Justia Minnesota Supreme Court Opinion Summaries

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After Defendant was arrested on suspicion of driving while impaired, officers asked him to submit to a warrantless blood or urine test. Defendant refused both tests. The State charged Defendant with second-degree test refusal, among other counts. Defendant moved to dismiss the test refusal charge, arguing that the statute was unconstitutional. The district court denied the motion and found Defendant guilty of test refusal. The court of appeals reversed, concluding that charging a defendant with test refusal violates a fundamental right. The Supreme Court affirmed, holding that the test refusal statute is unconstitutional as applied to Defendant. View "State v. Thompson" on Justia Law

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Petitioners filed a petition under Minn. Stat. 204B.44 asserting that Respondents - the Secretary of State, the Ramsey County and Hennepin County election managers, and certain election judges - were not taking the necessary steps to ensure that those ineligible to vote were not permitted to vote, in violation of the separation-of-powers doctrine and the constitutional rights of eligible voters. The Supreme Court dismissed the petition, holding that, even if the petition properly invoked the Court’s original jurisdiction under section 204B.44, the Court would not exercise it in this case because an exercise of original jurisdiction over this case was not warranted. View "Minnesota Voters Alliance v. Simon" on Justia Law

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Mark Juelich and Steven Thoemke, former employees of Toyota-Lift of Minnesota, Inc. (TLM), claimed that TLM failed to pay them commissions they earned under their employment agreements with TLM. Juelich and Thoemke sought penalties under Minn. Stat. 181.14. The district court determined that TLM owed additional commissions to Juelich and Thoemke totaling $104,000 and that TLM was entitled to recover $815,000 from American Warehouse Systems, LLC (AWS) due to AWS’s breach of an asset purchase agreement entered into by AWS and TLM and its unjust retention of customer payments owed to TLM. The district court denied the request of Juelich and Thoemke for penalties under section 181.14, reasoning that the $814,000 judgment owed to TLM from AWS offset the unpaid commissions owed to Juelich and Thoemke. The court of appeals reversed, concluding that TLM was liable for statutory penalties under section 181.14. The Supreme Court affirmed, holding that when a court determines whether an employer is liable to an employee for the statutory penalty for nonpayment of wages under section 181.14, the court may not consider offsetting liabilities owed by the employee to the employer. View "Toyota-Lift of Minnesota, Inc. v. American Warehouse Sys., LLC" on Justia Law

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After a jury trial, Defendant was convicted of one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder. The Supreme Court affirmed the convictions on appeal. Defendant later filed a petition for postconviction relief, arguing that appellate counsel was ineffective for failing to raise several issues on appeal. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant could not show prejudice from his appellate counsel’s alleged errors, and therefore, the postconviction court did not abuse its discretion by denying Defendant’s postconviction motion without holding an evidentiary hearing. View "Morrow v. State" on Justia Law

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After a jury trial, Defendant was convicted of first-degree premeditated murder and other crimes. Defendant was sentenced to life imprisonment without the possibility of release. Defendant appealed, asserting a number of errors. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant’s convictions; (2) the district court did not commit reversible error when it disallowed certain defense evidence offered at trial; (3) Defendant was not denied the effective assistance of trial counsel; (4) Defendant was not entitled to a sentencing hearing under Miller v. Alabama; and (5) Defendant’s claims offered in a pro se supplemental brief lacked merit. View "State v. Robertson" on Justia Law

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Dahmes Stainless, Inc. challenged the additional use taxes and interest assessed by the Commissioner of Revenue on components that Dahmes purchased to manufacture its products. In making the assessment, the Commissioner determined that Dahmes’s products constituted improvements to real property because they were common law fixtures. The tax court disagreed, concluding that Dahmes’s products were tangible personal property rather than improvements to real property, and therefore, the Commissioner erred by assessing use taxes. Dahmes subsequently filed a Minnesota Equal Access to Justice Act (MEAJA) application for attorney fees. The tax court awarded fees, concluding that the Commissioner’s position was not “substantially justified” by a “reasonable basis in law and fact” under Minn. Stat. 15.472(a). The Supreme Court affirmed, holding (1) Dahmes’s MEAJA application for attorney fees was timely filed; and (2) the tax court did not abuse its discretion by awarding attorney fees. View "Comm’r of Revenue v. Dahmes Stainless, Inc." on Justia Law

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Appellant agreed with Respondent to rent an apartment located in Hennepin County. Respondent received the first month’s rent and security deposit but refused to deliver physical possession of the premises to Appellant. Appellant brought an unlawful exclusion petition under Minn. Stat. 504B.375 - the unlawful exclusion statute - to enforce her agreement with Respondent. The housing referee recommended granting Respondent’s motion to dismiss on the grounds that Appellant did not qualify as a “residential tenant” under the statute because she was not physically “occupying” the residential premises. The district court adopted the referee’s decision. The court of appeals affirmed. The Supreme Court reversed, holding (1) a tenant who holds the present legal right to occupy residential rental property pursuant to a lease or contract satisfies the definition of “residential tenant” under Minn. Stat. 504B.001, and (2) therefore, upon the effective date of a lease agreement, a tenant has the right to bring an unlawful removal or exclusion petition under Minn. Stat. 504B.375(1). View "Cocchiarella v. Driggs" on Justia Law

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The Commissioner of Revenue disallowed certain charitable-contribution deductions claimed on an income tax return filed by Respondents. The tax court reversed and granted summary judgment in favor of Respondents. In doing so, the court excluded evidence offered by the Commissioner of Revenue regarding a computational error made in calculating Respondents’ tax liability and thus failed to correct Respondents’ tax liability to account for the Commissioner’s computational error. The Supreme Court affirmed, holding that (1) the tax court did not abuse its discretion in excluding the Commissioner’s evidence of a computational error; and (2) the tax court’s finding regarding Respondents’ tax liability was supported by the record. View "Antonello v. Comm’r of Revenue" on Justia Law

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Respondent brought suit against Appellant by service of a summons and complaint, raising claims of negligence, assault and battery. The case was pending when Minn. R. Civ. P. 5.04(a) went into effect. The case was subsequently deemed to be dismissed with prejudice under the new Rule 5.04(a). Respondent moved to vacate the judgment under Minn. R. Civ. P. 60.02, arguing that Rule 5.04(a) violated his right o procedural due process and that relief was warranted due to excusable neglect. The district court concluded that Rule 60.02 is inapplicable to a dismissal under Rule 5.04(a) or, alternatively, that Respondent failed to establish all four requirements for relief under Rule 60.02. The court of appeals reversed and remanded. The Supreme Court affirmed as modified, holding (1) Rule 60.02 applies to a dismissal under Rule 5.04(a); (2) a dismissal under Rule 5.04(a) does not violate procedural due process; and (3) the district court failed to make findings sufficient to enable appellate review of its Rule 60.02 finding. View "Gams v. Houghton" on Justia Law

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Respondent brought a civil suit against Appellant. After Respondent transmitted the summons, complaint, and affidavit of service, Appellant filed a motion to dismiss on the grounds that Respondent failed to timely file. Respondent filed a motion to vacate under Minn. R. Civ. P. 60.02, arguing that his counsel’s admitted neglect in timely filing was excusable because of counsel’s ignorance of the law. The district court dismissed the action, concluding that ignorance of the law by Respondent’s counsel was not excusable neglect under Rule 60.02. The court of appeals reversed. The Supreme Court affirmed as modified, holding that the district court abused its discretion by failing to consider all four requirements from Finden v. Klaas. Remanded to the district court for reconsideration of Respondent’s Rule 60.02 motion. View "Cole v. Wutzke" on Justia Law

Posted in: Civil Procedure