Justia Minnesota Supreme Court Opinion Summaries

After a bench trial, Defendant was convicted of third-degree possession of a controlled substance. Defendant appealed, arguing that the district court erred by denying his motion to suppress the heroin seized from the car he was driving on the grounds that the police unlawfully searched the car without a warrant. The court of appeals reversed, concluding that the police did not have probable cause to arrest Defendant or to search his car. The Supreme Court reversed, holding that the warrantless search of Defendant’s car was lawful under the automobile exception because there was probable cause to believe that Defendant’s car contained contraband, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Lester" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. The district court imposed a life sentence with eligibility for supervised release after thirty years. The Supreme Court affirmed the conviction, holding (1) the jury instruction describing felony malicious punishment of a child as a type of child abuse was plainly erroneous, but Appellant failed to establish that the erroneous jury instruction affected her substantial rights; (2) assuming that the district court abused its discretion when it allowed a state expert to testify that biting a child is a “particularly vicious” form of child abuse, there was no reasonable likelihood that the testimony significantly affected the verdict in this case; and (3) the prosecutor made improper remarks during closing argument, but the prosecutorial misconduct did not affect Appellant’s substantial rights. View "State v. Peltier" on Justia Law

After a jury trial, Defendant was found guilty of three counts of first-degree murder while committing first-degree criminal sexual conduct. Defendant was sentenced to life imprisonment without the possibility of release. Thereafter, Defendant filed a petition for postconviction relief, alleging that the district court committed three errors entitling him to relief. The postconviction court denied relief on all grounds. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Defendant’s request to introduce alternative-perpetrator evidence; (2) the district court did not err when it denied Defendant’s request for a lesser-included-offense instruction on second-degree intentional murder; and (3) the trial judge presiding at Defendant’s jury trial was not disqualified based on an appearance of partiality. View "Troxel v. State" on Justia Law

The apartment building in which Tenants lived was damaged by a fire. For purposes of this appeal, the parties agreed that the fire was caused by Tenants’ negligence. Landlord’s insurer paid for the repairs to the building and then brought this subrogation action against Tenants in the name of Landlord to recover the money it paid to repair the damage caused by the fire. The district court granted summary judgment in favor of Tenants, determining that the parties did not reasonably expect that Tenants would be liable for the damage they caused. The court of appeals reversed, concluding that the lease agreement clearly reflected the parties’ intention that Tenants would reimburse Landlord for any damage caused by their negligence. The Supreme Court affirmed in part and reversed in part, holding (1) under the circumstances of this case, it is reasonable that Tenants should be liable for negligence they caused to the leased premises; but (2) the parties would not reasonably have expected that Tenants would be liable for damage to other property belonging to Landlord. Remanded. View "Melrose Gates, LLC v. Moua" on Justia Law

Nissan North America, Inc., a motor vehicle manufacturer, and Stephen McDaniels, a prospective Nissan dealer (collectively, Defendants), sought to relocate a Nissan dealership to a location 7.6 miles from a dealership operated by Wayzata Nissan, LLC. Wayzata filed an action against Defendants and then moved for a temporary restraining order, challenging the relocation under the Minnesota Motor Vehicle Sale and Distribution Act, Minn. Stat. 80E.01-.17. The district court denied the motion, determining that the exception in section 80E.14(1) for the “relocation of an existing dealer” applied. The court of appeals affirmed. The Supreme Court reversed on the merits, holding (1) even though the relocation at issue has already occurred this appeal is not moot; (2) the notice and good-cause requirements of section 80E.14(1) apply on the date that a manufacturer develops the intention to authorize a relocation, not on the date of the physical relocation of a dealership; and (3) the existing-dealer exception does not apply when the relocation of a dealership is accompanied by a change in the person or entity operating the dealership, and therefore, the existing-dealer exception does not apply in this case. View "Wayzata Nissan, LLC v. Nissan N. Am., Inc." on Justia Law

Employee was injured while participating in an annual employee-recognition event sponsored by Employer. Employee petitioned for workers’ compensation benefits, but Employer denied liability, arguing that Employee’s injury was excluded from coverage under Minn. Stat. 176.021(9), which exempts from workers’ compensation coverage injuries incurred during “voluntary recreational programs.” A compensation judge concluded that the employee-recognition event was not a “voluntary” program because it occurred during Employee’s shift, and he was required to attend in order to obtain his wage without sacrificing his vacation time. The Workers’ Compensation Court affirmed. The Supreme Court affirmed, holding (1) an employer-sponsored recreational program is not “voluntary” when it takes place during work hours and employees must either attend the event or risk forfeiting pay or benefits; and (2) the relevant inquiry when applying section 176.021(9) is whether the program is voluntary, not whether individual recreational activities within the program are voluntary. View "Shire v. Rosemount, Inc." on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to mandatory life imprisonment. The Supreme Court affirmed on appeal and affirmed the denial of Appellant’s first and second postconviction petitions. This appeal arose from the postconviction court’s summary denial of Appellant’s third and fourth petitions for postconviction relief on the grounds that the petitions were untimely. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by determining that Appellant’s third petition was untimely under Minn. Stat. 590.01(4)(c) and that Appellant’s fourth postconviction petition was untimely under Minn. Stat. 590.01(4)(b)(2). View "Rhodes v. State" on Justia Law

During a traffic stop, Defendant failed two sobriety tests. Defendant provided a weak breath sample and refused to provide a second breath sample in violation of Minn. Stat. 169A.20(2). Defendant was subsequently charged with first-degree refusal to submit to testing and first-degree driving under the influence. Defendant pleaded guilty to the refusal-to-test charge. Defendant appealed, arguing that the implied-consent law was unconstitutional and that his conviction was invalid because district court failed fully to comply with the provisions of Minn. R. Crim. P. 26.01(4). The court of appeals affirmed. The Supreme Court affirmed, holding that the district court committed plain error by failing to fully comply with the provisions of Rule 26.01(4), but Defendant failed to show prejudice to his substantial rights and was therefore not entitled to relief based on this error. View "State v. Myhre" on Justia Law

When Respondents filed their Minnesota tax return for tax year 2007, they claimed they were part-year residents of the state. After an audit, the Commissioner of Revenue determined that Respondents were full-year residents of Minnesota for that year and assessed additional income tax, penalties, and interest. On appeal, the tax court granted summary judgment in favor of Respondents, concluding that Respondents were not “residents” under Minn. Stat. 290.01. The Supreme Court reversed, holding (1) the statute is ambiguous; and (2) the tax court’s interpretation of the statute was erroneous. Remanded to the tax court for a recalculation of Respondents’ tax debt in accordance with this opinion. View "Curtis G. v. Comm’r of Revenue" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree premeditated murder for the benefit of a gang and two counts of attempted first-degree premeditated murder for the benefit of a gang. The convictions arose from a drive-by shooting. The Supreme Court affirmed Defendant’s convictions, holding that the district court (1) did not commit prejudicial error when it admitted evidence of a prior drive-by shooting incident that led to Defendant’s prior conviction of attempted murder; (2) did not abuse its discretion when it permitted the State to introduce testimony on gangs from an expert witness; and (3) did not err in its instruction on reasonable doubt because it used language the Supreme Court approved in State v. Smith, rather than the language of the pattern jury instruction. Also, Defendant was not entitled to relief based on any of the claims contained in his pro se brief. View "State v. Thao" on Justia Law