Justia Minnesota Supreme Court Opinion Summaries

Appellant, a Delaware limited liability company, made short-term, high-interest payday loans to Minnesota residents over the Internet. Integrity conceded that its payday loans did not comply with several provisions of Minnesota’s payday-lending law. In 2011, the Minnesota Attorney General sued Integrity, alleging that it had violated Minnesota’s payday-lending law. Integrity counterclaimed by requesting a declaratory judgment that Minnesota’s payday-lending law was unconstitutional under the extraterritoriality principle of the Commerce Clause, which prohibits a state from regulating commerce that occurs wholly outside the state. The district court granted summary judgment to the State. The court of appeals affirmed. The Supreme Court affirmed, holding that Minnesota’s payday-lending law does not violate the Commerce Clause. View "State v. Integrity Advance, LLC" on Justia Law

After a jury trial, Defendant was found guilty of first-degree assault. The jury found that certain facts existed to support a sentencing departure under the repeat offender aggravating factor. After a sentencing hearing, the district court departed upward from the presumptive sentence range of 135-189 months and sentenced Defendant to the statutory maximum sentence of 240 months. The court of appeals affirmed the sentence, concluding that the repeat offender aggravating factor provided a valid ground for departure and that the district court did not abuse its discretion by imposing a 240-month sentence. The Supreme Court affirmed, holding (1) the district court properly applied the repeat offender aggravating factor to Defendant’s first-degree assault conviction; and (2) the district court did not abuse its discretion in imposing a 240-month sentence. View "State v. Meyers" on Justia Law

In 1997, Appellant was convicted of first-degree premeditated murder and attempted first-degree murder. In 2003, Appellant filed his first postconviction petition. The postconviction court denied the petition after holding an evidentiary hearing. In 2013, Appellant filed his second postconviction petition, claiming that he received ineffective assistance of trial and appellate counsel. The postconviction court denied the petition without holding an evidentiary hearing, concluding that the petition was both untimely under the two-year statute of limitations for filing a postconviction petition and procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Appellant’s claims were procedurally barred. View "Williams v. State" on Justia Law

After Employee ended his employment with Employer he applied for and received state unemployment benefits from the Department of Employment and Economic Development (DEED) and supplemental unemployment benefits (SUB) through a plan offered by Employer. DEED determined that the SUB plan payments counted as “wages” under Minn. Stat. 268.035(29)(A) and determined that Employee had been overpaid state unemployment benefits. An unemployment law judge affirmed. The court of appeals reversed, concluding that Employee was entitled to keep the state unemployment benefits. The Supreme Court affirmed, holding the SUB plan payments Employee received were not “wages” for purposes of his eligibility for state unemployment benefits, and therefore, Employee was not overpaid state unemployment benefits. View "Engfer v. Gen. Dynamics Advanced Info. Sys., Inc." on Justia Law

After being placed on probation, Appellant was cited for consumption of alcohol by a minor and disorderly conduct. The State subsequently moved to have Appellant’s probation revoked, and the State cited Appellant for misdemeanor contempt of court. Appellant moved to dismiss the criminal contempt charge. The district court granted the motion, concluding that the statute charged does not cover violations of probationary terms. Meanwhile, Appellant’s probation was revoked, and the sentence was executed. The Supreme Court affirmed the dismissal of the contempt charge after determining and clarifying the relationship between both the contempt and probation statutes, holding that a willful violation of of a “term” of probation prescribed at sentencing does not itself constitute the crime of violation of a “mandate of a court” under the criminal contempt statute. View "State v. Jones" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree murder and two counts of attempted first-degree murder. The Supreme Court affirmed the convictions, holding (1) the district court’s exclusion from the courtroom members of the public that did not have photographic identification did not constitute a partial courtroom closure; (2) even if the district court’s exclusion of certain evidence supporting an alternative motive of accomplice witnesses was erroneous, the error was harmless; (3) even if the district court erred in admitting testimony from a gang expert identifying Defendant as a gang member, the error was harmless; (4) the district court did not plainly err in instructing the jury on aiding and abetting liability; (5) the district court did not plainly err by not giving a limiting instruction sua sponte regarding Appellant’s prior convictions; (6) the district court did not violate Defendant’s right to a speedy trial; (7) the district court did not err in admitting into evidence a handwritten note seized from Defendant’s jail cell; (8) Defendant waived review of whether the admission into evidence of prison phone call recordings was erroneous; and (9) the cumulative effect of the two assumed errors did not deprive Defendant of a fair trial. View "State v. Taylor" on Justia Law

After a jury trial, Appellant was convicted of felony fourth-degree assault of a peace officer in violation of Minn. Stat. 609.2231(1). Appellant appealed, arguing that the district court abused its discretion by declining to instruct the jury that the act of intentionally throwing or otherwise transferring bodily fluids at or onto an officer, in itself, is a physical assault only when the defendant inflicted or attempted to inflict bodily harm on the officer. The court of appeals affirmed, concluding that the transfer of bodily fluids onto an officer in itself constitutes fourth-degree felony assault. The Supreme Court reversed, holding (1) the unambiguous language of section 609.2231(1) requires that the State prove the elements of a physical assault in addition to proving that a defendant intentionally threw or transferred bodily fluids at or onto the officer; and (2) the district court in this case erred by omitting the element of “physical assault” in its instructions to the jury. View "State v. Struzyk" on Justia Law

Defendant was the driver of a vehicle that was involved in a single-vehicle rollover crash. The accident resulted in one fatality. At the time of the accident, an officer obtained a blood draw from Defendant, and later testing of that blood revealed an alcohol concentration of 0.20. The State charged Defendant with three counts of criminal vehicular operation resulting in death, two counts of fourth-degree driving while impaired, reckless driving, and careless driving. Defendant filed a motion to suppress the alcohol concentration test results on the grounds that his blood was drawn without a warrant and without his consent. The district court suppressed the alcohol concentration test results, concluding that the State failed to satisfy the exigent circumstances exception as applied in Missouri v. McNeely. The court of appeals reversed, concluding that the State established that exigent circumstances justified the warrantless blood draw. The Supreme Court affirmed, holding that the State proved the existence of exigent circumstances justifying the warrantless blood draw. View "State v. Stavish" on Justia Law

The City of Rochester contracted with Rochester City Lines, Co. (RCL) for more than thirty years to operate the municipal bus service in Rochester. In 2011, the Federal Transit Administration informed the City that, in order to continue to receive federal funding, the City needed to initiate a competitive bidding process for its next contract. During the City's ensuing bidding process, RCL filed a lawsuit against the City, claiming that the City’s actions were an unconstitutional taking of RCL’s property. The City subsequently awarded the contract to First Transit, Inc. RCL subsequently amended its complaint to add claims against members of the City Council and First Transit. The district court granted summary judgment to Defendants on each of RCL’s claims. The court of appeals affirmed. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) RCL presented sufficient evidence to create a genuine issue of material fact on the question of whether the City awarded the contract to First Transit based on an unfair and biased process; and (2) the district court properly granted summary judgment on the remainder of RCL’s claims. View "Rochester City Lines, Co. v. City of Rochester" on Justia Law

Appellant was convicted of third-degree driving while impaired. At trial, the court admitted test results showing Appellant’s alcohol concentration at the time of the incident that were based on a warrantless blood draw. After the court of appeals affirmed the conviction, the Supreme Court decided Missouri v. McNeely, which held that the dissipation of alcohol in the blood does not create a single-factor exigency justifying a warrantless blood draw of suspected drunk drivers. Defendant petitioned for review to determine whether, in light of McNeely, her blood draw was an unconstitutional search. The Supreme Court vacated the court of appeals’ decision and remanded for further proceedings in light of McNeely. On remand, the court of appeals again affirmed. The Supreme Court affirmed, holding (1) McNeely applies to cases on direct review at the time of decision; but (2) the test results from Appellant’s blood draw, even if obtained in violation of Appellant’s constitutional rights, need not be suppressed because the officer who facilitated the blood draw acted in objectively reasonable reliance on binding appellate precedent. View "State v. Lindquist" on Justia Law