Justia Minnesota Supreme Court Opinion Summaries

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

After a jury trial, Petitioner was convicted of aiding and abetting first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed the conviction. Thereafter, Petitioner filed a petition for postconviction relief, alleging that Eric Bermea, who testified as an eyewitness at the trial, had provided false testimony and had subsequently recanted that testimony. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that because the absence of Bermea’s testimony would not have changed the jury’s verdict to an acquittal or to a conviction of a lesser charge, the postconviction court did not abuse its discretion in denying Petitioner’s petition without an evidentiary hearing. View "Ortega v. State" on Justia Law

Appellant pleaded guilty to first-degree criminal sexual conduct in return for the State recommending the presumptive sentence under the Minnesota Sentencing Guidelines - twelve years executed. After a sentencing hearing, the district court sentenced Appellant to twelve years in prison but stayed the sentence and put Appellant on supervised probation for thirty years. The court of appeals reversed and remanded for execution of the presumptive twelve-year prison sentence. The Supreme Court granted Appellant’s petition for review, vacated the judgment of the court of appeals, and remanded, holding that the district court abused its discretion in departing from the Sentencing Guidelines. View "State v. Soto" on Justia Law

An Insurer issued a life insurance policy to an Insured. After the Insured died, the Insurer refused to pay the death benefit to Plaintiff, the Insured’s widow, and rescinded the life insurance policy based on its discovery that the Insured had failed to disclose that he had undergone certain medical procedures. Plaintiff sued the Insurer and the medical records contractor from whom the Insurer requested the Insured’s medical records. The district court granted summary judgment to Defendants, concluding (1) the Insured’s failure to disclose the medical procedures made his statements willfully false or intentionally misleading as a matter of law; and (2) a patient does not have a cause of action under Minn. Stat. 144.298(2) for withholding a medical record that the patient authorized to be released. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) rescission of a life insurance policy requires proof of the insured’s subjective intent to deceive, and there was a genuine issue of material fact regarding the intent of the Insured in this case; and (2) a patient does not have a private right of action under section 144.298(2) when a person releases fewer medical records than authorized by a patient’s consent. View "Larson v. Northwestern Mut. Life Ins. Co." on Justia Law