Justia Minnesota Supreme Court Opinion Summaries

Respondent sustained injuries while employed by Employer. In 2010, Respondent sought workers’ compensation benefits, claiming that as a result of his injury he developed complex regional pain syndrome (CRPS) and that he was entitled to compensation for certain medical expenses, including expenses incurred for the implantation of a spinal cord neurostimulator. The compensation judge concluded that Respondent had failed to show that the effects of his work-related injury included CRPS and therefore necessitated a neurostimulator. The Workers’ Compensation Court of Appeals (WCCA) affirmed. In 2013, Respondent filed a second request for medical benefits seeking compensation for the expenses related to the replacement of his neurostimulator. The compensation judge dismissed the claim, concluding that Respondent’s 2013 claim was barred by res judicata and collateral estoppel. The WCCA reversed. The Supreme Court vacated the decision of the WCCA, holding (1) res judicata did not preclude Respondent’s 2013 claim; but (2) in resolving the 2013 claim, the compensation judge did not determine whether Respondent’s medical condition had changed or new material facts had emerged, a determination that was necessary in order to resolve whether collateral estoppel precluded the 2013 claim. Remanded. View "Mach v. Wells Concrete Prods. Co." on Justia Law

In 1987, after a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Thereafter, Appellant filed four petitions for postconviction relief and a motion for postconviction DNA testing. All of the petitions or motions were denied. In 2014, Appellant filed his seventh request for relief raising several claims. The postconviction court denied Appellant’s petition without an evidentiary hearing, determining that his claims were time-barred under Minn. Stat. 590.01 and procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Appellant’s petition was untimely under Minn. Stat. 590.01(4)(a)(2). View "Wayne v. State" on Justia Law

The district court ordered Father to pay monthly child support. Dakota County was a party to the proceeding because Mother had applied for non-public assistance child support services. Father later retired due to disability and began receiving Social Security benefits. As a result, Mother began receiving derivative Social Security benefits on behalf of the children. Father moved to modify his child support obligation. The child support magistrate granted Father’s motion in part and offset his prospective child support obligation by the derivative Social Security benefits received by Mother. Both parties sought review. The district court concluded Father was entitled to credit for the derivative Social Security benefits received by Mother at the time Mother began receiving derivative Social Security benefits but before Father served notice of the motion to modify. The Supreme Court reversed, holding that a modification of a child support order is retroactive to the date of service of the notice of motion to modify. View "In re Dakota County" on Justia Law

Prior to his death and after consulting a lawyer about divorcing Wife, Husband changed the beneficiary on his term life insurance policy from Wife to Respondents, his parents and sister. Less than four months before Husband’s death, Wife petitioned for dissolution of marriage to Husband. Following Husband’s death, the district court dismissed the dissolution proceeding. Wife subsequently filed suit against Respondents, alleging that Husband’s transfer violated Minn. Stat. 518.58(1)(a), which prohibits the transfer of “marital assets” by a party who contemplates commencing a marriage dissolution. The district court granted summary judgment to Respondents. The court of appeals affirmed, holding that section 518.58(1)(a) did not apply to Wife’s claim because her dissolution proceeding abated upon Husband’s death and the statute applies only in current dissolution proceedings. The Supreme Court affirmed, holding that because the language of section 518.58(1)(a) limits the statute’s application to pending dissolution proceedings, the statute did not provide Wife, who was no longer a party to a marital dissolution proceeding, a remedy in this case. View "Nelson v. Nelson" on Justia Law

Yer Sumner was injured when she fell while working for Jim Lupient Infiniti. Sumner filed a claim petition for workers’ compensation benefits. Lupient denied primary liability. After Sumner filed her claim petition, eleven entities (collectively, Intervenors), including two health-care providers that provided treatment to Sumner (collectively, Relators), moved to intervene as of right. Lupient objected to the compensability of the services for which several Intervenors, including Relators, sought reimbursement. Intervenors had their claims for reimbursement denied when they failed to attend a hearing before a compensation judge. Relators and Sumner appealed. The Workers’ Compensation Court of Appeals affirmed the denial of Relators’ reimbursement claims. The Supreme Court affirmed, holding that, because Relators were absent from the hearing, and none of the exceptions to the attendance requirement was met, the compensation judge did not err when he denied Relators’ claims for reimbursement. View "Sumner v. Jim Lupient Infiniti" on Justia Law

Prior to his scheduled probation revocation hearing, Probationer moved the district court judge for disqualification or, in the alternative, to direct the chief judge of the district to determine whether the district court judge was disqualified due to what Probationer alleged was a “reasonable question” about judicial impartiality. The district court rejected Probationer’s motions in their entirety without issuing a written order and, after a probation revocation hearing, revoked Probationer’s probation and executed his sentence. On appeal, Probationer argued that Minn. R. Crim. P. 26.03(14)(3) requires the chief judge of the district court to hear requests to disqualify. The court of appeals affirmed, concluding that Probationer’s arguments failed both procedurally and on the merits. The Supreme Court reversed the decision of the court of appeals and vacated the probation revocation order, holding (1) Probationer’s appeal was not procedurally flawed; and (2) the district court erred when it declined to refer the request to disqualify to the chief judge of the district, and the error was not harmless. View "State v. Finch" on Justia Law

The State acquired three parcels of land for use during construction of Interstate 394. Because the State no longer needed the parcels, it planned to convey the land to the Golden Valley Housing and Redevelopment Authority (HRA). Webb Golden Valley owned nearby land and argued that the conveyance violated Minn. Stat. 161.44(1). The district court (1) granted Defendants’ motion to dismiss as to two of the parcels for lack of standing, and (2) dismissed the complaint in its entirety when Webb failed to post a surety bond. The court of appeals reversed, holding (1) Webb’s interest in purchasing the two parcels was sufficient to confer standing to challenge the State’s proposed transfer; and (2) the HRA’s allegations of public harm were not supported by evidence in the record, and therefore the district court erred in granting the HRA’s motion for an order directing Webb to post a surety bond. The Supreme Court affirmed in part and reversed in part, holding (1) Webb had standing to bring this suit; but (2) the district court did not abuse its discretion by ordering Webb to post a surety bond, and because Webb did not post the surety bond, the district court did not err in dismissing Webb’s lawsuit with prejudice. View "Webb Golden Valley, LLC v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to terroristic threats. The victim filed a request for restitution, including the cost of hiring an employee to help the victim perform his job while his injuries healed. The district court concluded that the language of Minn. Stat. 611A.045(1) does not prohibit consideration of the victim’s fault and thus awarded the victim only half of the employment-related expenses that he sought because the victim was the initial aggressor. The court of appeals reversed and remanded with instructions to the district court to consider only the factors identified in section 611A.045(1) when determining the amount of restitution. The Supreme Court affirmed, holding that a victim’s role as an initial aggressor may not be considered when determining the amount of restitution to award for economic loss sustained by the victim as a result of the offense. View "State v. Riggs" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court (1) did not err in admitting evidence from Appellant’s cell phone because the police lawfully seized the cell phone under the plain-view exception to the warrant requirement; (2) did not err in admitting evidence obtained from the execution of numerous search warrants because the search warrants were supported by probable cause; and (3) did not abuse its discretion in dismissing a juror for cause. View "State v. Holland" on Justia Law

After a jury trial, Respondent was convicted of unintentional second-degree murder. During trial the State sought to introduce evidence, through the admission of evidence of Respondent’s prior bad acts, that Respondent had a pattern of shifting blame and falsely asserting self-defense after being the aggressor in an altercation. Respondent appealed, claiming that the admission of evidence relating to three previous assaults constituted impermissible character evidence. The court of appeals reversed and remanded for a new trial, concluding that the evidence did not tend to disprove the elements of self-defense and therefore unfairly prejudiced the defense. The Supreme Court reversed, holding (1) evidence of Respondent’s pattern of shifting blame and falsely asserting self-defense was relevant to one or more of the elements of Defendant’s self-defense claim; and (2) the trial court did not commit reversible error when it admitted the previous incidents of assault. View "State v. Welle" on Justia Law