Justia Minnesota Supreme Court Opinion Summaries

The State filed a juvenile delinquency petition against seventeen-year-old C.J.H. Defense counsel at the first appearance told the juvenile court that the parties had agreed to a “continuance for dismissal.” Without finding that the allegations in the charging document had been proved, the juvenile court continued the delinquency proceeding and, approximately nine months later, terminated the continuance. The juvenile court subsequently adjudicated C.J.H. delinquent. C.J.H. appealed, arguing that the proceedings at the first appearance constituted a “continuance without adjudication” because he unconditionally admitted the charged offense. Therefore, C.J.H. argued, under Minn. R. Juv. Delinq. P. 15.05, the juvenile court’s jurisdiction expired before he was adjudicated delinquent. The court of appeals reversed, concluding that the juvenile court’s jurisdiction expired before C.J.H. was adjudicated delinquent. The Supreme Court reversed, holding (1) the plain language of Rule 15.05 requires a juvenile court to find the allegations in the charging document to have been proven before continuing the case without adjudication; and (2) because no such finding was made in this case, the proceedings at C.J.H.’s first appearance did not constitute a continuance without adjudication. View "In re Welfare of C.J.H." on Justia Law

At issue in this case was whether truck drivers hauling asphalt cement from a commercial oil refinery to a contractor’s facility are performing “work under a contract” under Minn. Stat. 177.44(1) and, therefore, must be paid prevailing wages. The Minnesota Department of Transportation (MDOT) determined that the construction companies that were awarded contracts to work on state highway projects violated the project contracts by failing to ensure that drivers that assisted in the acquisition and transport of asphalt cement for the projects were paid prevailing wages. Appellants argued that the hauling activities of these drivers did not constitute “work under a contract” under Minn. Stat. 177.44(1) and, alternatively, that the hauling activities were exempt from the prevailing wage requirements under the “commercial establishment exception” in the Prevailing Wage Act. The district courts granted summary judgment to MDOT. The court of appeals affirmed. The Supreme Court reversed, holding that hauling activities must be to, from, or on the site of a public works project to qualify as “work under a contract,” and therefore, the hauling activities in this case did not constitute “work under the contract” subject to the prevailing wage requirements. View "J.D. Donovan, Inc. v. Minn. Dep’t of Transp." on Justia Law

When Daniel Berglund refused to file Minnesota income tax returns for tax years 2008, 2009, and 2010, the Minnesota Department of Revenue prepared and filed returns for Berglund and mailed him Notices of Commissioner Filed Returns for the relevant tax years. In total, the Commissioner of Revenue assessed $668,840 in unpaid taxes, penalties, and interest for the three-year period. Berglund appealed, arguing that because the returns did not contain the Commissioner’s signature they were invalid and unenforceable. The tax court granted the Commissioner’s motion for judgment on the pleadings, finding that the lack of a “manual signature” was of no consequence. The Supreme Court affirmed, holding that the relevant statutes do not require that the Commissioner sign commissioner-filed returns in order for those returns to be valid. View "Berglund v. Comm’r of Revenue" on Justia Law

Pursuant to a plea agreement, Appellant pleaded guilty to aiding and abetting first-degree murder and second-degree intentional murder. One year later, Appellant petitioned for postconviction relief under Minn. Stat. 590.01. The postconviction court denied relief. Defendant later filed a motion to correct his sentence pursuant to Minn. R. Crim. P. 27.03(9) challenging the validity of his guilty plea. The postconviction court denied relief on all of Appellant’s claims with the exception of a clerical error, concluding that Appellant’s claims were properly treated as requests for postconviction relief under Minn. Stat. 590.01 and that the holding in State v. Knaffla barred Appellant’s claims. Five years later, Appellant filed a motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The postconviction court denied relief, concluding that Appellant motion was, in effect, a petition for postconviction relief and that it was both untimely and Knaffla-barred. The Supreme Court affirmed, holding that the postconviction court properly dismissed Appellant’s claim as untimely. View "Johnson v. State" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

After a jury trial, Defendant was found guilty of second-degree intentional murder and second-degree felony murder. Defendant was sentenced to 306 months in prison for second-degree intentional murder. Defendant appealed, arguing that the accomplice-liability instructions given to the jury failed accurately to state the law. The court of appeals affirmed, concluding that the accomplice-liability instructions were plainly erroneous but that the error did not affect Defendant’s substantial rights. The Supreme Court reversed, holding (1) the instructions at issue were plainly erroneous; (2) Defendant met his burden of proving that the plainly erroneous jury instructions affected his substantial rights; and (3) a new trial was necessary in this case to protect the fairness, integrity, and public reputation of the judicial proceedings. View "State v. Huber" on Justia Law

Appellants, LaVonne and Henry Pfeil, were longstanding members of St. Matthew Lutheran Church. St. Matthew’s pastors decided to excommunicate Appellants due to their “slander and gossip” of the church’s leadership and ministry. At special voters’ meeting, the congregation voted to affirm the excommunication decision. LaVonne subsequently brought a lawsuit on behalf of herself and Henry against St. Matthew and its pastors (collectively, Respondents), asserting claims for defamation and negligence. After resolving Henry’s claims on other grounds, the district court dismissed the case with prejudice, concluding that the First Amendment deprived the court of jurisdiction to adjudicate LaVonne’s claims. The court of appeals affirmed. The Supreme Court affirmed, holding that that the First Amendment prohibits holding an organization or individual liable for statements made in the course of a religious disciplinary proceeding when those statements are disseminated only to members of the church congregation or the organization’s membership or hierarchy. View "Pfeil v. St. Matthews Evangelical Lutheran Church" on Justia Law

Kelly Dennis was allegedly injured in the course of his employment with The Salvation Army. Dennis filed a claim for workers’ compensation benefits, but The Salvation Army and its insurer (collectively, Relators) denied liability. The compensation judge awarded Dennis benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed. Within thirty days, Relators filed a petition for a writ of certiorari with the clerk of the appellate courts. Relators, however, failed to serve a cost bond on the WCCA as required by Minn. Stat. 176.471. Relators subsequently served an untimely cost bond on the WCCA. At issue before the Supreme Court was whether timely service of the cost bond was mandatory to have the WCCA order reviewed by the Supreme Court on certiorari. The Supreme Court discharged the writ of certiorari and dismissed the appeal, holding that Relators’ failure to file the cost bond within the thirty-day period to appeal was fatal to their appeal. View "Dennis v. Salvation Army" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree murder and two counts of second-degree murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree murder conviction. The Supreme Court affirmed on appeal. After unsuccessfully seeking postconviction relief, Appellant filed a second petition for postconviction relief, alleging that he was entitled to a new trial on two grounds. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant’s claim that the district court gave an erroneous jury instruction during trial was untimely, and the postconviction court did not abuse its discretion when it denied his petition without a hearing; and (2) Appellant was not entitled to relief in the interests of justice based on any of the issues he raised. View "Bolstad v. State" on Justia Law