Justia Minnesota Supreme Court Opinion Summaries

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 After the Insured died, the Insurer refused to pay the death benefit to Plaintiff, the Insured’s widow, and rescinded the life insurance policy based on its discovery that the Insured had failed to disclose that he had undergone certain medical procedures.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

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