Justia Minnesota Supreme Court Opinion Summaries

In this case, the Governor of Minnesota issued a writ of special election on December 27, 2024, to fill a vacancy in the office of State Representative for District 40B in Ramsey County. The writ scheduled the special election for January 28, 2025. The Minnesota Voters Alliance, two voters from House District 40B, and the Republican Party of Minnesota challenged the writ, arguing it was issued prematurely.The Ramsey County District Court had previously ruled on December 20, 2024, in an election contest brought by Paul Wikstrom against Curtis Johnson, the elected representative for House District 40B. The court found that Johnson did not meet the residency requirement to serve as the district's representative. No appeal was filed against this decision. Johnson subsequently sent a letter to the Governor on December 27, 2024, stating he would not accept his seat and resigned effective immediately.The Minnesota Supreme Court reviewed the case and determined that the writ of special election was issued prematurely. The court held that Minnesota Statutes section 204D.19, subdivision 4, which governs the timing of special elections following a successful election contest, required the writ to be issued 22 days after the start of the legislative session unless the house passed a resolution regarding the court's determination. The court found that Johnson's letter did not create a vacancy that allowed for the writ's issuance on December 27, 2024, as he was not an incumbent and could not resign from an office he did not hold.The Minnesota Supreme Court granted the petition, quashed the writ of special election, and ordered the cancellation of the special election scheduled for January 28, 2025. View "Minnesota Voters Alliance v. Walz" on Justia Law

A minor, through his mother, filed a lawsuit against Best Academy after his teacher, Aaron Hjermstad, sexually assaulted him. Hjermstad had a history of sexual abuse allegations from his previous employment, which Best Academy did not uncover during their hiring process. The school did not obtain reference letters or contact references, which were part of their hiring protocol.The district court granted summary judgment in favor of Best Academy, reasoning that hiring decisions are always protected by the discretionary-function exception to municipal tort liability under Minnesota Statutes section 466.03, subdivision 6. The court of appeals affirmed this decision, applying the same reasoning.The Minnesota Supreme Court reviewed the case and concluded that a municipality’s hiring decision is not categorically a policy-level decision involving weighing competing economic, social, political, and financial considerations. The court emphasized that the discretionary-function exception should be interpreted narrowly and that municipalities bear the burden of proving that their conduct involved such considerations. The court found that Best Academy did not provide evidence that its decision not to investigate Hjermstad’s background was based on balancing policy considerations. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "Minor Doe 601 v. Best Academy" on Justia Law

Hollydale Land LLC (Hollydale) owned a golf course in Hennepin County, Minnesota, which was taxed under the Minnesota Open Space Property Tax Law. This law allows for reduced tax assessments on properties used for recreational purposes, with deferred taxes calculated based on the difference between the market value and the reduced value. When Hollydale sold the golf course, Hennepin County assessed seven years of deferred taxes totaling $2,622,720.41. Hollydale paid the amount but contested the calculation, arguing that the County failed to cap the market value at the bona fide sale price.Hollydale filed a petition in district court, later transferred to the tax court, challenging the County's assessment. Hennepin County moved to dismiss the petition, arguing it was untimely because Hollydale should have challenged the valuations annually. The tax court denied the motion, holding that the petition was timely as it was filed within 60 days of the notice of deferred taxes, thus the tax court had jurisdiction.Hennepin County sought certiorari review of the tax court's order. The Minnesota Supreme Court reviewed whether the tax court's order denying the motion to dismiss was a "final order" under Minn. Stat. § 271.10, subd. 1, which would allow for immediate appeal. The court reaffirmed its decision in Beuning Family LP v. County of Stearns, which held that such orders are not final and thus not immediately appealable. The court also declined to exercise discretionary review under Minn. R. Civ. App. P. 105.1, finding no compelling reason for immediate appeal and determining that judicial economy would be better served by allowing the tax court to resolve the merits of the case.The Minnesota Supreme Court dismissed the writ of certiorari, concluding that the tax court's order was not a final order and that the interests of justice did not warrant discretionary review. View "County of Hennepin v. Hollydale Land LLC" on Justia Law

A deputy from the Ramsey County Sheriff’s Department stopped Kyaw Be Bee’s vehicle on a public roadway in Saint Paul and found a BB gun under the driver’s seat. Bee was charged with carrying a BB gun in a public place, a gross misdemeanor under Minn. Stat. § 624.7181, subd. 2 (2024). The statute defines “public place” to include property owned or controlled by a governmental unit and private property open to the public, excluding certain private properties and specific locations.The district court dismissed the complaint for lack of probable cause, ruling that the interior of a motor vehicle on a public roadway is not a “public place” under the statute. The State appealed, and the Minnesota Court of Appeals reversed the district court’s decision. The appellate court held that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway, referencing the statutory context and a related exemption for transporting firearms in vehicles.The Minnesota Supreme Court reviewed the case to determine whether the interior of a private motor vehicle on a public road is a “public place” under Minn. Stat. § 624.7181, subd. 1(c). The court concluded that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway. The court reasoned that the statute’s exemptions and related provisions indicate that a motor vehicle on a public road is considered a public place. Consequently, the Supreme Court affirmed the decision of the court of appeals, reinstating the charge against Bee. View "State of Minnesota vs. Bee" on Justia Law

In 2018, Joshua Chiazor Ezeka was convicted by a Hennepin County jury of first-degree premeditated murder, first-degree attempted murder, and second-degree assault for killing Birdell Beeks while shooting at a rival gang member. He was sentenced to life in prison without the possibility of release for the murder, and additional consecutive sentences for the other charges. On direct appeal, the Minnesota Supreme Court affirmed his convictions but remanded for resentencing on the attempted murder charge due to an excessive sentence.After resentencing, Ezeka filed a petition for postconviction relief in 2022, which the district court denied without an evidentiary hearing. The district court concluded that even if the facts alleged in the petition were proven, Ezeka was not entitled to relief. The court also found that most of his claims were procedurally barred as they were known or should have been known at the time of his direct appeal.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the new evidence presented by Ezeka, including reports of general discriminatory practices by the Minneapolis Police Department and the Hennepin County Attorney’s Office, did not meet the legal standard for newly discovered evidence as it did not directly pertain to his case and would not have changed the trial's outcome. The court also found that the alleged failure to disclose this evidence did not constitute a Brady violation as it was not material to the case.Additionally, the court rejected Ezeka’s claims of ineffective assistance of trial and appellate counsel, concluding that his trial counsel’s performance was not objectively unreasonable and that there was no prejudice resulting from the alleged deficiencies. The court determined that the district court did not abuse its discretion in summarily denying the petition for postconviction relief. View "Ezeka vs. State of Minnesota" on Justia Law

Edgard Francisco Talave Latino was charged with misdemeanor domestic assault after an incident with M.T.L., with whom he had a prior romantic and sexual relationship. Latino and M.T.L. met in 2020 and had an on-again, off-again relationship that ended in November 2021. Shortly after their breakup, Latino went to M.T.L.'s apartment, where an argument ensued, and he assaulted her.The district court found Latino guilty of misdemeanor domestic assault, determining that he and M.T.L. had been involved in a significant romantic or sexual relationship, thus meeting the statutory definition of "family or household member." Latino waived his right to a jury trial, and the district court made this finding based on the evidence presented.Latino appealed, arguing that the statutory definition of "family or household member" should only apply to current relationships, not former ones. The Minnesota Court of Appeals disagreed, affirming the conviction by referencing its decision in Sperle v. Orth, which held that former relationships could qualify under the statute. The court of appeals concluded that the evidence was sufficient to prove that Latino and M.T.L. had been in a significant romantic or sexual relationship.The Minnesota Supreme Court reviewed the case to determine whether the statutory definition of "family or household member" includes former significant romantic or sexual relationships. The court held that the definition does include former relationships, subject to the statutory factors of length, type, frequency of interaction, and time since termination. The court found that the evidence was sufficient to support the district court's finding that Latino and M.T.L. had been involved in such a relationship, affirming the decision of the court of appeals. View "State vs. Talave Latino" on Justia Law

Deborah Jane Clapp, a Minneapolis homeowner and taxpayer, filed a declaratory judgment action against the Minneapolis Public Schools and its officials. Clapp challenged the constitutionality of racial and ethnic preference provisions in a collective bargaining agreement between the school district and its teachers' union. She sought to stop the school district from implementing and spending public money on these provisions, alleging they violated the Minnesota Constitution's Equal Protection Guarantee.The district court dismissed Clapp's complaint, ruling that she lacked standing and that her claims were not ripe. Clapp appealed, and the Minnesota Court of Appeals reversed the district court's decision, concluding that Clapp had taxpayer standing and that her claims were ripe for judicial review. The school district then petitioned for review by the Minnesota Supreme Court.The Minnesota Supreme Court reviewed the case and focused on the issue of taxpayer standing. The court held that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. In this case, the court found that the alleged unlawful disbursements were merely incidental to the central dispute, which was the constitutionality of the racial and ethnic preference provisions in the collective bargaining agreement. Therefore, Clapp lacked taxpayer standing to bring her claims. The court reversed the decision of the court of appeals, upholding the district court's dismissal of Clapp's complaint. View "Clapp vs. Sayles-Adams" on Justia Law

Berry Alexander Davis was involved in the kidnapping and murder of Monique Baugh and the attempted murder of her boyfriend, Jon, on New Year’s Eve in 2019. Baugh was abducted, placed in a U-Haul truck, and fatally shot. Davis and a co-defendant, Cedric Lamont Berry, were charged with first-degree premeditated murder, attempted first-degree premeditated murder, and kidnapping. The State's theory was that Davis and Berry attacked Jon on behalf of Lyndon Wiggins, who had a falling out with Jon. Detective Briana Johnson testified about the relationship between Davis, Berry, and Wiggins, indicating they were involved in drug dealing together. Davis waived his right to testify, and the jury found him guilty on all counts. He was sentenced to life in prison without the possibility of release.On direct appeal, Davis argued that the district court erred in joining his trial with Berry’s and that Detective Johnson’s testimony was inadmissible and prejudicial. The Minnesota Supreme Court rejected these arguments and affirmed his conviction and sentence. Davis also filed a pro se supplemental brief raising several claims, including that his sentence violated his constitutional right to a sentencing jury under Blakely v. Washington. The court found these claims lacked merit.Davis subsequently filed a postconviction petition alleging ineffective assistance of trial and appellate counsel and constitutional violations in his sentencing. The district court summarily denied the petition without an evidentiary hearing, concluding that even if Davis proved the facts alleged, he would not be entitled to relief as a matter of law.The Minnesota Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the district court did not abuse its discretion in denying Davis’s postconviction petition without an evidentiary hearing, as his claims failed on their merits as a matter of law. View "Davis vs. State" on Justia Law

In 2018, Ricky Darnell Waiters was convicted of first-degree felony murder, attempted first-degree felony murder, and drive-by shooting for an incident where he shot two people in a bar parking lot, killing one and wounding the other. Waiters admitted to the shooting but claimed self-defense. His convictions were affirmed on direct appeal. Subsequently, Waiters filed multiple motions for postconviction relief, which the district court construed as petitions for postconviction relief and denied each time.Waiters filed a new petition for postconviction relief in November 2023, seeking reversal of his convictions or a new trial based on claims of ineffective assistance of counsel, prosecutorial misconduct, erroneous evidentiary rulings, and insufficient evidence. The district court summarily denied the petition without a hearing and without providing reasons for the denial.The Minnesota Supreme Court reviewed the case and found that the record did not disclose the basis for the district court’s decision. The Supreme Court could not determine whether the district court had considered Waiters’s claims. Therefore, the Supreme Court reversed the district court’s decision and remanded the case for further proceedings to ensure that the district court properly considers and addresses Waiters’s claims for postconviction relief. View "Waiters vs. State" on Justia Law

Robert Lee Baker, III, was charged with second-degree intentional murder after he shot and killed Maurice Anderson. The incident occurred after Anderson and an accomplice robbed Baker and his girlfriend at gunpoint while they were in a car. As the robbers were leaving with Baker's property, Baker exited the car with a firearm and demanded the return of his belongings. Anderson raised his gun in response, and Baker shot him multiple times, resulting in Anderson's death.At trial, Baker claimed self-defense and defense of others, but the district court refused to instruct the jury on these defenses. The court concluded that Baker was not entitled to the instructions because he failed to establish that he was not the initial aggressor and that he did not have a reasonable means to retreat. The jury found Baker guilty of second-degree intentional murder, and he was sentenced to 438 months in prison. The court of appeals affirmed the conviction, but on different grounds, concluding that Baker's use of deadly force was unreasonable as a matter of law.The Minnesota Supreme Court reviewed the case to determine whether the district court abused its discretion by refusing to instruct the jury on self-defense and defense of others. The court held that the proper standard for determining whether a defendant is entitled to a jury instruction on self-defense or defense of others is whether the defendant produced reasonable evidence to support their claim. The court concluded that Baker presented sufficient evidence to support his claims of self-defense and defense of others, and that the district court's failure to give these instructions was not harmless. Therefore, the Minnesota Supreme Court reversed the decision of the court of appeals and remanded the case for a new trial. View "State of Minnesota vs. Baker" on Justia Law