Justia Minnesota Supreme Court Opinion Summaries

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

Appellant brought an action against Respondent, a railroad company, in state court seeking damages under the Federal Employers’ Liability Act (FELA) and the Locomotive Inspection Act (LIA). The jury returned a verdict in favor of Appellant, finding that Respondent had violated LIA. Thereafter, Appellant filed a motion to amend the judgment, requesting interest from the date of the verdict to the date of judgment. The district court denied the motion on the ground that prejudgment interest is not available in a FELA action. The Supreme Court affirmed, holding that post-verdict, prejudgment interest is not available in a FELA action as a matter of federal substantive law. View "Kinworthy v. Soo Line R.R. Co." on Justia Law

Sysdyne Corporation and Xigent Solutions, LLC provide staff augmentation services to companies in the engineering and information industries. When Brian Rousslang, a former employee of Sysdyne Corporation who was subject to a noncompete agreement, obtained employment with Xigent Solutions, LLC, Sysdyne sued Xigent for tortious interference with contract and sued Rousslang for breach of contract. The trial court (1) awarded damages to Sysdyne on its breach of contract claim with respect to certain preexisting customers Rousslang brought with him from Sysdyne to Xigent; but (2) ruled in favor of Xigent on the tortious interference claim, concluding that Xigent was justified in interfering with the contract because Xigent conducted a reasonable inquiry into the enforceability of the noncompete agreement and, based on advice of outside counsel, honestly believed that the agreement was unenforceable. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the justification defense to a claim of tortious interference with a contract may be satisfied by a defendant’s reliance on incorrect advice of outside counsel; and (2) under the facts of this case, the trial court did not err in concluding that Xigent met its burden of proving the justification defense. View "Sysdyne Corp. v. Rousslang" on Justia Law

Defendant was convicted of a violation of Minn. Stat. 97B.301, which states that a person may not “take” deer without a license, after he was discovered sitting in a camouflaged blind in an open field, wearing blaze orange, and possessing a loaded gun. At issue on appeal was whether Defendant’s actions constituted a “take” under the applicable definition. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the statutory definition of “taking” applies to “take”; and (2) under that definition, a jury could reasonably conclude that Defendant took deer by “pursuing” or “attempting to take” deer in violation of section 97B.301. View "State v. Schmid" on Justia Law

When Amos Graves was anticipating losing his home to foreclosure, Michael Wayman persuaded him to enter into a transaction that would purportedly save his home. Graves executed a quitclaim deed in favor of a corporate entity under Wayman’s control, but, the next day, sent a cancellation notice to Wayman, as was his statutory right. Wayman refused to cancel the transaction. When Wayman ceased making mortgage payments, First Minnesota Bank, the eventual mortgagee of the property, foreclosed on and purchased the home. Graves sued Wayman, Wayman’s companies, and First Minnesota, alleging that First Minnesota’s mortgage was invalid because Graves did not lawfully sell his home to Wayman. The district court awarded the property to First Minnesota, concluding that the bank was a bona fide purchaser. The court of appeals reversed and awarded the property to Graves, concluding that First Minnesota did not qualify as a bona fide purchaser. The Supreme Court affirmed in part and reversed in part, holding (1) First Minnesota was not entitled to rights in the property as a bona fide purchaser; but (2) the court of appeals erred in concluding that Graves should be awarded title to the property free of any interest of First Minnesota. Remanded. View "Graves v. Wayman" on Justia Law

William Krebes died in 2009, survived by his wife, Helen Durand. The next year, two of Durand’s children petitioned the district court for the appointment of a conservator for Durand because she lacked clarity of mind to make informed decisions regarding her late husband’s estate. The district court agreed and appointed a conservator. The conservator then filed an elective share petition on Durand’s behalf in the probate court. The personal representative of Krebes’s estate opposed the petition, arguing that the elective share statute, Minn. Stat. 524.2-212, required the conservator, before filing for Durand’s elective share in the probate proceeding, to obtain a court order authorizing the filing, and the conservator in this case did not do so. The district court granted summary judgment for the conservator, concluding that section 524.2-212 violated Durand’s equal protection rights because protected surviving spouses are treated differently than non-protected surviving spouses. The court of appeals reversed on the grounds that protected and non-protected surviving spouses are not similarly situated. The Supreme Court affirmed, holding that the distinction between protected and non-protected spouses in the section 524.2-212 does not violate equal protection under the Minnesota Constitution. View "In re Guardianship & Conservatorship of Durand" on Justia Law

This case stemmed from the largely fraudulent lending operations of First United Funding, LLC (First United). After First United collapsed, a court-appointed Receiver commenced this action under Minnesota’s Uniform Fraudulent Transfer Act (MUFTA) against several financial institutions, including Alliance Bank and certain Respondent Banks, that had participated in First United’s loan-participation scheme. The district court (1) dismissed the claims against the Respondent Banks for failure to bring the action in a timely fashion, and (2) allowed the claim against Alliance Bank, concluding that that the Receiver had pleaded legally sufficient claims based on a “Ponzi-scheme presumption.” The district court then entered judgment against Alliance Bank. The Receiver and Alliance Bank appealed. The court of appeals (1) divided the Ponzi-scheme presumption into three separate components and concluded that the third component was unfounded in the case of Alliance Bank; and (2) concluded that the district court erred when it dismissed the Receiver’s actual-fraud claims against the Respondent Banks. The Supreme Court affirmed as modified, holding (1) all three components of the Ponzi-scheme presumption lack support in MUFTA; and (2) the Receiver failed to adequately plead constructive fraud, but the district court erred when it dismissed the Receiver’s actual fraud claims. Remanded. View "Finn v. Alliance Bank" on Justia Law