Justia Minnesota Supreme Court Opinion Summaries

Appellant was convicted of first-degree murder of a peace officer. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a postconviction petition, which the district court denied. The Supreme Court affirmed. Thereafter, Appellant filed a motion for relief from judgment alleging a number of claims, including ineffective assistance of trial and appellate counsel. Treating Appellant’s motion as a second postconviction petition, the district court denied relief, concluding that all of Appellant’s claims were untimely under Minn. Stat. 590.01(4). The Supreme Court affirmed, holding (1) even if the district court had treated Appellant’s request for relief as a motion under Minn. R. Civ. P. 60.02, his request would have been untimely; and (2) Appellant’s claims were also untimely under the postconviction statute. View "Evans v. State" on Justia Law

Based on an indirect audit that the Commissioner of the Minnesota Department of Revenue conducted of the sales and use tax returns for Conga Corporation for the tax periods from January 1, 2007 through March 31, 2010, the Commissioner determined that Conga had unreported revenues for the relevant tax periods and issued an order assessing additional sales, use, and entertainment taxes, plus penalties and interest. The tax court affirmed the Commissioner’s order with respect to the assessment of 2007 taxes but reversed with the penalty assessment for tax years 2008-2010, concluding that the Commissioner’s decision to use an indirect audit was not supported by the record. The Supreme Court reversed, holding that the Commissioner’s decision to use an indirect audit to assess taxes was supported by the record. Remanded. View "Conga Corp. v. Comm’r of Revenue" on Justia Law

On July 13, 2007, Appellant was charged with fifth-degree controlled substance crime. Appellant pleaded guilty. On February 27, 2009, the court stayed adjudication of Appellant’s case under Minn. Stat. 152.18(1), placing him on probation. On May 24, 2011, Appellant admitted to violating the terms of his probation. The district court revoked the stay of adjudication and entered a judgment of conviction. On May 23, 2013, Appellant filed a petition for postconviction relief requesting that he be permitted to withdraw his guilty plea. The postconviction court summarily denied the petition on the ground that it was untimely under Minn. Stat. 590.01(4)(a)(1) because it was filed more than two years after the order staying adjudication. The court of appeals affirmed, holding that a stay of adjudication is a “sentence” under Minn. Stat. 590.01(4)(a)(1) that triggers the two-year statute of limitations for filing a postconviction petition. The Supreme Court reversed, holding that a stay of adjudication under Minn. Stat. 152.18(1) is not a judgment of conviction or sentence under Minn. Stat. 590.01(4)(a)(1), and therefore, the district court erred by concluding that Appellant’s petition was time-barred. View "Dupey v. State" on Justia Law

Respondent, the chief investigator for the Medicaid Fraud Control Unit (MFCU) of the Minnesota Attorney General’s Office, was investigating Affiliated Counseling Center, LLC (Affiliated) when she applied for and received a search warrant for Affiliated’s premises. The police executed the warrant and seized numerous documents from Affiliated’s office, including patient files. Thereafter, Appellant, the sole owner of Affiliated, sued Respondent, alleging that Respondent committed conversion and trespass to chattels by losing and/or destroying some of Affiliated’s patient files. Respondent moved to dismiss, asserting that she was entitled to prosecutorial immunity. The district court denied the motion. The court of appeals reversed, concluding that Respondent was entitled to prosecutorial immunity because her challenged conduct was taken pursuant to her statutory authority to investigate Medicaid fraud. The Supreme Court reversed, holding (1) prosecutorial immunity does not extend to an investigator when the investigator’s conduct is not intimately involved with the initiation and maintenance of criminal charges; and (2) therefore, the court of appeals erred when it concluded that Respondent was entitled to prosecutorial immunity. View "Stresemann v. Jesson" on Justia Law

Appellant was one of nineteen individuals injured when a school bus was struck by an at-fault vehicle. Appellant sought excess underinsured motorist (UIM) coverage benefits from his family’s automobile policy with American Family Mutual Insurance Company because his damages exceeded the recovery available to him under the coverage of the school bus. American Family denied Appellant’s claim for excess UIM benefits, claiming that, pursuant to the Minnesota No-Fault Automobile Insurance Act, Appellant’s excess UIM coverage ($100,000) did not “exceed” the UIM coverage provided by the school bus’s insurance ($1,000,000). Appellant then brought this action, seeking the difference between the recovery he received and his UIM policy limits from American Family. The district court granted summary judgment in favor of American Family, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the phrase “coverage available,” as used in Minn. Stat. 65B.49(3)(a)(5), in reference to the “excess insurance protection” for an injured insured, is ambiguous; and (2) the phrase “coverage available” means the benefits actually paid to the insured under the coverage provided by the occupied vehicle’s policy. View "Sleiter v. Am. Family Mut. Ins. Co." on Justia Law

Appellant was found guilty of second-degree murder for the benefit of a gang, attempted second-degree murder, second-degree assault for the benefit of a gang, and second-degree assault. The court of appeals reversed Appellant’s convictions of attempted second-degree murder for the benefit of a gang and second-degree assault for the benefit of a gang. On remand, the district court imposed a 165-month prison sentence for Appellant’s conviction of the lesser-included offense of attempted second-degree murder. On appeal, Appellant argued that because the district court originally imposed a 165-month sentence for his conviction of attempted second-degree murder for the benefit of a gang, the court abused its discretion by imposing the same sentence for his conviction of attempted second-degree murder. The court of appeals affirmed, concluding that the sentence imposed on remand did not violate the public policy and fairness concerns articulated in State v. Prudhomme. The Supreme Court affirmed, holding that Appellant’s sentence was not in error because the record did not support Appellant’s assertion that the district court imposed a greater sentence on remand following his successful appeal of his conviction of attempted second-degree murder for the benefit of a gang. View "State v. Kangbateh" on Justia Law

In 2005, the City of Winona enacted the thirty-percent rule, which limits the number of lots on a block in certain areas of the City that are eligible for certification as rental properties. Appellants brought this action challenging the rental ordinance, claiming that the thirty-percent rule is a zoning law that exceeds the City’s power authorized by Minn. Stat. 462.357 and violates their equal protection and substantive due process rights. The district court granted summary judgment in favor of the City, concluding that the ordinance is not unconstitutional and that the City had authority to enact it. The court of appeals affirmed. Appellants filed a petition for review. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that Appellants' claims had become moot because, under the facts and circumstances of this case, the alleged harm to Appellants’ interests had ceased. View "Dean v. City of Winona" on Justia Law

In 1994, Appellant was convicted of first-degree murder. In 1995, Appellant pleaded guilty to second-degree attempted murder. In 2014, Appellant brought a fifth postconviction petition alleging ineffective assistance of appellate counsel. The postconviction court denied the petition without an evidentiary hearing, concluding that it was both time-barred and procedurally barred. Also in 2014, Appellant brought a second motion to correct his sentence. The postconviction court concluded that the Supreme Court had already decided the issue and denied the motion. The Supreme Court affirmed in both matters, holding (1) Appellant’s postconviction petition was time-barred under Minn. Stat. 590.01(4)(a); and (2) Appellant’s motion to correct his sentence raised the same issue that this Court decided in Appellant's previous petition had no merit, and therefore, the second motion was properly denied. View "Townsend v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life in prison. The Supreme Court affirmed. Appellant then filed a pro se petition for postconviction relief alleging, inter alia, ineffective assistance of appellate counsel and newly discovered evidence. The postconviction court summarily denied relief on all claims with the exception of the newly discovered evidence claim. After an evidentiary hearing, the postconviction court denied the newly discovered evidence claim. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it (1) summarily denied Appellant’s ineffective assistance of counsel claim because the facts alleged in the petition failed to satisfy the Strickland test; (2) denied Appellant’s newly discovered evidence claim after an evidentiary hearing because the record supported the court’s finding that the testimony of the newly discovered witnesses was doubtful; and (3) summarily denied Appellant’s remaining claims because those claims were procedurally barred. View "Carridine v. State" on Justia Law

Reichmann Land and Cattle, LLP managed a winter feeding facility. In 2011, the Minnesota Pollution Control Agency (MPCA) issued an administrative order requiring Reichmann to obtain national-pollutant-discharge-elimination-system (NPDES) and state-disposal-system (SDS) permits or discontinue the winter feeding operation. Reichmann requested a contested case hearing. An administrative law judge (ALJ) concluded that Reichmann’s winter feeding fields constituted a “concentrated animal feeding operation” and were not “pastures.” Therefore, Reichmann was required to apply for an NPDES/SDS permit. The Commissioner of the MPCA adopted the findings and conclusions of the ALJ. The court of appeals affirmed the Commissioner’s conclusion that Reichmann must apply for an SDS permit but reversed the Commission’s requirement that Reichmann must apply for an NPDES permit. The Supreme Court affirmed, holding (1) Reichmann need not obtain an NPDES permit because its winter feeding facility is not an animal feeding operation as required by 40 C.F.R. 122.23(b)(1); and (2) Reichmann is required to obtain an SDS permit because it does not qualify for the pasture exemption. View "In re Reichmann Land & Cattle, LLP" on Justia Law