Justia Minnesota Supreme Court Opinion Summaries

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

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

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

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