Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree premeditated murder on an accomplice-liability theory. The district court sentenced Defendant to life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence seized as a result of her arrest, as the arrest was supported by probable cause; (2) the district court did not err in overruling Defendant’s challenges to the State’s peremptory strikes of certain jurors under Batson v. Kentucky; (3) the district court did not abuse its discretion when instructing the jury on accomplice liability; and (4) Defendant’s pro se contentions lacked merit. View "State v. Onyelobi" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction, holding (1) the district court did not err when it denied Defendant’s motion to suppress statements from a police interview conducted shortly after the murder; (2) the warrantless seizure of Defendant’s cellphone did not violate her constitutional rights; (3) Defendant was not entitled to relief on her claim that defective search warrants violated her constitutional rights; (4) the district court did not err when it failed to give an accomplice-corroboration jury instruction; (5) the district court did not err in denying Defendant’s request to remove a juror for cause; and (6) the evidence was sufficient to support Defendant’s conviction of first-degree premeditated murder. View "State v. Horst" on Justia Law

Defendant entered a straight plea to the charge of conspiracy to commit a first-degree controlled substance crime. At the plea hearing, Defendant waived his right under Blakely v. Washington to have a jury determine whether aggravating factors existed to justify an upward durational department to his sentence. During Defendant’s Blakely court trial to determine whether the alleged aggravating factors existed, the district court did not apply the Minnesota Rules of Evidence. After the trial, the district court concluded that the State proved all three of the aggravating sentencing factors. The court imposed a 240-month sentence, a greater than double upward durational departure from the presumptive sentencing range. The court of appeals affirmed, concluding that the rules of evidence do not apply during a Blakely court trial. The Supreme Court affirmed as modified, holding that the rules of evidence apply in a Blakely court trial, but there was no objection and the error was not plain. View "State v. Sanchez-Sanchez" on Justia Law

Respondent was pulled over by a police office on suspicion of driving while impaired for taking a wide right turn and weaving once within his lane around 2 a.m. Respondent was arrested and subsequently charged with second degree driving while impaired. Respondent moved to dismiss the charges, arguing that the arresting officer lacked a valid basis for the traffic stop. The trial court denied the motion to dismiss. Respondent was subsequently found guilty of one count of second-degree driving while impaired-alcohol concentration of 0.08 or more within two hours. The court of appeals reversed, concluding that the stop was improper. The Supreme Court reversed, holding that, under the totality of the circumstances, the arresting officer had a reasonable, articulable suspicion to justify the vehicle stop. View "State v. Morse" on Justia Law

The State filed a juvenile delinquency petition against seventeen-year-old C.J.H. Defense counsel at the first appearance told the juvenile court that the parties had agreed to a “continuance for dismissal.” Without finding that the allegations in the charging document had been proved, the juvenile court continued the delinquency proceeding and, approximately nine months later, terminated the continuance. The juvenile court subsequently adjudicated C.J.H. delinquent. C.J.H. appealed, arguing that the proceedings at the first appearance constituted a “continuance without adjudication” because he unconditionally admitted the charged offense. Therefore, C.J.H. argued, under Minn. R. Juv. Delinq. P. 15.05, the juvenile court’s jurisdiction expired before he was adjudicated delinquent. The court of appeals reversed, concluding that the juvenile court’s jurisdiction expired before C.J.H. was adjudicated delinquent. The Supreme Court reversed, holding (1) the plain language of Rule 15.05 requires a juvenile court to find the allegations in the charging document to have been proven before continuing the case without adjudication; and (2) because no such finding was made in this case, the proceedings at C.J.H.’s first appearance did not constitute a continuance without adjudication. View "In re Welfare of C.J.H." on Justia Law

At issue in this case was whether truck drivers hauling asphalt cement from a commercial oil refinery to a contractor’s facility are performing “work under a contract” under Minn. Stat. 177.44(1) and, therefore, must be paid prevailing wages. The Minnesota Department of Transportation (MDOT) determined that the construction companies that were awarded contracts to work on state highway projects violated the project contracts by failing to ensure that drivers that assisted in the acquisition and transport of asphalt cement for the projects were paid prevailing wages. Appellants argued that the hauling activities of these drivers did not constitute “work under a contract” under Minn. Stat. 177.44(1) and, alternatively, that the hauling activities were exempt from the prevailing wage requirements under the “commercial establishment exception” in the Prevailing Wage Act. The district courts granted summary judgment to MDOT. The court of appeals affirmed. The Supreme Court reversed, holding that hauling activities must be to, from, or on the site of a public works project to qualify as “work under a contract,” and therefore, the hauling activities in this case did not constitute “work under the contract” subject to the prevailing wage requirements. View "J.D. Donovan, Inc. v. Minn. Dep’t of Transp." on Justia Law

When Daniel Berglund refused to file Minnesota income tax returns for tax years 2008, 2009, and 2010, the Minnesota Department of Revenue prepared and filed returns for Berglund and mailed him Notices of Commissioner Filed Returns for the relevant tax years. In total, the Commissioner of Revenue assessed $668,840 in unpaid taxes, penalties, and interest for the three-year period. Berglund appealed, arguing that because the returns did not contain the Commissioner’s signature they were invalid and unenforceable. The tax court granted the Commissioner’s motion for judgment on the pleadings, finding that the lack of a “manual signature” was of no consequence. The Supreme Court affirmed, holding that the relevant statutes do not require that the Commissioner sign commissioner-filed returns in order for those returns to be valid. View "Berglund v. Comm’r of Revenue" on Justia Law

Pursuant to a plea agreement, Appellant pleaded guilty to aiding and abetting first-degree murder and second-degree intentional murder. One year later, Appellant petitioned for postconviction relief under Minn. Stat. 590.01. The postconviction court denied relief. Defendant later filed a motion to correct his sentence pursuant to Minn. R. Crim. P. 27.03(9) challenging the validity of his guilty plea. The postconviction court denied relief on all of Appellant’s claims with the exception of a clerical error, concluding that Appellant’s claims were properly treated as requests for postconviction relief under Minn. Stat. 590.01 and that the holding in State v. Knaffla barred Appellant’s claims. Five years later, Appellant filed a motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The postconviction court denied relief, concluding that Appellant motion was, in effect, a petition for postconviction relief and that it was both untimely and Knaffla-barred. The Supreme Court affirmed, holding that the postconviction court properly dismissed Appellant’s claim as untimely. View "Johnson v. State" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law