Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of three counts of first-degree murder. The district court imposed three concurrent life sentences. Fifteen years after the Supreme Court affirmed Defendant’s convictions and the denial of his first postconviction motion, Defendant filed this fourth petition for postconviction relief, alleging that a confession witness recanted her testimony that Defendant confessed to the murder. The postconviction court summarily denied relief, holding that Defendant’s petition was untimely and that Defendant’s previously raised recantation claims were procedurally barred under State. v. Knaffla. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in concluding that Defendant’s petition was untimely and that his previously raised claims were Knaffla-barred. View "Hooper v. State" on Justia Law

In 2008, Respondent pleaded guilty to failing to register as a predatory offender. The district court sentenced Respondent to one year and one day in prison. In 2009, the district court sua sponte modified Respondent’s sentence to include a ten-year conditional release term. More than four years later, Respondent brought a motion under Minn. R. Crim. P. 27.03(9) to correct his sentence, arguing that the conditional release term violated Blakely v. Washington. The district court treated Respondent’s motion as a petition for postconviction relief and determined that the expiration of the two-year limitations period in the postconviction statute required the dismissal of Respondent’s claim. The court of appeals reversed, concluding that Respondent’s challenge to his conditional release term could be brought at any time because it fell within the scope of Rule 27.03(9) and that the imposition of the conditional release term violated Respondent’s Sixth Amendment right to a jury trial. The Supreme Court affirmed, holding (1) Respondent’s challenge was properly brought under Rule 27.03(9); and (2) applying the two-year limitations period in the postconviction statute to a motion brought under Rule 27.03(9) violates the separation of powers. View "Reynolds v. State" on Justia Law

Defendant was convicted of first-degree assault for pushing D.E. twice in the chest, causing D.E. to stumble into a nearby bonfire and sustain burn injuries. The court of appeals affirmed. Defendant appealed, arguing that the evidence was insufficient to sustain her conviction because she did not intentionally harm D.E. and her actions did not directly cause D.E.’s injuries. The Supreme Court affirmed, holding that the evidence was sufficient to sustain Defendant’s conviction for first-degree assault because (1) Defendant’s application of force to D.E. was “intentional,” (2) Defendant’s conduct constituted a battery and was therefore an “infliction” of harm, and (3) Defendant’s conduct was the direct cause of D.E.’s injuries. View "State v. Dorn" on Justia Law

Defendant pled guilty to felony domestic assault in district court. Following sentencing, Ramsey County Community Corrections notified the district court that Defendant was required to register as a predatory offender due to his conviction. Defendant filed a motion to withdraw his guilty plea on the ground that he had not been aware that his conviction would trigger the requirement to register as a predatory offender. The district court denied the request. The court of appeals affirmed. The Supreme Court affirmed, holding that a defense attorney’s failure to advise a defendant about predatory offender registration requirements before the defendant enters a plea of guilty does not violate a defendant’s right to effective assistance of counsel, and therefore, Defendant was not entitled to withdraw his guilty plea. View "Taylor v. State" on Justia Law

Appellant, who was injured in a car accident, sought basic economic loss benefits under Minnesota’s No-Fault Automobile Insurance Act from his insurer, Founders Insurance Company. An arbitrator awarded Appellant $19,128 in basic economic loss benefits. The district court confirmed the arbitration award. The court of appeals reversed, concluding that the Founders was not required to provide basic economic loss coverage because Founders was an out-of-state insurer that did not write motor vehicle insurance in Minnesota. The Supreme Court reversed, holding that Minn. Stat. 65B.50(2) requires an out-of-state insurer to provide no-fault benefits to its insured when its insured is in an accident in Minnesota and the insured vehicle is in Minnesota, even if the insurer is not licensed by the state to issue motor vehicle insurance. View "Founders Insurance Co. v. Yates" on Justia Law

Appellant was charged with second-degree controlled substance crime, driving after revocation, and possession of drug paraphernalia. Appellant moved to suppress evidence obtained during a search of his vehicle during a traffic stop, asserting that the police illegally expanded the scope and duration of the stop without a reasonable, articulable suspicion. The district court agreed with Appellant, granted his motion to suppress, and dismissed the charges. The court of appeals reversed, concluding that the search was justified by reasonable suspicion. The Supreme Court affirmed, holding that, applying de novo review to the undisputed facts, the district court erred in suppressing the drug evidence discovered as a result of a dog-sniff and the ensuing search because police had a reasonable, articulable suspicion of drug activity that supported the expansion of the vehicle stop. View "State v. Lugo" on Justia Law

Jerry Expose underwent therapy at Thad Wilderson & Associates, P.A. (the Clinic). During one of his therapy sessions with Nina Mattson, an unlicensed intern-therapist, Expose made statements that threatened serious injury to a particular individual. Mattson reported the threats, and a jury found Expose guilty of making terroristic threats. The court of appeals reversed, concluding that the therapist-client privilege prohibited Mattson from testifying about information she learned during Expose’s therapy sessions. Before appealing, Expose filed suit against the Clinic and Mattson (collectively, Appellants). The district court concluded that Appellants were immune from liability under the common law doctrine of absolute privilege. The court of appeals reversed on all issues except the immunity under the doctrine of absolute privilege as to the testimony from the criminal trial. The Supreme Court affirmed, holding (1) an unlicensed intern-therapist has no statutory duty to disclose to law enforcement information regarding a serious threat of physical violence made against an identifiable person; (2) the doctrine of absolute privilege does not shield the disclosures made by an unlicensed intern-therapist to law enforcement and to prosecutors; and (3) a consent form notifying a client of the client’s rights under the Minnesota Health Records Act does not authorize the release of the client’s medical records. View "Expose v. Thad Wilderson & Associates, P.A." on Justia Law

Respondents submitted a petition to the Minneapolis Charter Commission to amend the City Charter to establish a local minimum-wage standard in the City of Minneapolis. The City Clerk certified that the petition met the statutory signature requirements. Reasoning that the minimum-wage amendment was legislature in nature and that the City Charter does not provide for voter initiatives for the passage of ordinances by a ballot referendum, the City Attorney recommended that the City Council decline to place the provision on the November 2016 general election ballot. Thereafter, the City Council voted not to include the wage amendment on the ballot for the general election. Respondents filed a petition asking the district court to order the City Council to place the proposed charter amendment before the voters on the ballot, arguing that the City had a duty to put the proposed amendment on the ballot. The district court granted the petition, concluding that the proposed charter amendment was the proper subject of a citizen initiative. The Supreme Court reversed, holding that the district court erred in granting the petition because Minneapolis residents do not have legislative and policymaking authority under the City Charter. View "Vasseur v. City of Minneapolis" on Justia Law

Appellant was charged with the issuance of a dishonored check in violation of the dishonored-check statute when her check for past-due property taxes was returned by her bank for insufficient funds. The district court dismissed the criminal complaint, concluding that Appellant’s check for past-due property taxes met the statutory exception for “a check given for a past consideration” because there was no contemporaneous exchange of goods or services for the check. The court of appeals reversed. The Supreme Court reversed, holding (1) “a check given for a past consideration” refers to a check given for a good or service that was received in the past; and (2) because Appellant’s check for past-due property taxes was given, in part, for government services provided in the previous year, her check was “given for a past consideration.” View "State v. Schouweiler" on Justia Law

Defendant pleaded guilty to first-degree sexual conduct. Defendant’s sentence consisted of a term of imprisonment, a supervised-release term, and a conditional-release term. After Defendant was released from prison on supervised release, a hearing officer found that Defendant had violated the terms of his supervised release, revoked his supervised release, and ordered him returned to prison. The Department of Corrections (DOC) later informed Defendant that it had recalculated the projected expiration date of his conditional-release term in light of two recent decisions from the court of appeals. Defendant filed a habeas petition alleging that the DOC’s new method for calculating the expiration date of his conditional-release term was illegal because it did not give him credit for the time he had spent in prison after the DOC had revoked his supervised release. Defendant was subsequently released into the community. Thereafter, the district court denied Defendant’s petition for writ of habeas corpus. The Supreme Court affirmed, holding that an inmate is not entitled to credit against a conditional-release term for any time the inmate spends in prison after the DOC has revoked the inmate’s supervised release. View "State v. Roy" on Justia Law