Justia Minnesota Supreme Court Opinion Summaries

This case arose out of the foreclosure of Respondent’s townhome. Respondent’s townhome association served Respondent’s adult son with notice of the foreclosure under Minn. R. Civ. P. 4.03(a), the substitute-service rule. Respondent brought this action seeking a declaratory judgment that the foreclosure sale was legally void. The district court determined that service was ineffective under Rule 4.03(a) because Respondent’s son was not “residing” in Respondent’s townhome when the association attempted to serve Respondent. The court of appeals affirmed. The Supreme Court affirmed, holding that because Respondent’s son had not lived at Respondent’s home for an extended period when the substitute service occurred, the service was ineffective under Rule 4.03(a). View "Jaeger v. Palladium Holdings, LLC" on Justia Law

After a jury trial, Appellant was found guilty of one count of first-degree murder of a peace officer, three counts of attempted first-degree murder of a peace officer, and one count of unauthorized possession of a firearm. The Supreme Court affirmed, holding (1) the district court did not violate Defendant’s right under the Minnesota Constitution to be tried by a jury of the county or district in which the alleged offense occurred; and (2) the district court did not commit prejudicial error by refusing to sever the first-degree murder charge from the other charges in Appellant’s case for the purpose of trial. View "State v. Fitch" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder, two counts of first-degree intentional felony murder, and first-degree aggravated robbery. Appellant was sentenced to life without the possibility release for the murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress a confession he gave to police following his arrest, as the totality of the circumstances did not support Appellant’s argument that his confession to police was involuntary; and (2) the evidence was sufficient to support the jury’s verdict that Appellant committed premeditated murder. View "State v. Cox" on Justia Law

Robert Burks, a Metro Transit passenger, requested access to a recording of an exchange he had with a Metro Transit bus driver. Metro Transit, a division of Metropolitan Council, denied the request. Burks subsequently filed a complaint in district court requesting that the court require Metro Transit to release the video recording to him. The district court granted relief to Burks, determining that the recording was public data under the Minnesota Government Data Practices Act. The court of appeals affirmed. The Supreme Court affirmed, holding that Burks satisfied the prerequisites for access to the video recording because he was an “individual subject of the data.” View "Burks v. Metropolitan Council" on Justia Law

KSTP-TV (KSTP) requested videos that contained recordings of two incidents on Metro Transit buses. Metro Transit, a division of Metropolitan Council, had evaluated the conduct of the drivers of both buses but did not discipline either of them. Metro Transit refused KSTP’s requests, concluding that the videos contained private personnel data on the bus drivers, and therefore, the videos were exempt from disclosure. KSTP filed a complaint under the Minnesota Government Data Practices Act with the Office of Administrative Hearings. An administrative law judge concluded that the recordings were public data and, accordingly, that KSTP was entitled to the video data. The court of appeals affirmed. The Supreme Court reversed, holding (1) video data from public buses is personnel data under the Data Practices Act only if it is maintained exclusively because an individual subject of the data is a government employee; and (2) to determine whether particular data is personnel data under the Act, a government entity must classify the data at the time a request for access to the data is made. Remanded to the Office of Administrative Hearings for further proceedings. View "KSTP-TV v. Metropolitan Council" on Justia Law

Two churches (the Churches) located in the City of Saint Paul were subject to a right-of-way assessment (ROW assessment) that the City assessed to nearly every owner of real property within the city limits to pay for public right-of-way maintenance services. The Churches appealed their 2011 ROW assessment, arguing that the charge was a tax and was not imposed uniformly upon the same class of property and that the assessed amount improperly exceeded the special benefit to the Churches’ properties. The district court upheld the assessments after applying a reasonableness test, concluding that the ROW was not a tax imposed under the City’s taxing power but was a fee imposed under the City’s police power and, therefore, was not subject to constitutional restrictions on taxation. The court of appeals affirmed. The Supreme Court reversed, holding (1) the ROW assessment was imposed as an exercise of the City’s taxing power rather than its police power; and (2) summary judgment was inappropriate because a genuine issue of material fact existed regarding the extent of special benefits to the Churches’ properties attributable to the right-of-way services. View "First Baptist Church of St. Paul v. City of St. Paul" on Justia Law

Appellant drove her car through a red light, causing a collision with another car. A police detective applied for and was issued a warrant to search a sample of Appellant’s blood for “evidence of criminal vehicular operation.” The issuing judge found that probable cause existed for the issuance of the search. After Appellant’s blood was drawn, a toxicology report indicated that Appellant's blood contained a metabolite of THC and Alprazolam at the time of the accident. The State charged Appellant with criminal vehicular operation. Appellant filed a motion to suppress, arguing that the warrant did not provide probable cause for the police to test her blood for controlled substances. The district court granted Appellant’s motion, concluding that the blood sample was lawfully obtained under the warrant but that the subsequent testing of the blood sample for the presence of drugs was unlawful. The court of appeals reversed. The Supreme Court affirmed, holding (1) the facts alleged in the warrant application and supporting affidavit supported testing Appellant’s blood for controlled substances; and (2) the search warrant satisfied the particularity requirement in the Fourth Amendment. View "State v. Fawcett" on Justia Law

Respondents filed a class-action complaint alleging, among other claims, that MoneyMutual, LLC, which operates a website allowing individuals to apply for short-term loans known as payday loans, matched Respondents with payday lenders that were unlicensed in Minnesota and that the terms of the payday loans were illegal. MoneyMutual moved to dismiss the complaint for lack of personal jurisdiction. The district court denied the motion to dismiss, concluding that it could exercise specific personal jurisdiction over MoneyMutual based on MoneyMutual’s email correspondence with residents and advertising in Minnesota. The court of appeals affirmed. The Supreme Court affirmed, holding that sufficient minimum contacts existed for the exercise of personal jurisdiction over MoneyMutual and that exercising personal jurisdiction over MoneyMutual comported with notions of fair play and substantial justice. View "Rilley v. MoneyMutual, LLC" on Justia Law

Defendant was charged with several criminal counts. When the State’s only witness failed to appear in court, the State requested a continuance, but the district court denied the request. The State subsequently voluntarily dismissed the case and then refiled the criminal charges against Defendant. Defendant filed a motion to dismiss, arguing that the State’s approach would allow the State to circumvent the court’s denial of a continuance. The district court denied Defendant’s motion to dismiss. The court of appeals reversed, concluding that the State’s “dismiss-and-refile tactic” was an act of bad faith. The Supreme Court reversed, holding that the district court did not abuse its discretion when it denied Defendant’s motion to dismiss the refiled charges. View "State v. Olson" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree felony murder and two counts of attempted first-degree felony murder. Appellant was fifteen years old at the time of the murders. The district court imposed two mandatory sentences of life imprisonment with the possibility of release after thirty years for the murder convictions and ordered Defendant’s sentences to be served consecutively. The Supreme Court affirmed on direct appeal. Appellant later moved to correct his sentences, asserting that his sentences were void because the juvenile court failed to follow the proper adult-certification procedures before referring him to adult court. Construing Appellant’s motion to correct his sentence as a petition for postconviction relief, the postconviction court summarily denied relief, concluding that Appellant’s petition was procedurally barred under the Knaffla rule. The Supreme Court affirmed, holding that the postconviction court (1) did not err by construing Appellant’s motion to correct his sentence as a petition for postconviction relief; and (2) did not abuse its discretion by summarily dying relief because Appellant’s postconviction petition was procedurally barred. View "Ouk v. State" on Justia Law