Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree murder while committing domestic abuse, second-degree intentional murder, second-degree felony murder, and third-degree murder. The Supreme Court (1) reversed Defendant’s first-degree murder conviction and remanded for a new trial on that charge, holding that the district court committed multiple plain errors that, taken cumulatively, affected Defendant’s substantial rights and the fairness, integrity, or public reputation of the judicial proceedings; and (2) Defendant was not entitled to a new trial on the charge of second-degree intentional murder because any alleged error based on the exclusion of Defendant’s preliminary breath test results was harmless beyond a reasonable doubt. View "State v. Bustos" on Justia Law

Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. Appellant later filed a pro se petition for postconviction relief, raising a sentencing claim, a restitution claim, and several claims of ineffective assistance of counsel and newly discovered evidence. The postconviction court granted relief on Appellant’s sentencing claim but denied relief on his other claims. Appellant appealed, arguing that the postconviction court erred when it denied his claims without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not err when it summarily denied Appellant’s petition. View "Nissalke v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder for the benefit of a gang, first-degree premeditated murder, and second-degree intentional murder. The trial court sentenced Defendant to life imprisonment without the possibility of release. The Supreme Court affirmed Defendant’s conviction, holding that the trial court did not commit plain error when it admitted as substantive evidence out-of-court statements made to the police by one of the State’s witnesses and when it admitted Spreigl evidence relating to a 2009 shots-fired incident, as the allegedly erroneous admission of the evidence did not affect Defendant’s substantial rights or substantially influence the verdict. View "Ramsey County v. Campbell" on Justia Law

RDNT, LLC, which provided assisted living and skilled nursing services, owned a campus consisting of two buildings. RDNT submitted an application to the City of Bloomington for a conditional use permit, seeking to expand its services by adding a third building to the campus. The City Council denied RDNT’s application, giving four reasons for its decision. The district court reversed the denial of RDNT’s application, holding that the City misapplied certain standards, misrepresented the impact of certain studies, and ignored certain evidence. The court of appeals reversed, concluding that the City appropriately exercised its discretion. The Supreme Court affirmed, holding that the City’s decision was not unreasonable arbitrary or capricious, as the City based its decision on a legally and factually sufficient ground, and the City properly considered RDNT’s proposed traffic-mitigating conditions. View "RDNT, LLC v. City of Bloomington" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life in prison. The Supreme Court affirmed on direct appeal. Defendant subsequently filed four petitions for postconviction relief as well as a motion for postconviction DNA testing. All five postconviction petitions or motions were denied. In his sixth petition, Defendant argued that he received ineffective assistance of counsel because he was not informed of a plea offer purportedly discussed during an in-chambers meeting that occurred during his trial. The postconviction court denied Defendant’s petition without an evidentiary hearing, concluding that his claim was both time barred and procedurally barred. The Supreme Court affirmed, holding that Defendant’s petition was untimely under Minn. Stat. 590.01(4)(a), and neither of the exceptions upon which he relied applied in this case. View "Wayne v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder while committing a drive-by shooting. The district court imposed a life sentence with the possibility of release. After the Supreme Court affirmed on appeal, Defendant filed several petitions for postconviction relief. Defendant's third and fourth petitions asserted claims of newly discovered evidence. The postconviction court denied Defendant’s third and fourth petitions after an evidentiary hearing, determining that because the witnesses who testified on Defendant’s behalf were not credible, the evidence that Defendant presented as newly discovered failed to satisfy the materiality requirement of the newly discovered evidence test set forth in Rainer v. State. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Defendant’s third and fourth petitions for postconviction relief. View "Bobo v. State" on Justia Law

Defendant pled guilty to a fourth-degree controlled substance violation. After finding that Defendant was a career offender under Minn. Stat. 609.1095(4), the district court imposed a sentence of sixty-six months, a double upward departure from the thirty-three-month presumptive sentence under the Minnesota Sentencing Guidelines. The court of appeals reversed and remanded for resentencing, concluding (1) one of Defendant’s felony convictions did not meet the requirements of the career-offender statute because it had been deemed a misdemeanor before Defendant was sentenced, and (2) therefore, Defendant could not be sentenced as a career offender because he did not have five prior felony convictions. The Supreme Court affirmed, holding that, under the plain language of section 609.1095(4), a felony conviction that has been deemed a misdemeanor by operation of Minn. Stat. 609.13 before an offender is sentenced for the current offense may not be considered when determining whether the offender has five or more prior felony convictions. View "State v. Franklin" on Justia Law

Law enforcement officers searched Defendant’s home pursuant to a search warrant and found plastic bags containing methamphetamine. The search warrant was based on information police received from a warrantless search of Defendant’s garbage. Defendant was charged with third-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the warrantless search of his garbage violated Minn. Const. art. I, 10. The district court denied the motion to suppress. The court of appeals affirmed. At issue before the Supreme Court was whether Article I, Section 10 of the Minnesota Constitution requires greater protection than the Fourth Amendment to the United States Constitution in the context of a warrantless search of garbage set out for collection in an area accessible to the public. The Supreme Court affirmed, holding (1) there is not a principled basis for interpreting Article I, Section 10 to require greater protection that the Fourth Amendment; (2) it was lawful for the police to obtain Defendant’s garbage from the garbage collector; and (3) because the warrantless search of Defendant’s garbage was reasonable under the state and federal constitutions, the search warrant for Defendant’s residence based on evidence found in the garbage was valid. View "State v. McMurray" on Justia Law

Employee fractured her ankle on a staircase at her workplace. A workers’ compensation judge awarded benefits to Employee, concluding that the injuries “arose out of” her employment. The Workers’ Compensation Court of Appeals (WCCA) affirmed, relying on its previous decision in Dykhoff v. Xcel Energy. The Supreme Court stayed Employer’s appeal while it considered Dykhoff. The Supreme Court then reversed the WCCA’s decision in Dykhoff and remanded. On remand, the WCCA again affirmed, this time applying the “increased risk” test, which requires an employee to to show that her workplace exposed her to a risk of injury that was increased over what she would face in her everyday life. The WCCA relied on two factual findings to conclude that Employee’s injury was compensable under the increased risk test. The Supreme Court reversed, holding that the WCCA’s decision was manifestly contrary to the evidence. Remanded. View "Arrowhead Senior Living Cmty. v. Kainz" on Justia Law

After Appellants, several public utilities, sought to condemn a permanent easement across the property of Landowners for a high-voltage transmission line, Landowners elected to compel Appellants to purchase their entire parcel of land pursuant to the Buy-the-Farm statute, Minn. Stat. 216E.12(4). Appellants challenged Landowners’ election, arguing that it was not reasonable because the land subject to the election was much larger than the land needed for the easement and that the district court must consider several factors in addition to the statute’s requirements, including the size of the election. The district court approved the election, concluding that it was not required to analyze factors outside the provisions of the Buy-the-Farm statute. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the language of the statute forecloses Appellants’ assertion that the district court must engage in a totality-of-the-circumstances analysis of the reasonableness of Landowners’ election; (2) case law does not require an extra-statutory analysis; and (3) because Landowners’ election meets the statutory requires, the district court did not err in approving the compelled purchase of the parcel. View "Great River Energy v. Swedzinski" on Justia Law