Justia Minnesota Supreme Court Opinion Summaries

Minn. Stat. 169A.20(2) (“the test refusal statute”) makes it a crime for a driver to refuse to request to take a chemical test to detect the presence of alcohol if certain conditions are met. One of those conditions is that the driver has been validly arrested for driving while impaired. Appellant argued that the test refusal statute violated due process because it criminalizes refusal to consent to an unreasonable, warrantless search of a driver’s breath. The district court dismissed the charges, concluding that the police lacked a lawful basis to search Appellant without a warrant, and therefore, the test refusal statute was unconstitutional as applied. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the breath test the police asked Defendant to take would have been constitutional under the search-incident-to-arrest exception to the Fourth Amendment’s warrant requirement, charging Defendant with criminal test refusal did not implicate a fundamental right; and (2) the test refusal statute is a reasonable means to a permissive object and passes rational basis review. View "State v. Bernard" on Justia Law

Plaintiff filed a putative class action against Defendant, a former employee of the Minnesota Department of Human Services (DHS), alleging that Defendant accessed Driver and Vehicle Services records without authorization in violation of the federal Driver’s Privacy Protection Act (DPPA). DHS denied Defendant’s request for defense and indemnification, concluding that Defendant’s actions were outside the scope of his employment. Defendant filed a petition for a writ of certiorari with the court of appeals seeking judicial review of DHS’s decision. The court of appeals remanded the matter to DHS with instructions to grant Defendant’s request, concluding that DHS’s decision was not supported by substantial evidence. The Supreme Court vacated the decision of the court of appeals, holding that the court of appeals did not have jurisdiction over Defendant’s petition for a writ of certiorari and therefore did not have authority to hear this appeal. View "Nelson v. Schlener" on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder and attempted first-degree murder. In a postconviction motion, Appellant argued that he was entitled to a new trial based on newly discovered evidence and the recantation of two witnesses. The postconviction court denied the petition after granting multiple continuances for Appellant to attempt to secure the appearance of favorable witnesses and then holding an evidentiary hearing. The Supreme Court affirmed on the merits but remanded for resentencing, holding (1) the postconviction court did not err when it refused to compel the attendance of certain witnesses at an evidentiary hearing; (2) Appellant forfeited his argument that his trial counsel provided ineffective assistance; and (3) the sentence imposed after a remand from Appellant’s direct appeal was improper. Remanded for resentencing. View "Burrell v. State" on Justia Law

Plaintiff’s employment at the Minnesota Office of the Secretary of State (OSS) ended when her contract was not renewed at the end of her probationary period. Plaintiff sued the State, OSS, and two government officials (collectively, Respondents), alleging common-law tort claims and statutory claims for “false statements as inducement to entering employment” under Minn. Stat. 181.64 and 181.65. Respondents moved to dismiss the claims, arguing that Plaintiff’s statutory claims against the State were barred by sovereign immunity. The district court denied the motion to dismiss in part, concluding that the Legislature waived sovereign immunity for claims brought under sections 181.64 and 181.65. The court of appeals reversed, concluding that the broad language of the statutes was insufficient by itself to subject the State to suit. The Supreme Court affirmed, holding that the State is immune from claims brought under sections 181.64 and 181.65 because the Legislature did not demonstrate a plain, clear and unmistakable intent to waive sovereign immunity for claims brought under these statutes. View "Nichols v. State" on Justia Law

Appellant pleaded guilty and was convicted of first-degree burglary. Two years after Appellant was placed on probation, he appeared before the district court regarding alleged probation violations. Appellant personally admitted the probation violations, and the district court revoked his probation. On appeal, Appellant argued for the first time that the district court erred when it violated his constitutional right to be advised of his due process rights under Morrissey v. Brewer and when it failed to provide him the rights advisory required by Minn. R. Crim. P. 27.04. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a probationer does not have a separate constitutional right “to be advised” that he or she has the procedural due process rights articulated in Morrissey; and (2) the district court’s plain error in failing to provide Appellant the rights advisory requirement by Rule 27.04 did not affect his substantial rights. View "State v. Beaulieu" on Justia Law

After a jury trial, Appellant was convicted of first-degree domestic-abuse murder and two counts of second-degree murder. Appellant was sentenced to life imprisonment with the possibility of release. The Supreme Court affirmed, holding (1) two courtroom closures did not violate Defendant’s Sixth Amendment right to a public trial because Defendant requested the courtroom closures, and the closures did not seriously affect the fairness, integrity, or public reputation of the judicial proceedings; and (2) any error in the admission of relationship evidence under Minn. Stat. 634.20 of Defendant’s past incidents of domestic abuse against his sister and his former girlfriend was harmless. View "State v. Benton" on Justia Law

Upon executing a warrant to search Defendant’s home for stolen property, law enforcement officers found a locked gun safe in the bedroom. Inside the gun safe were a sawed-off shotgun, a full-length shotgun, and a pistol. No evidence identified Defendant as the owner of the sawed-off shotgun or the pistol. After a jury trial, Defendant was convicted of being a felon in possession of a firearm, in possession of a firearm with no serial number, and in possession of a short-barreled shotgun. Defendant appealed, arguing that there was insufficient evidence that he constructively possessed the firearms in the locked safe. The court of appeals affirmed. The Supreme Court affirmed, holding that under the first prong of State v. Florine, the State established Defendant’s constructive possession of the guns by direct evidence, and therefore, the evidence was sufficient to support the convictions. View "State v. Salyers" on Justia Law

In 2012, the governing board of Avera Marshall Regional Medical Center notified the hospital’s medical staff that it had approved the repeal of the medical staff bylaws and replaced them with revised bylaws. Avera Marshall’s Medical Staff, Chief of Staff, and Chief of Staff-elect commenced an action seeking a declaration that the Medical Staff had standing to sue Avera Marshall and that the former medical staff bylaws constituted a contract between Avera Marshall and the Medical Staff. The district court granted judgment for Avera Marshall and dismissed the case, concluding that the Medical Staff lacked the capacity to sue under Minnesota law and that the medical staff bylaws did not constitute an enforceable contract between Avera Marshall and the Medical Staff. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Medical Staff has the capacity to sue and be sued under Minnesota law; and (2) the medical staff bylaws constitute an enforceable contract between Avera Marshall and the individual members of the Medical Staff. Remanded. View "Medical Staff of Avera Marshall Reg’l Med. Ctr. v. Avera Marshall" on Justia Law

During a hail storm, all twenty of the townhome buildings managed by Cedar Bluff Townhome Condominium Association (Cedar Bluff) were damaged, with at least one siding panel on each building sustaining damage. Cedar Bluff submitted a claim to American Family Mutual Insurance Company (American Family) under its businessowners’ policy, which provided for the replacement of “damaged property with other property…[o]f comparable material and quality.” A dispute arose as to whether the policy required the replacement of all siding, including undamaged siding, in order to provide a color match. Because the parties were unable to agree on the amount of the loss, Cedar Bluff demanded an appraisal. The appraisal panel concluded that siding of comparable material and quality required a reasonable color match between the damaged and undamaged siding. American Family refused to pay the appraisal award. The court of appeals agreed with the appraisal panel, concluding that “a reasonable person could understand that ‘comparable material’ means material that is the same color as the damaged property.” The Supreme Court affirmed, holding that, under the terms of its policy with American Family, Cedar Bluff was entitled to have all of the siding panels on each of its twenty buildings replaced. View "Cedar Bluff Townhome Condo. Ass’n, Inc. v. Am. Family Mut. Ins. Co." on Justia Law

Minn. Stat. 176.081(1)(a) requires employers and insurers to pay attorney fees calculated by a statutory formula not subject to judicial review. In this case, Respondent injured his back while working for Employer. Employer and its insurer (together, Relators) settled with Respondent. Respondent’s attorney then sought an award of contingent attorney fees in an amount that was calculated by applying the statutory formula in section 176.081 but which disregarded the upper limit set by the formula. Relators objected, arguing that, in the absence of judicial review to ensure a fee award is not excessive, application of the statutory formula violates separation of powers principles. The compensation judge applied the statutory formula and concluded that $13,000 would adequately compensate Respondent’s attorney but refused to consider whether the statutory fee was reasonable. The Workers’ Compensation Court of Appeals affirmed the compensation judge’s fee award. The Supreme Court affirmed, holding (1) the Court will recognize the Legislature’s statutory formula as presumptively reasonable, and, absent exceptional circumstances, further judicial review of an award based on the statutory formula is unnecessary; and (2) Relators failed to present any exceptional circumstances to challenge this presumption. View "David v. Bartel Enters." on Justia Law