Justia Minnesota Supreme Court Opinion Summaries

Meagher & Geer, PLLP (MG) represented Ryan Contracting Company (Ryan) in an action to foreclose on several mechanic’s liens. Later, represented by O’Neill & Murphy, LLP (O’Neill), Ryan brought suit against MG for legal malpractice arising out of MG’s allegedly defective filing and foreclosure of Ryan’s mechanic’s liens. The district court granted MG’s motion to dismiss on the ground that O’Neill failed to timely file expert witness affidavits. Ryan then brought suit against O’Neill for legal malpractice arising out of O’Neill’s representation of Ryan in the MG lawsuit. The district court granted summary judgment for O’Neill, concluding that the mechanic’s liens were not perfected, not because of MG’s conduct, but because of Ryan’s error in not filing the pre-lien notice to the property owner required by Minn. Stat. 514.011. The court of appeals reversed in part, concluding that Ryan was exempt from the pre-lien notice requirement under section 514.011, and there were genuine issues of fact regarding the other issues. The Supreme Court affirmed as modified, holding that the court of appeals did not err in concluding that Ryan was not required to give pre-lien notice to enforce its mechanic’s liens. View "Ryan Contracting Co. v. O’Neill & Murphy, LLP" on Justia Law

A School District expelled Student for six weeks after finding a pocketknife in a purse in her locker. The Commissioner of the Department of Education affirmed. The court of appeals reversed, concluding (1) Student did not willfully violate the District’s weapons policy when she unintentionally carried the pocketknife to school, and (2) the pocketknife’s presence in Student’s locker did not bring Student or others into danger. The Supreme Court affirmed, holding (1) the record did not support the conclusion that Student deliberately and intentionally violated the District’s weapons policy; and (2) the record did not contain substantial evidence that Student exposed anyone to actual or even probable harm. View "In re Expulsion of A.D. from United S. Central Pub. Schs." on Justia Law

Defendant pleaded guilty to seven counts of possession of pornographic work involving minors for downloading and saving seven pornographic images of minors engaged in sexual conduct on seven different days. Before sentencing, Defendant filed a motion arguing (1) he could only be convicted and sentenced for one count of possession for possessing the computer, and (2) his offenses were part of a single behavioral incident. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not err in sentencing Defendant on each of the separate possession convictions, as Defendant’s sentences were completed at substantially different times, and his conduct was not motivated by an effort to obtain a single criminal objective. View "State v. Bakken" on Justia Law

At issue in this case was Hennepin County’s assessment of the market value of two bulk-distribution warehouses for two assessment dates in 2009 and 2010. The tax court adopted market valuations that were far lower than the recent sale price of each subject property. The County appealed, arguing that the tax court provided inadequate reasons for rejecting the County’s sales comparison analysis and for rejecting a large portion of the County’s income capitalization analysis. The Supreme Court reversed the portion of the tax court’s decision rejecting the County’s sales comparison analysis and vacated the tax court’s order, holding that the tax court (1) did not err in rejecting portions of the County’s income capitalization analysis, but (2) failed adequately to explain its reasons for rejecting the County’s sales comparison analysis. Remanded. View "Archway Marketing Servs. v. County of Hennepin" on Justia Law

Appellant filed an action under 42 U.S.C. 1983 against Scott County and Credit River Township, claiming that the County took his property without just compensation by placing conditions on the approval of his plat application. The County moved for summary judgment, arguing that the district court did not have subject-matter jurisdiction because Appellant’s exclusive avenue for review of the County’s decision was to seek a writ of certiorari from the court of appeals. The district court determined that it had jurisdiction over the action. The court of appeals reversed, concluding that the County’s plat approval subject to conditions was a quasi-judicial action, which was reviewable only by certiorari appeal within sixty days. The Supreme Court reversed, holding that the district court had jurisdiction over Appellant’s section 1983 action. View "Zweber v. Credit River Township" on Justia Law

Appellant entered a Norgaard plea to third-degree criminal sexual conduct. The district court imposed a downward durational departure from the presumptive sentence, concluding in part that Appellant’s remorse provided substantial reasons to depart from the presumptive sentence length. The court of appeals reversed the downward durational departure because Appellant’s remorse did not make his conduct "less serious than the typical offense.” The court further found that even if Appellant’s remorse were a mitigating factor, Appellant was not entitled to a downward departure based on one mitigating factor alone. The Supreme Court affirmed, holding (1) a single mitigating factor may provide a substantial reason to impose a downward durational sentencing departure; but (2) a downward durational departure was not warranted in this case because Appellant’s expressions of remorse did not diminish the seriousness of his offense. View "State v. Solberg" on Justia Law

Homeowners brought an action against a City alleging that the City’s non-employee City Engineer was negligent and caused a nuisance. The City Engineer performed the allegedly negligent acts under a contract with the City. The district court granted summary judgment to the City on the negligence claim based on vicarious official immunity but denied summary judgment on the nuisance claim, concluding that there were genuine issues of material fact for trial. The court of appeals affirmed the district court’s conclusion that the City was entitled to vicarious official immunity for the negligent design claim but reversed the denial of summary judgment on the nuisance claim, concluding that vicarious official immunity applied to the nuisance claim because the alleged nuisance arose from the same immune conduct as the alleged negligence. The Supreme Court affirmed, holding that the City was entitled to vicarious official immunity for both the Homeowners’ claims. View "Kariniemi v. City of Rockford" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder of a peace officer and nine other felonies. The Supreme Court affirmed Appellant’s first-degree murder conviction and all but one of his other felony convictions. Thereafter, Appellant filed a petition for postconviction relief, asserting, inter alia, that he did not actually cause the death of the officer. The postconviction court denied Appellant’s petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied Appellant’s petition without holding an evidentiary hearing. View "Fairbanks v. State" on Justia Law

Respondent suffered a work-related back injury. Respondent and her employer entered into a “full, final, and complete” settlement of Respondent’s claims for workers’ compensation benefits related to that injury. Respondent later filed a claim petition seeking additional benefits for the back injury, alleging a lumbar spine injury with consequential depression and anxiety. The employer moved to dismiss the petition on the ground that Respondent was first required to bring a motion to vacate the existing settlement agreement before bringing a new claim. The workers’ compensation judge denied the motion, concluding that the settlement agreement did not foreclose a later claim for consequential psychological injury. The Workers’ Compensation Court of Appeals affirmed, concluding that the settlement agreement did not foreclose claims from the same incident that were not mentioned in the agreement without evidence that those claims were contemplated by the parties at the time they entered into the agreement. The Supreme Court reversed, holding that the language of the settlement agreement was sufficient settle conditions and complications that arise out of, and are a consequence of, Respondent’s workers’ compensation injury. View "Ryan v. Potlatch Corp." on Justia Law

In 2008, Appellant was convicted of three counts of first-degree murder and four counts of second-degree murder. Appellant was sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. In 2012, Appellant filed a petition for postconviction relief, alleging numerous trial errors as well as ineffective assistance of counsel. The postconviction court summarily denied most of Appellant’s claims on the ground that they were procedurally barred. Following an evidentiary hearing, the court denied Appellant’s remaining ineffective assistance of counsel claims. The Supreme Court affirmed, holding (1) most of Defendant’s claims were procedurally barred, and therefore, the postconviction court did not abuse its discretion by denying them without granting an evidentiary hearing; and (2) the district court did not err when it denied several of Appellant’s ineffective assistance of counsel claims after an evidentiary hearing. View "Swaney v. State" on Justia Law