Justia Minnesota Supreme Court Opinion Summaries

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After a jury trial, Appellant was convicted of six counts of soliciting and promoting prostitution and conspiracy to commit sex trafficking. The district court sentenced Appellant to an aggregate sentence of 432 months’ imprisonment. The court of appeals affirmed. The Supreme Court affirmed the convictions, holding (1) the statute that criminalizes the promotion and solicitation of prostitution is not substantially overbroad under the First Amendment; (2) the district court gave plainly erroneous accomplice-liability jury instructions, but the instructions did not affect Appellant’s substantial rights; and (3) the evidence presented at trial was sufficient to support Appellant’s convictions. View "State v. Washington-Davis" on Justia Law

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Darek Jon Nelson pleaded guilty to first-degree premeditated murder and was sentenced to life in prison without the possibility of release. The postconviction court subsequently denied Nelson's petition for postconviction relief asking to withdraw his guilty plea. In this case, the record clearly shows that Nelson understood the charges against him, understood the rights he was waiving, and understood the consequences of his plea. Therefore, the court affirmed the judgment, concluding that Nelson did not meet his burden to show that his guilty plea was not entered intelligently, accurately, or voluntarily. View "Nelson v. State of Minnesota" on Justia Law

Posted in: Criminal Law
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After the Commissioner denied Kimberly-Clark's corresponding refund claims that accompanied amended corporate franchise tax returns, Kimberly-Clark appealed to the tax court. Kimberly-Clark argued that its refund claims were allowable because the Legislature’s enactment of the Multistate Tax Commission’s apportionment formula was a contractual obligation that was unconstitutionally impaired when the 1987 Legislature repealed the provisions that authorized the use of that formula. The Minnesota Tax Court concluded that the Legislature’s 1987 repeal of the apportionment formula was constitutional and therefore the Commissioner properly denied Kimberly Clark’s refund claims. Kimberly-Clark petitioned for review. The court concluded that the Legislature made no unmistakable commitment in 1983 when it enacted Multistate Tax Compact, Minn. Stat. 290.171 that was impaired when the Legislature later repealed portions of that statute. Accordingly, the court affirmed the judgment. View "Kimberly-Clark Corp. Commissioner" on Justia Law

Posted in: Tax Law
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Respondent filed suit against appellant for personal injuries he suffered as a result of an automobile accident. Respondent attempted to serve the summons and complaint on appellant via certified mail. The district court concluded that appellant was not properly served before the statute of limitations expired and therefore dismissed the complaint. The court of appeals reversed and remanded. The court held that service of process via certified mail does not constitute personal service under Minn. R. Civ. P. 4.03. Accordingly, the court reversed the court of appeals' decision and reinstated the district court's judgment of dismissal with prejudice. View "Melillo v Heitland" on Justia Law

Posted in: Civil Procedure
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After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder, first-degree arson of a dwelling and theft of a motor vehicle. The Supreme Court affirmed on appeal. Thereafter, Defendant filed a petition for postconviction relief, alleging claims of trial error, ineffective assistance of trial counsel, and ineffective assistance of appellate counsel. The postconviction court denied the petition without granting an evidentiary hearing, concluding that Defendant’s claims were either procedurally barred or meritless. The Supreme Court affirmed, holding (1) Defendant’s claims of trial error were procedurally barred; (2) Defendant’s ineffective assistance of trial counsel claims were either procedurally barred or did not otherwise entitle him to an evidentiary hearing; and (3) Defendant did not receive ineffective assistance of appellate counsel. View "Zornes v. State" on Justia Law

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After a jury trial, Defendant was convicted of first-degree murder and other crimes. The Supreme Court affirmed on appeal. Defendant later filed a pro se petition for postconviction relief, alleging several claims of error. The postconviction court summarily denied Defendant’s petition as untimely, concluding that the petition was filed beyond the two-year limitations period in Minn. Stat. 590.01(4)(a)(2) and that the petition did not meet any exceptions to the time limit. The Supreme Court affirmed, holding (1) Defendant’s claims challenging the jury instructions were procedurally barred, and Defendant failed to satisfy either Knaffla exception; and (2) Defendant’s claim that his sentence of life imprisonment without the possibility of release is unconstitutional under Miller v. Alabama was without merit. View "Munt v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of first-degree felony murder. The district court sentenced Defendant to life in prison. The Supreme Court affirmed the conviction on appeal. Thereafter, Defendant filed a petition for a writ of habeas, asserting many of the same claims he raised on direct appeal. The federal district court dismissed the petition. Defendant appealed. Defendant subsequently filed a petition for postconviction relief, seeking an evidentiary hearing, vacation of his sentence, and/or a new trial based on fifteen claims. The postconviction court summarily denied the petition, ruling that it was procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Defendant’s claims were procedurally barred under State v. Knaffla. View "Davis v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was found guilty of first-degree murder of a peace officer while the officer was engaged in official duties. Defendant was sentenced to life imprisonment without the possibility of release and ordered to pay restitution to the Crime Victims Reparations Board. Appellant later filed a motion to correct his sentence. The postconviction court denied the motion, concluding that it was untimely under Minn. Stat. 611A. 045(3)(b) because Appellant failed to challenge the restitution award within thirty days of receiving written notice of the amount of restitution requested. The Supreme Court affirmed, holding that the district court did not err in denying Appellant’s motion on the grounds of untimeliness. View "Evans v. State" on Justia Law

Posted in: Criminal Law
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Appellant Patrick Figgins brought suit against respondent Grand Rapids State Bank (GRSB) and its CEO, respondent Noah Wilcox, claiming, among other things, that Wilcox and GRSB had made misrepresentations and breached an oral agreement regarding the due date of a payment on an outstanding loan. Respondents moved to dismiss on the ground that Minn. Stat. 513.33 (2014) did not permit these claims. The district court agreed and dismissed the complaint with prejudice. Figgins, on appeal, argued that section 513.33 did not apply to his claims and, to the extent it did, his promissory estoppel claim should have survived because promissory estoppel was an exception to the statute. Finding no reversible error in the district court's judgment, the Minnesota Supreme Court affirmed. View "Figgins vs. Wilcox" on Justia Law

Posted in: Contracts
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Following a bench trial, a district court found appellant Marcus Barshaw guilty of first-degree premeditated murder in connection with the shooting death of Jeffery Schutz and first-degree assault of a peace officer in connection with an assault committed against Deputy Chad Meemken. The court sentenced Barshaw to life in prison without the possibility of release. On appeal, Barshaw argued that the evidence presented at trial was insufficient to support his convictions of premeditated murder and first-degree assault of a peace officer. Because the evidence was sufficient to support both convictions, the Supreme Court affirmed. View "Minnesota v. Barshaw" on Justia Law