not to include the amendment question on the ballot for the November 2016 election. Appellants filed a petition to challenge that decision. The district court agreed with the City Council and dismissed the petition. The Supreme Court affirmed, holding that the proposed insurance amendment conflicts with state law, and therefore, the district court properly dismissed Appellants’ petition. View "Bicking v. City of Minneapolis" on Justia Law

The State charged Defendant under Minn. Stat. 609.352, subd. 2a(2) with felony communication with a child describing sexual conduct after she sent sexually explicit images and messages to a fifteen-year-old boy. Defendant filed a motion to dismiss, arguing that section 609.352, subd. 2a(2) proscribes a substantial amount of speech that the First Amendment protects and thus facially violates the First Amendment. The district court concluded that the statute violates the First Amendment, and the court of appeals affirmed. The Supreme Court reversed, holding that 609.352, subd. 2a(2) is not substantially overbroad in relation to its plainly legitimate sweep. View "State v. Muccio" on Justia Law

After Appellant pleaded guilty to third-degree criminal sexual conduct, removal proceedings were initiated against him. In an attempt to avoid deportation, Appellant filed an emergency motion to withdraw his guilty plea, arguing, inter alia, that he received ineffective assistance of counsel because counsel failed accurately to inform him that his plea would lead to his removal from the United States. Specifically, Appellant argued that Padilla v. Kentucky required his attorney to advise him that the plea would result in his deportation, rather than just the deportation was a possibility. The postconviction court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding that Padilla did not require Appellant’s counsel to do anything more than provide a general warning about the immigration consequences of entering the plea, and therefore, Appellant’s counsel satisfied his obligation under the Sixth Amendment. View "Sanchez v. State" on Justia Law

Defendant was arrested and charged with drug-related crimes. The district court ordered Defendant’s pretrial release. The district court later found probable cause that Defendant had violated the conditions of her release and issued a warrant for her arrest. Officers then went to the residence of Defendant’s boyfriend. One officer opened an unlocked door, went inside, and arrested Defendant. While arresting her, the officer saw marijuana and a bong in plain view. Law enforcement then obtained a search warrant for the apartment of Defendant’s boyfriend. The state subsequently charged Defendant with two counts of fifth-degree possession of a controlled substance and possession of drug paraphernalia. The district court suppressed all fruits of Defendant’s arrest and dismissed the charges, concluding that the arrest was illegal because the warrant for Defendant's arrest did not authorize police to enter her boyfriend’s apartment. The court of appeals reversed. The Supreme Court affirmed, holding that neither the Fourth Amendment of the U.S. Constitution nor Article I, Section 10 of the Minnesota Constitution requires police to obtain a search warrant before entering a home to arrest a guest who is the subject of a lawfully issued arrest warrant. View "State v. deLottinville" on Justia Law

Plaintiff sued Defendants, health care providers, alleging professional negligence. Defendants filed a motion to compel authorization of an informal discussion with the surgeon who performed the Plaintiff’s surgery. The surgeon was not named as a defendant. Upon Plaintiff’s motion, the district court issued a protective order requiring Plaintiff to authorize the surgeon to participate in the informal discussion but restricting Defendants’ questioning of the surgeon to his own treatment of Plaintiff. Defendants filed an interlocutory appeal. Meanwhile, the parties and the surgeon participated in an informal discussion. While the interlocutory appeal was pending, the case was tried to a jury. The district court allowed the surgeon to opine on matters other than his own treatment of Plaintiff. The jury found in favor of Defendants. Thereafter, the court of appeals proceeded to decide the interlocutory appeal and reversed the district court’s protective order, concluding that Defendants were allowed to ask the surgeon about Defendants’ care of Plaintiff and the cause of her injury. The Supreme Court vacated the court of appeals’ opinion, holding that the court of appeals lacked appellate jurisdiction over the interlocutory order. View "Howard v. Svoboda" on Justia Law

Respondent received a head injury during the course of her employment. Respondent filed a request with the workers’ compensation division seeking coverage for various treatments she was receiving for her injuries, including treatment for emotional and psychological conditions that allegedly developed from her injury. The compensation judge denied Respondent’s request for coverage of emotional and psychological conditions, finding that Respondent had not suffered a concussion and post-concussive syndrome. The compensation judge relied heavily on the opinion of a certain psychologist. The WCCA reversed and vacated the denial of coverage of the emotional and psychological conditions, concluding that there was not an adequate factual foundation for the psychologist’s opinion. The Supreme Court reversed, holding (1) the WCCA erred when it raised and ruled on the forfeited issue of whether a psychologist was competent to provide an expert opinion; (2) the WCCA erred when it reversed the compensation judge’s decision based primarily on the psychologist’s report; and (3) the WCCA erred when it reversed the compensation judge’s finding that Respondent did not suffer a concussion and post-concussive syndrome. View "Gianotti v. Independent School District 152" on Justia Law

After the Supreme Court overturned Petitioner’s first conviction on direct appeal, Petitioner was tried a second time and convicted of first-degree murder while committing or attempting to commit a kidnapping. Petitioner was sentenced to life in prison without the possibility of release. The Supreme Court affirmed. This appeal concerned Petitioner’s third petition for postconviction relief in which Petitioner raised a variety of claims. The postconviction court summarily denied the claims as either meritless or untimely filed. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in summarily denying the petition, as one of Petitioner’s claims was meritless and the remaining claims were untimely filed. View "Hannon v. State" on Justia Law