Justia Minnesota Supreme Court Opinion Summaries

Plaintiff, a former employee of the Minneapolis Public Schools (MPS), was notified on April 22, 2008 that her position would be eliminated. Plaintiff’s last day of work was June 30, 2008. Plaintiff commenced this lawsuit against MPS on June 29, 2010, asserting retaliation in violation of the Minnesota Whistleblower Act (MWA). The district court dismissed Plaintiff’s MWA claim on statute of limitations grounds. The court of appeals reversed, concluding that Plaintiff’s claim was subject to a six-year limitations period, as provided by Minn. Stat. 541.05(1)(2). On appeal, MPS argued that Plaintiff’s claim was subject to the two-year limitations period found in Minn. Stat. 541.07(1). The Supreme Court affirmed, holding that Plaintiff’s cause of action was governed by the six-year statute of limitations found in section 541.05(1)(2). View "Ford v. Minneapolis Public Schools" on Justia Law

Defendant pleaded guilty pursuant to an Alford plea to fifth-degree criminal sexual conduct. Jane Doe subsequently sued Defendant, alleging that he committed sexual battery and sexual abuse based on the conduct that gave rise to the criminal charges. Prior to trial, Defendant brought a motion in limine to prevent Doe from introducing evidence of the Alford plea. The district court granted the motion, concluding that any mention of the Alford plea would be substantially more prejudicial to Defendant than probative to Doe’s case. After a jury trial, Defendant was found not liable for sexual assault and battery. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by declining to admit Defendant’s Alford plea under Minn. R. Evid. 403; and (2) did not abuse its discretion when it did not allow Defendant’s Alford plea to be admitted for impeachment purposes. View "Jane Doe 136 v. Liebsch" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The Supreme Court affirmed. Appellant later filed his current petition for postconviction relief alleging that a witness had recanted his trial testimony. After an evidentiary hearing to determine the credibility of the alleged recantation, the postconviction court denied the petition, concluding that “it was not well satisfied that the trial witness’s testimony was false.” The Supreme Court affirmed, holding (1) Appellant failed to prove that the State substantially interfered with the decisions of Appellant’s witnesses about whether to testify at the postconviction hearing; and (2) the postconviction court did not abuse its discretion by refusing to grant use immunity to Appellant’s witnesses or by finding that Appellant presented insufficient evidence to warrant a new trial. View "McKenzie v. State" on Justia Law

Respondents, Angela Lennartson and Katie Foss, were involved in separate car accidents and recovered damages in their respective negligence actions. Subsequently, each respondent was awarded no-fault benefits from their insurer, State Farm, in arbitration proceedings under the Minnesota No-Fault Insurance Act (No-Fault Act). State-Farm moved to vacated the arbitration awards, arguing, inter alia, that collateral estoppel barred the no-fault arbitrations. The district court granted State Farm’s motion to vacate in Lennartson’s case and denied it in Foss’s case. The cases were consolidated on appeal. The court of appeals affirmed the decision in favor of Foss and reversed the decision against Lennartson, concluding that neither the No-Fault Act nor collateral estoppel barred the arbitrators’ awards of no-fault benefits to Respondents.The Supreme Court affirmed, holding (1) the No-Fault Act does not bar an insured from recovering no-fault benefits for medical expenses previously recovered in a negligence action; and (2) collateral estoppel does not bar an insured from seeking medical-expense or income-loss benefits in no-fault arbitration recovering damages for the same expenses or losses in a negligence action. View "State Farm Mut. Auto. Ins. Co. v. Lennartson" on Justia Law

In 2008, Appellant was convicted of first-degree premeditated murder. The district court sentenced Appellant to life imprisonment and reserved the issue of restitution for thirty days. The court, however, took no further action on the restitution issue until 2014, when the court granted the restitution request and ordered Appellant to pay $6,500 in restitution. Appellant filed a motion to stop the restitution payments and return the funds taken. The district court denied the motion, concluding that Appellant had properly been served with the restitution request and had failed to timely object to it. The Supreme Court affirmed as modified, holding (1) the district court had the statutory authority to order restitution and did not abuse its discretion in ordering Appellant to pay $6,500 in restitution; and (2) the court properly denied Appellant’s motion to return the funds taken, as the motion was not properly before the district court. View "State v. Anderson" on Justia Law

The State charged Appellant with aiding and abetting first-degree sale of a mixture of a controlled substance of ten grams or more in connection with the sale of methamphetamine. During trial, Appellant objected to the admission of test results by the Minnesota Bureau of Criminal Apprehension (BCA) that confirmed the substance was methamphetamine, arguing that the BCA results were unreliable because the contents of the bags might have been contaminated while the bags were in the custody of the St. Paul Police Crime Lab, which had been investigated for deficiencies in its quality-assurance controls. The district court rejected Appellant’s contamination argument, and Appellant was subsequently convicted of the charged offense. The court of appeals affirmed. Before the Supreme Court, Appellant asked that the Court adopt a new standard that would presume that all evidence processed through the Crime Lab is contaminated and inadmissible unless the State can prove the absence of contamination. The Supreme Court affirmed, holding that the invocation of the Court’s supervisory powers to adopt Respondent’s requested presumption of contamination is not required to ensure the fair administration of justice, and constitutional principles do not require the rebuttable presumption Appellant proposed. View "State v. Hill" on Justia Law

As a condition of his probation from a prior conviction, Respondent was required to attend anger-management therapy sessions with N.M., a mental-health practitioner. During one session, Respondent made a threatening statement about a caseworker assigned to a child-protection case involving Respondent’s children. N.M. determined that Respondent’s statements triggered her statutory duty to warn and reported the statements to the police. The State charged Respondent with one count of making terroristic threats. The jury found Respondent guilty. Respondent appealed, asserting that N.M.’s testimony was inadmissible under the therapist-client privilege. The court of appeals reversed, concluding (1) the therapist-client privilege is not subject to a “threats exception”; and (2) Respondent’s privileged statements were inadmissible through the testimony of any witness, including D.P. The Supreme Court affirmed as modified, holding (1) the statute does not contain a threats exception; (2) the privilege does not apply to the testimony of third parties who learn of confidential information shared by a client with his or her therapist; and (3) Respondent was entitled to a new trial due to N.M.’s disclosure of privileged information at trial. View "State v. Expose" on Justia Law

Appellant used Respondent as the general contractor for the construction of a building. When the building began having problems with water intrusion, Appellant brought suit claiming that Respondent acted negligently in its duties as general contractor. The district court granted summary judgment in favor of Respondent, concluding that the action was untimely under the two-year statute of limitations for improvements to real property in Minn. Stat. 541.051(1)(a). The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals correctly found that the plain language of section 541.051(1) does not require that construction be substantially complete to start the running of the statute of limitations; but (2) there remained a genuine issue of material fact as to when Appellant discovered its injury, and therefore, the district court erred in granting summary judgment. Remanded. View "328 Barry Avenue v. Nolan Props. Group, LLC" on Justia Law

An insurance company (Insurer) issued a policy of insurance on a building. A bank (Bank) was named in the policy as mortgagee. The policy contained a standard mortgage clause and a vacancy clause. The building was later vandalized, and Bank made a claim on the property. Insurer denied the claim under the vacancy clause. Bank sued for breach of the insurance contract. The district court summary judgment in favor of Insurer, concluding that Insurer was not liable to Bank because there was never any coverage offered for a vacant building. The court of appeals reversed, concluded that, under the standard mortgage clause, Bank was entitled to recover. The Supreme Court reversed, holding that, when a property insurance policy contains both a vacancy clause and a standard mortgage clause, a mortgagee has coverage for vandalism damage to a vacant building only if the building was vacant because of the acts of the owner or if the owner failed to comply with the terms of the policy and the mortgagee was unaware of the acts or failure. Remanded. View "Commerce Bank v. West Bend Mut. Ins. Co." on Justia Law

Appellant represented a client pursuant to a contingent-fee agreement but voluntarily withdrew from the representation of the client when efforts to settle the case failed. The client subsequently retained substitute counsel, and substitute counsel successfully negotiated a settlement. Appellant filed suit seeking to recover in quantum meruit the value of the services provided prior to withdrawal. The district court entered judgment against Appellant, concluding that Appellant was not entitled to recover in quantum meruit because he failed to establish good cause for withdrawal. The Supreme Court affirmed, holding (1) an attorney may withdraw from a contingent-fee agreement with or without cause, provided that the withdrawal satisfies the rule of professional responsibility; (2) the attorney may recover in quantum meruit the reasonable value of the services rendered prior to withdrawal if the attorney establishes that the withdrawal is for good cause; and (3) Appellant in this case failed to establish good cause. View "In re Petition for Distribution of Attorney’s Fees between Stowman Law Firm, P.A., and Lori Peterson Law Firm" on Justia Law