Justia Minnesota Supreme Court Opinion Summaries

Respondent fell and was injured during the course of his employment with The Salvation Army. A workers compensation judge awarded Defendant benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed the findings and order of the compensation judge. Relators subsequently filed a timely petition for a writ of certiorari with the clerk of the appellate courts. Relators’ filing, however, did not include a cost bond. The clerk provided Relators with a conformed writ, which Relators served on Respondent and the WCCA. The WCCA notified the clerk of court that Relators had not served a cost bond on the WCCA as required by Minn. Stat. 176.471(3). Relators then served a cost bond on the WCCA. Respondent argued that the plain and unambiguous language of section 176.471 required timely service of a cost bond to effect the Supreme Court’s review. The Supreme Court held that because Relators did not timely serve a cost bond upon the WCCA as required by section 176.471(3) the writ of certiorari must be discharged and the appeal dismissed. View "Dennis v. The Salvation Army" on Justia Law

After a second jury trial before Judge Harvey Ginsberg, Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed Defendant’s conviction on direct appeal. In 2003, Defendant filed his first petition for postconviction relief. The postconviction court denied the petition. Before the Supreme Court decided the appeal from the denial of Defendant’s postconviction petition, the Court removed Judge Ginsberg from office. The Court subsequently affirmed the postconviction court’s judgment denying relief to Defendant. In 2014, Defendant filed a petition for postconviction relief based on Judge Ginsberg’s removal from office. The postconviction court denied the petition without holding an evidentiary hearing, concluding that the petition was both untimely filed and procedurally barred. The Supreme Court affirmed, holding that the postconviction court did not err in denying Defendant’s second petition or postconviction relief without holding an evidentiary hearing where Defendant filed his petition after the expiration of the statutory two-year limitations period, and the statutory interests-of-justice exception does not apply. View "Taylor v. State" on Justia Law

Terry Boyd filed this lawsuit against BNSF Railway Company, his former employer, under the Federal Employers’ Liability Act (FELA) after being injured in the course of his employment. Boyd later made a settlement offer, which BNSF rejected. The jury returned a verdict and award against BNSF. The district court ordered BNSF to pay double costs to Boyd pursuant to Minn. R. Civ. P. 68.03(b)(2), which provides for additional costs and disbursement incurred after an offer is rejected by a defendant and the relief awarded is less favorable to the defendant than the rejected offer. BNSF sought review, arguing that an award of double costs under Rule 68.03(b)(2) is preempted by FELA. The court of appeals affirmed. The Supreme Court reversed, holding that because double costs are substantive, rather than procedural, and are not authorized by federal law, FELA preempts the application of Rule 68.03(b)(2) in a state court FELA action. View "Boyd v. BNSF Railway Co." on Justia Law

Plaintiff, a former employee of the Minneapolis Public Schools (MPS), was notified on April 22, 2008 that her position would be eliminated. Plaintiff’s last day of work was June 30, 2008. Plaintiff commenced this lawsuit against MPS on June 29, 2010, asserting retaliation in violation of the Minnesota Whistleblower Act (MWA). The district court dismissed Plaintiff’s MWA claim on statute of limitations grounds. The court of appeals reversed, concluding that Plaintiff’s claim was subject to a six-year limitations period, as provided by Minn. Stat. 541.05(1)(2). On appeal, MPS argued that Plaintiff’s claim was subject to the two-year limitations period found in Minn. Stat. 541.07(1). The Supreme Court affirmed, holding that Plaintiff’s cause of action was governed by the six-year statute of limitations found in section 541.05(1)(2). View "Ford v. Minneapolis Public Schools" on Justia Law

Defendant pleaded guilty pursuant to an Alford plea to fifth-degree criminal sexual conduct. Jane Doe subsequently sued Defendant, alleging that he committed sexual battery and sexual abuse based on the conduct that gave rise to the criminal charges. Prior to trial, Defendant brought a motion in limine to prevent Doe from introducing evidence of the Alford plea. The district court granted the motion, concluding that any mention of the Alford plea would be substantially more prejudicial to Defendant than probative to Doe’s case. After a jury trial, Defendant was found not liable for sexual assault and battery. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by declining to admit Defendant’s Alford plea under Minn. R. Evid. 403; and (2) did not abuse its discretion when it did not allow Defendant’s Alford plea to be admitted for impeachment purposes. View "Jane Doe 136 v. Liebsch" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The Supreme Court affirmed. Appellant later filed his current petition for postconviction relief alleging that a witness had recanted his trial testimony. After an evidentiary hearing to determine the credibility of the alleged recantation, the postconviction court denied the petition, concluding that “it was not well satisfied that the trial witness’s testimony was false.” The Supreme Court affirmed, holding (1) Appellant failed to prove that the State substantially interfered with the decisions of Appellant’s witnesses about whether to testify at the postconviction hearing; and (2) the postconviction court did not abuse its discretion by refusing to grant use immunity to Appellant’s witnesses or by finding that Appellant presented insufficient evidence to warrant a new trial. View "McKenzie v. State" on Justia Law

Respondents, Angela Lennartson and Katie Foss, were involved in separate car accidents and recovered damages in their respective negligence actions. Subsequently, each respondent was awarded no-fault benefits from their insurer, State Farm, in arbitration proceedings under the Minnesota No-Fault Insurance Act (No-Fault Act). State-Farm moved to vacated the arbitration awards, arguing, inter alia, that collateral estoppel barred the no-fault arbitrations. The district court granted State Farm’s motion to vacate in Lennartson’s case and denied it in Foss’s case. The cases were consolidated on appeal. The court of appeals affirmed the decision in favor of Foss and reversed the decision against Lennartson, concluding that neither the No-Fault Act nor collateral estoppel barred the arbitrators’ awards of no-fault benefits to Respondents.The Supreme Court affirmed, holding (1) the No-Fault Act does not bar an insured from recovering no-fault benefits for medical expenses previously recovered in a negligence action; and (2) collateral estoppel does not bar an insured from seeking medical-expense or income-loss benefits in no-fault arbitration recovering damages for the same expenses or losses in a negligence action. View "State Farm Mut. Auto. Ins. Co. v. Lennartson" on Justia Law

In 2008, Appellant was convicted of first-degree premeditated murder. The district court sentenced Appellant to life imprisonment and reserved the issue of restitution for thirty days. The court, however, took no further action on the restitution issue until 2014, when the court granted the restitution request and ordered Appellant to pay $6,500 in restitution. Appellant filed a motion to stop the restitution payments and return the funds taken. The district court denied the motion, concluding that Appellant had properly been served with the restitution request and had failed to timely object to it. The Supreme Court affirmed as modified, holding (1) the district court had the statutory authority to order restitution and did not abuse its discretion in ordering Appellant to pay $6,500 in restitution; and (2) the court properly denied Appellant’s motion to return the funds taken, as the motion was not properly before the district court. View "State v. Anderson" on Justia Law

The State charged Appellant with aiding and abetting first-degree sale of a mixture of a controlled substance of ten grams or more in connection with the sale of methamphetamine. During trial, Appellant objected to the admission of test results by the Minnesota Bureau of Criminal Apprehension (BCA) that confirmed the substance was methamphetamine, arguing that the BCA results were unreliable because the contents of the bags might have been contaminated while the bags were in the custody of the St. Paul Police Crime Lab, which had been investigated for deficiencies in its quality-assurance controls. The district court rejected Appellant’s contamination argument, and Appellant was subsequently convicted of the charged offense. The court of appeals affirmed. Before the Supreme Court, Appellant asked that the Court adopt a new standard that would presume that all evidence processed through the Crime Lab is contaminated and inadmissible unless the State can prove the absence of contamination. The Supreme Court affirmed, holding that the invocation of the Court’s supervisory powers to adopt Respondent’s requested presumption of contamination is not required to ensure the fair administration of justice, and constitutional principles do not require the rebuttable presumption Appellant proposed. View "State v. Hill" on Justia Law

As a condition of his probation from a prior conviction, Respondent was required to attend anger-management therapy sessions with N.M., a mental-health practitioner. During one session, Respondent made a threatening statement about a caseworker assigned to a child-protection case involving Respondent’s children. N.M. determined that Respondent’s statements triggered her statutory duty to warn and reported the statements to the police. The State charged Respondent with one count of making terroristic threats. The jury found Respondent guilty. Respondent appealed, asserting that N.M.’s testimony was inadmissible under the therapist-client privilege. The court of appeals reversed, concluding (1) the therapist-client privilege is not subject to a “threats exception”; and (2) Respondent’s privileged statements were inadmissible through the testimony of any witness, including D.P. The Supreme Court affirmed as modified, holding (1) the statute does not contain a threats exception; (2) the privilege does not apply to the testimony of third parties who learn of confidential information shared by a client with his or her therapist; and (3) Respondent was entitled to a new trial due to N.M.’s disclosure of privileged information at trial. View "State v. Expose" on Justia Law