Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct for sexually penetrating a member of the parish where he served as a priest. The court of appeals reversed and ordered a new trial, holding that the district court erred in (1) failing to provide a specific-unanimity instruction; (2) failing to instruct the jury that State was required to prove that Defendant had subjective knowledge of the purpose of the meeting at which sexual penetration occurred; and (3) denying Defendant’s motion to admit evidence of the complainant’s sexual history after it admitted the State’s evidence of the victim’s sexual inexperience. The Supreme Court reversed, holding (1) the district court’s failure to provide a specific-unanimity jury instruction did not affect Defendant’s substantial rights; (2) the clergy sexual conduct statute does not require the clergy member to know that the complainant seeks or is receiving spiritual counsel; and (3) even assuming the district court abused its discretion in disallowing Defendant’s sexual-history evidence, any error was harmless beyond a reasonable doubt. View "State v. Wenthe" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder committed for the benefit of a gang and first-degree premeditated murder. Appellant was convicted of first-degree premeditated murder, and the district court imposed a sentence of life without the possibility of release. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, alleging, inter alia, newly discovered evidence of the recantations of two witnesses. The Supreme Court remanded the case to the postconviction court for an evidentiary hearing on the witness recantation claim. Thereafter, Appellant filed a second petition for postconviction relief, alleging that his sentence was unconstitutional and that he was entitled to retroactive application of Miller v. Alabama. The postconviction court consolidated both matters, conducted an evidentiary hearing, and (1) denied Appellant’s witness recantation claim from his first postconviction petition, and (2) denied Appellant’s second postconviction petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to a new trial on his witness recantation claim; and (2) Appellant’s second petition for postconviction relief was time-barred. View "Martin v. State" on Justia Law

Respondent suffered a significant injury in a motor vehicle accident and was totally disabled for approximately five months. During her period of disability, Respondent was unable to perform most household duties. Respondent later filed a claim for replacement service loss benefits with her no-fault insurance provider, Western National Mutual Insurance Co. (Appellant), alleging that she was entitled to the reasonable value of the home care and maintenance services she was unable to perform. Appellant refused to pay Respondent’s claim, asserting that it would not reimburse Respondent for household services that were not replaced in some way. An arbitrator awarded Respondent’s entire claim. The district court denied Appellant’s motion to vacate the arbitration award. The court of appeals affirmed, concluding that Minn. Stat. 65B.44(5) does not require replacement of household services when the injured person is primarily responsible for household duties. The Supreme Court affirmed, holding that an injured person who has primary responsibility for care and maintenance of the household need not replace household services as a condition to recovering the reasonable value of such services under section 65B.44(5). View "Schroeder v. Western Nat’l Mut. Ins. Co." on Justia Law

Appellant was denied a promotion after based on the results of a civil service test conducted by the Richfield Police and Fire Civil Service Commission. Appellant filed a petition for writ of certiorari with the Court of Appeals, arguing that the Commission’s promotional process failed to meet the requirements of Minn. Stat. 419.06(9). The Supreme Court reversed, holding (1) the Court of Appeals erred by determining that the term “records” under section 419.06(9) includes a candidate’s interview responses at the time the candidate is applying for a promotion; and (2) the Commission violated section 419.06(9) when it failed to consider records “kept in the regular course of the administration of civil service” as required by statute. View "Peterson v. Richfield Civil Serv. Comm’n" on Justia Law

After a jury trial, Appellant was convicted of unlawful possession of a firearm and first-degree felony murder. The district court sentenced Appellant to life in prison with the possibility of release. The Supreme Court affirmed, holding that the district court (1) erred in instructing the jury on the intent element of burglary, the predicate offense for the felony-murder charge, but the error did not constitute reversible plain error; (2) erred in suggesting the order in which the jury should consider the charges when instructing the jury, but the error was not plain; (3) did not abuse its discretion by excluding alternative-perpetrator evidence of Appellant’s alleged bad acts; and (4) did not violate Minn. R. Crim. P. 26.03(1) by proceeding with the trial in Appellant’s absence. View "State v. Davis" on Justia Law

Appellant was convicted of second-degree unintentional murder. Appellant waived his right to a sentencing jury. The district court imposed a 420-month sentence, an upward durational departure of 168 months, determining that Defendant’s concealment of the victim’s body was an aggravating factor sufficient to justify the upward durational departure. The court of appeals affirmed the sentence. The Supreme Court affirmed, holding that concealment of a murder victim’s body is an aggravating factor on which a district court may base an upward departure, and therefore, the district court did not abuse its discretion when it imposed an upward durational departure on Appellant’s sentence for second-degree unintentional murder. View "State v. Hicks" on Justia Law

In 1988, Appellant pleaded guilty to first-degree murder and attempted first-degree murder. Appellant was sentenced to consecutive terms of life in prison and 130 months. This appeal concerned Appellant’s fifth postconviction petition, in which Appellant claimed that his guilty pleas were not knowing, voluntary, and intelligent. Appellant filed the petition after expiration of the postconviction statute of limitations under Minn. Stat. 590.01(4)(a). The postconviction court summarily denied Appellant’s petition as time-barred. Appellant appealed, arguing that his claim was not time-barred because it satisfied three of the exceptions to the statute of limitations. The Supreme Court affirmed, holding that Appellant’s claim failed to satisfy any of the exceptions to the postconviction statute of limitations under section 590.01(4)(b), and therefore, Appellant's fifth request for postconviction relief was time-barred. View "Brown v. State" on Justia Law

This case arose from a dispute over a construction contract entered into between Contractors Edge, Inc. and the City of Mankato. Contractors Edge sued the City alleging, as relevant to this appeal, breach of contract and violation of the Prompt Payment Act. The district court dismissed the breach of contract claim in an order (the October 2012 order) that concluded, “let judgment be entered accordingly.” Neither party asked for a certification of final judgment under Minn. R. Civ. P. 54.02. The parties subsequently settled the remaining Prompt Payment Act claim. The district court entered final judgment in January 2014. Contractors Edge appealed, challenging the October 2012 order. The court of appeals dismissed the appeal as time barred, holding (1) regardless of whether the district court properly certified the October 2012 order, the partial judgment was immediately appealable, and (2) Contractors Edge’s appeal time had expired. The Supreme Court reversed, holding (1) the district court abused its discretion in certifying the October 2012 order as a final partial judgment under Rule 54.02; and (2) when a district court abuses the discretion given in Rule 54.02 to certify an order as a final partial judgment, the resulting judgment is not final and is not immediately appealable. View "Contractors Edge, Inc. v. City of Mankato" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, one count of attempted first-degree murder, and one count of burglary. Appellant committed the offenses when he was sixteen years old. The district court imposed a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction. Defendant’s convictions were affirmed on direct appeal. Nineteen years later, Appellant moved to correct his sentence based on the rule announced in Miller v. Alabama. Specifically, Appellant argued that the rule announced in Miller should be extended to statutory provisions that mandate the imposition of life imprisonment with the possibility of release and should apply to a district court’s discretionary imposition of consecutive sentences that are the functional equivalent of life imprisonment without the possibility of release. The postconviction court denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court’s decision was consistent with the Court’s recent rulings, and its ruling was a sound exercise of its discretion. View "State v. Williams" on Justia Law

Appellant was convicted of two counts of criminal sexual conduct arising from separate behavioral incidents with separate victims. The district court concluded that Appellant was not subject to lifetime conditional release under Minn. Stat. 609.3455(7)(b) because the two convictions were entered at the same hearing, and therefore, Defendant under not have a “prior sex offense conviction” under section 609.344(1)(g). The Supreme Court reversed, holding that Defendant was subject to lifetime conditional release because the definition of “prior sex offense conviction” unambiguously includes a conviction for a separate behavioral incident entered before a second conviction, whether at different hearings or during the same hearing. Remanded. View "State v. Nodes" on Justia Law