Justia Minnesota Supreme Court Opinion Summaries

Daniel Moulton filed an affidavit of candidacy for Third Judicial District Seat 16 in the 2016 primary election. With his affidavit of candidacy, Moulton included proof that he was licensed to practice law in Minnesota. The Secretary of State and Attorney General allowed a county auditor to strike Moulton’s name from the primary election ballot on the grounds that Moulton had failed to comply with the requirements of Minn. Stat. 204B.06(8) because he did not provide a copy of his attorney license during the filing period. Moulton subsequently filed a petition asking the Supreme Court to direct the Secretary of State to include his name on the primary election ballot. The Supreme Court granted the petition, holding that Moulton complied with the statutory requirements for filing as a candidate for judicial office. View "Moulton v. Simon" on Justia Law

The Minnesota Department of Human Services (DHS) assessed surcharges against seven hospitals and hospital systems (collectively, the Hospitals) on their net patient revenue under Minn. Stat. 256.957(2). The Hospitals appealed their surcharge assessments for various months, alleging that federal law preempted the surcharge to the extent it required them to pay a surcharge on revenues obtained from insurance carriers that participated in the Federal Employee Health Benefits Program and the TRICARE program. The Commissioner of DHS denied the claim. The court of appeals affirmed. The Supreme Court affirmed, holding that the surcharge was not preempted by federal law. View "In re Consolidated Hosp. Surcharge Appeals of Gillette Children’s Specialty Healthcare" on Justia Law

Appellant pleaded guilty to possession of a firearm by an ineligible person and second-degree assault. The district court imposed an upward durational sentencing departure for the possession conviction on the grounds that Appellant fired the gun six times in a park filled with children, thereby putting a large number of individuals in real and significant danger of bodily harm. On appeal, Appellant contended that “the firing of the gun related only to the assault conviction and that the conduct underlying the assault conviction could not be used to support an upward departure for the possession conviction.” The Supreme Court affirmed, holding that the plain language of Minn. Stat. 244.10(5)(a)(b) authorized the upward departure, as the firing of the gun made Appellant’s illegal possession of the gun more egregious than the typical possession offense, even if the firing of the gun was part of the same course of conduct as the assault offense. View "State v. Fleming" on Justia Law

Blandin Paper Company (Blandin) owned 4,680 parcels of timberland located in Aitkin, Itasca, St. Louis, and Koochiching Counties (the Counties). Blandin challenged tax assessments of market value for the timberland properties. Before trial, the Counties filed a motion to exclude evidence Blandin offered regarding the unit-rule method for determining the market value of the property at issue. The tax court denied the motion, determining that the unit-rule method is admissible in property tax proceedings. At trial, the court adopted Blandin’s appraisal values based on the unit-rule method and reduced the assessor's aggregate market value of the properties. The Supreme Court reversed, holding (1) the unit-rule method to determine the fair market value of real property may be admissible in a property tax proceeding; (2) the record in this case does not establish that the appraisal evidence offered by Blandin satisfied the requirements set forth in this opinion for admitting such evidence; and (3) the case must be remanded for both parties to have the opportunity to present evidence in favor of their respective positions. View "County of Aitkin v. Blandin Paper Co." on Justia Law

The Minnesota Department of Transportation (MnDOT) contracted with Mathy Construction Company for a public highway project. Mathy subcontracted with Storms, Inc. for excavation and fill work. After Storms completed its work, MnDOT issued a deductive change order reducing Mathy’s contract amount by $327,064 because of errors in the estimated quantities of excavation and fill required for Storms’ work. Mathy reduced Storms’ subcontract by the same amount. Storms subsequently sued Mathy for the reduction in the subcontract price. The district court granted summary judgment in favor of Storms, concluding that Mathy had breached the subcontract. The court of appeals affirmed. The Supreme Court reversed, holding that Mathy did not breach its subcontract with Storms by issuing a corresponding deductive change order to Storms. View "Storms, Inc. v. Mathy Constr. Co." on Justia Law

In 2006, Appellant was found guilty of murder. The Supreme Court affirmed on appeal. In 2013, Appellant filed a petition for postconviction relief, asserting that certain medical evidence, known to Appellant at the time of his direct appeal, contradicted the opinion testimony of the State’s medical expert at trial. The postconviction court denied the petition, concluding that the petition was not timely filed and was procedurally barred under the Knaffla rule. The Supreme Court affirmed, holding that the the postconviction court did not err in summarily dismissing Appellant’s petition because it was untimely under Minn. Stat. 590.01(4)(a). View "Jones v. State" on Justia Law

Appellant pleaded guilty to one count of failure to register as a predatory offender. Appellant later filed a petition for postconviction relief seeking to withdraw his guilty plea on the ground that it was inaccurate and lacked an adequate factual basis. The postconviction court denied the petition, concluding that it was untimely under Minn. Stat. 590.01(4)(c). The court of appeals affirmed. On appeal, Appellant argued that the postconviction court was required to consider his petition on the merits because the State forfeited its right to assert section 590.01(4)(c) as an affirmative defense. The Supreme Court reversed, holding (1) when the State fails to raise the time limits set forth in section 590.01(4)(a) and (c), the postconviction court has the discretion to consider the time limits on its own motion, but before ruling on the issue, the court must give notice to the parties and an opportunity to be heard; and (2) because the postconviction court in this case failed to give the parties notice that it intended to consider on its own motion the statute of limitation in section 590.01(4)(c), the case must be remanded to allow the parties the opportunity to be heard on the timeliness of Appellant’s petition. View "Weitzel v. State" on Justia Law

Whitney National Bank (Whitney) obtained a judgment against Daniel Fitzpatrick and his business entities (collectively, Fitzpatrick). In a separate matter, Fitzpatrick, represented by O’Brien & Wolf, LLP, obtained a judgment against the City of Oronoco. Whitney served a garnishment summons on the City to establish and perfect a garnishment lien against the judgment proceeds won by Fitzpatrick. O’Brien subsequently filed a motion to establish and determine the amount and priority of its attorney’s lien. The district court held that Whitney’s garnishment lien was superior to O’Brien’s attorney’s lien, concluding that a cause-of-action attorney’s lien is perfected, as against third parties, from the time the attorney files notice of the lien claim. The court of appeals reversed. The Supreme Court affirmed, holding that the plain language of Minn. Stat. 481.13(1)(a)(1) does not require an attorney with a cause-of-action attorney’s lien to file notice of the lien claim for the lien to have priority over third-party claims. View "City of Oronoco v. Fitzpatrick Real Estate, LLC" on Justia Law

Appellant, a board-certified psychiatrist, was previously employed at the Minnesota Security Hospital in Saint Peter, Minnesota. After Appellant’s employment was terminated, Appellant filed suit against Respondents, alleging defamation and violations of the Minnesota Government Data Practices Act (MGDPA) based on statements made by the individual respondents regarding Appellant’s termination. Respondents filed a motion for summary judgment, arguing that they did not violate the MGDPA because the statements at issue were based upon public information and that the individual respondents had an absolute or qualified privilege. The district court denied the motion. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in granting summary judgment to Respondents on Appellant’s MGDPA claim; and (2) the deputy commissioner of the Department of Human Services was entitled to the protection of absolute privilege. View "Harlow v. State Dep’t of Human Servs." on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder. Appellant was sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on direct appeal. After unsuccessfully seeking postconviction relief in three successive petitions, Appellant filed the present petition for postconviction relief, arguing again that his right to effective assistance of counsel was violated and that the Supreme Court applied the wrong precedent in assessing this claim during his direct appeal. The postconviction court denied the petition as both untimely and procedurally barred. The Supreme Court affirmed, holding that Appellant’s petition was untimely and therefore frivolous and was properly denied. View "Brocks v. State" on Justia Law