Justia Minnesota Supreme Court Opinion Summaries

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

After a jury trial, Defendant was found guilty of second-degree intentional murder and second-degree felony murder. Defendant was sentenced to 306 months in prison for second-degree intentional murder. Defendant appealed, arguing that the accomplice-liability instructions given to the jury failed accurately to state the law. The court of appeals affirmed, concluding that the accomplice-liability instructions were plainly erroneous but that the error did not affect Defendant’s substantial rights. The Supreme Court reversed, holding (1) the instructions at issue were plainly erroneous; (2) Defendant met his burden of proving that the plainly erroneous jury instructions affected his substantial rights; and (3) a new trial was necessary in this case to protect the fairness, integrity, and public reputation of the judicial proceedings. View "State v. Huber" on Justia Law

Appellants, LaVonne and Henry Pfeil, were longstanding members of St. Matthew Lutheran Church. St. Matthew’s pastors decided to excommunicate Appellants due to their “slander and gossip” of the church’s leadership and ministry. At special voters’ meeting, the congregation voted to affirm the excommunication decision. LaVonne subsequently brought a lawsuit on behalf of herself and Henry against St. Matthew and its pastors (collectively, Respondents), asserting claims for defamation and negligence. After resolving Henry’s claims on other grounds, the district court dismissed the case with prejudice, concluding that the First Amendment deprived the court of jurisdiction to adjudicate LaVonne’s claims. The court of appeals affirmed. The Supreme Court affirmed, holding that that the First Amendment prohibits holding an organization or individual liable for statements made in the course of a religious disciplinary proceeding when those statements are disseminated only to members of the church congregation or the organization’s membership or hierarchy. View "Pfeil v. St. Matthews Evangelical Lutheran Church" on Justia Law

Kelly Dennis was allegedly injured in the course of his employment with The Salvation Army. Dennis filed a claim for workers’ compensation benefits, but The Salvation Army and its insurer (collectively, Relators) denied liability. The compensation judge awarded Dennis benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed. Within thirty days, Relators filed a petition for a writ of certiorari with the clerk of the appellate courts. Relators, however, failed to serve a cost bond on the WCCA as required by Minn. Stat. 176.471. Relators subsequently served an untimely cost bond on the WCCA. At issue before the Supreme Court was whether timely service of the cost bond was mandatory to have the WCCA order reviewed by the Supreme Court on certiorari. The Supreme Court discharged the writ of certiorari and dismissed the appeal, holding that Relators’ failure to file the cost bond within the thirty-day period to appeal was fatal to their appeal. View "Dennis v. Salvation Army" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree murder and two counts of second-degree murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree murder conviction. The Supreme Court affirmed on appeal. After unsuccessfully seeking postconviction relief, Appellant filed a second petition for postconviction relief, alleging that he was entitled to a new trial on two grounds. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant’s claim that the district court gave an erroneous jury instruction during trial was untimely, and the postconviction court did not abuse its discretion when it denied his petition without a hearing; and (2) Appellant was not entitled to relief in the interests of justice based on any of the issues he raised. View "Bolstad v. State" on Justia Law

Plaintiff brought an action against Defendant for copyright infringement and obtained a money judgment in California. The judgment against Defendant was filed and docketed in a Minnesota district court. Plaintiff subsequently served a garnishment summons on Defendant and sought to attach Defendant’s domain name and the content of its related website. The district court concluded that neither the domain name nor its associated website constituted property subject to garnishment under Minn. Stat. 571.73(3). The court of appeals reversed. The Supreme Court affirmed, holding that an Internet domain name constitutes intangible personal property subject to attachment by garnishment under section 571.73(3)(3). View "Sprinkler Warehouse, Inc. v. Systematic Rain, Inc." on Justia Law

In 2007, Appellant was injured in a motor vehicle collision. After settling her primary uninsured motorist (UM) claim, Appellant sought excess UM benefits from an American Family Mutual Insurance Group policy that covered her vehicle. American Family denied the claim. In 2013, Appellant filed a lawsuit seeking excess UM benefits from American Family. The district court granted summary judgment in favor of American Family, concluding that the excess UM claim was barred by the six-year statute of limitations for contract actions and that Appellant’s claim accrued on the date of the accident. The court of appeals affirmed. The Supreme Court affirmed, holding that claims for excess UM benefits accrue on the date of the accident, and therefore, summary judgment was properly granted in favor of American Family. View "Hegseth v. Am. Family Mut. Ins. Group" on Justia Law

Plaintiffs filed suit against Defendants for medical malpractice. Defendants moved to dismiss the complaint for insufficient process and and insufficient service of process. The district court (1) denied the motions to dismiss for insufficient process, concluding that, although the summons and complaint were defective due to the lack of a Minnesota attorney’s signature, the Minnesota Rules of Civil Procedure granted the court discretion to allow the summons and complaint to be cured by amendment; and (2) denied the motions to dismiss for insufficient service of process as to some defendants, finding those defendants to have been validly served, but granted the motions with respect to the remaining defendants. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the summons and complaint bearing only the signature of an attorney not licensed to practice in Minnesota were defective, but the district court did not abuse its discretion in allowing them to be amended; and (2) Plaintiffs in this case produced sufficient evidence of effective service, and Defendants did not satisfy their burden to prove that service was not effective, and therefore, the district court erred in granting Defendants’ motion to dismiss for insufficient service. View "DeCook v. Olmsted Med. Ctr., Inc." on Justia Law