Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted as an accomplice to first-degree aggravated robbery and third-degree assault. Appellant appealed, contending that he was entitled to a new trial because a jury instruction on accomplice liability plainly violated the newly announced rule in State v. Milton. The court of appeals affirmed, concluding that the accomplice liability instruction was legally erroneous but that Appellant was not entitled to relief under Minn. R. Crim. P. 31.02 because the law was unsettled at the time of the error and did not become settled in favor of Appellant until the time of appeal. The Supreme Court affirmed as modified, holding (1) Rule 31.02 is not limited to errors that were plain at the time of trial, but, rather, under this rule a court must examine the law in existence at the time of appellate review; but (2) Appellant in this case was not entitled to a new trial because the alleged error did not affect Appellant’s substantial rights. View "State v. Kelley" on Justia Law

After Sining Mao left his employment with Seagate Technology, LLC, Mao joined Seagate’s competitor, Western Digital Corporation. Seagate subsequently commenced a district court action alleging that Mao stole Seagate’s trade secrets and confidential information and provided it to Western Digital. Western Digital invoked an arbitration clause in Mao’s employment agreement with Seagate. Before the arbitration hearing, Seagate brought a motion for sanctions against Western Digital and Mao (Appellants) based on alleged fabrication of evidence. An arbitrator issued an award against Appellants in an amount exceeding $500 million. The district court vacated the award in part, but the court of appeals reinstated the award. On appeal, Appellants argued that the arbitrator’s exceeded his authority by issuing punitive sanctions and prejudiced Appellants by refusing to hear evidence material to the controversy. The Supreme Court affirmed the court of appeals’ decision reinstating and confirming the arbitration award in full, holding that the arbitrator did not exceed his authority or refuse to hear material evidence as required for vacatur. View "Seagate Tech., LLC v. W. Digital Corp." on Justia Law

After a jury trial, Appellant was convicted of one count of first-degree premeditated murder and two counts of first-degree felony murder. The Supreme Court consolidated Appellant’s direct appeal and his postconviction appeal and held (1) the mandatory imposition of life without the possibility of release (LWOR) on the first-degree premeditated murder conviction violated the Eighth Amendment’s prohibition on cruel and unusual punishment under Miller v. Alabama; and (2) the postconviction court did not err in denying postconviction relief, the district court did not err in its evidentiary rulings or in imposing consecutive sentences, and the arguments Appellant raised in a pro se supplemental brief were without merit. Remanded for resentencing on the first-degree premeditated murder conviction. View "State v. Ali" on Justia Law

Appellant was convicted of first-degree premeditated murder for the benefit of a gang and related offenses and was sentenced to life in prison without the possibility of release. In his third petition for postconviction relief, Appellant alleged that three witnesses testified falsely at his trial. The postconviction court denied Appellant’s petition without an evidentiary hearing. The Supreme Court reversed, holding that Appellant alleged facts that, if proven, would entitle him to relief, and therefore, the postconviction court abused its discretion when it failed to grant Appellant an evidentiary hearing in connection with his petition. Remanded for an evidentiary hearing. View "Caldwell v. State" on Justia Law

Following a bench trial, Appellant was convicted of three counts of first-degree premeditated murder and sentenced to three consecutive life sentences without the possibility of release. The Supreme Court affirmed Appellant’s convictions on direct appeal, holding (1) the district court did not err in admitting an in-court identification of Appellant; (2) the district court did not abuse its discretion in excluding Appellant’s proposed expert testimony regarding the problems with eyewitness identification; and (3) Appellant was not entitled to a new trial based on alleged prosecutorial misconduct in eliciting three types of inadmissible character evidence. View "State v. Mosley" on Justia Law

A court-appointed guardian had the power to consent to necessary medical treatment for a ward under Minn. Stat. 524.5-313(c)(4)(k). Although all parties agreed that it was in the ward’s best interests to remove him from life-sustaining treatment, the guardian argued that court approval was not required before he could consent to remove the ward from life support systems. The district court concluded that guardians do not have the power to direct the removal of life support without prior court approval. The court of appeals reversed, concluding that the medical-consent power granted to a guardian under section 524.5-313(c)(4) includes the power to authorize disconnection of a ward’s life-support systems without authorization from the district court. The Supreme Court affirmed, holding that the power of a guardian to consent to necessary medical treatment for a ward under the statute includes the power to consent to the removal of a ward from life support systems, without court approval, when all interested parties agree that removal is in the ward’s best interest. View "In re Guardianship of Tschumy" on Justia Law

LumiData, Inc. is a software company that sells a software program called SOLYS to retail suppliers. Between 2005 and 2008, LumiData did not file Minnesota sales tax returns or pay sales tax on its SOLYS sales. The Commissioner of Revenue assessed sales tax on LumiData’s SOLYS sales for the period at issue, concluding the software sales were subject to sales tax. LumiData appealed the Commissioner’s order to the tax court, arguing that its software sales were nontaxable because modifications it made to its software removed it from the definition of “prewritten computer software” within the meaning of Minn. Stat. 297A.61(17). The tax court upheld the assessment, concluding that SOLYS was taxable, prewritten computer software. The Supreme Court affirmed, holding (1) because LumiData did not separately state its customization charges in its invoices, the tax court correctly concluded that the sales price for SOLYS was taxable as a sale of prewritten computer software; and (2) because the record did not establish that LumiData had reasonable cause to believe that its sales of SOLYS were not taxable, the tax court did not err in upholding the Commissioner’s penalty assessments. View "LumiData, Inc. v. Comm’r of Revenue" on Justia Law

Minn. Stat. 260C.301(1)(b)(4) provides that parents who previously have had their parental rights to children involuntarily terminated are presumed to be palpably unfit to parent other children. In this case, a few weeks after Hennepin County filed a petition to terminate Parents’ rights to their four children, Mother gave birth to a fifth child. The juvenile court terminated Parents’ rights to their four older children. The County subsequently filed a petition to terminate Parents’ rights to the newborn pursuant to section 260C.301(1)(b)(4). The juvenile court found that both parents failed to overcome the presumption of unfitness and that it was in the child’s best interests to terminate their parental rights. The court of appeals affirmed. Mother filed a petition for judicial review, arguing that the presumption of palpable unfitness found in section 260C.301(1)(b)(4) violates the Equal Protection Clause of the Minnesota and United States Constitutions. The Supreme Court affirmed, holding that section 260C.301(1)(b)(4) is narrowly tailored to serve the government’s compelling interest, and therefore, the statute does not violate the equal protection provisions of the State or Federal Constitutions. View "In re Welfare of the Child of R.D.L. & J.W." on Justia Law

Appellant was charged with, and pleaded guilty to, first-degree murder while committing domestic abuse. The district court accepted Appellant’s guilty plea, convicted him, and sentenced him to life imprisonment with the possibility of release. Appellant later filed a motion to withdraw his guilty plea, asserting that enforcing his guilty plea was manifestly unjust because the plea was not accurate, intelligent, or voluntary. The postconviction court denied relief. The Supreme Court affirmed. Appellant then filed a second postconviction petition, alleging that his guilty plea was inaccurate and that the attorney who represented him on his first postconviction petition provided ineffective assistance. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court (1) did not abuse its discretion when it concluded that Appellant’s challenge to his guilty plea was procedurally barred; and (2) did not abuse its discretion when it summarily denied Appellant’s ineffective assistance of postconviction counsel claim because the petition and records conclusively showed that Appellant was not entitled to relief. View "Lussier v. State" on Justia Law

Alice Staab sued Diocese of St. Cloud for negligence. The jury awarded compensatory damages of $224,200, attributing fifty percent of the negligence that caused Alice’s injuries to the Diocese and fifty percent to Alice’s husband, Richard. Richard was not named as a party in the lawsuit. The district court entered judgment for $224,200 against the Diocese, concluding that Minn. Stat. 604.02(1), which limits liability for a severally liable person, does not apply when only one defendant is named in a lawsuit. The Supreme Court reversed, holding that section 604.02(1) applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor. On remand, the district court entered judgment against the Diocese for the entire damages award, concluding that an uncollectible share of damages attributable to a nonparty tortfeasor can be reallocated under Minn. Stat. 604.02(2). The court of appeals affirmed the reallocation. The Supreme Court reversed, holding that a party who is severally liable under section 604.02(1) cannot be ordered to contribute more than that party’s equitable share of the total damages award through the reallocation-of-damages provision in section 604.02(2). Remanded. View "Staab v. Diocese of St. Cloud" on Justia Law