Justia Minnesota Supreme Court Opinion Summaries

In 2005, the City of Winona enacted the thirty-percent rule, which limits the number of lots on a block in certain areas of the City that are eligible for certification as rental properties. Appellants brought this action challenging the rental ordinance, claiming that the thirty-percent rule is a zoning law that exceeds the City’s power authorized by Minn. Stat. 462.357 and violates their equal protection and substantive due process rights. The district court granted summary judgment in favor of the City, concluding that the ordinance is not unconstitutional and that the City had authority to enact it. The court of appeals affirmed. Appellants filed a petition for review. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that Appellants' claims had become moot because, under the facts and circumstances of this case, the alleged harm to Appellants’ interests had ceased. View "Dean v. City of Winona" on Justia Law

In 1994, Appellant was convicted of first-degree murder. In 1995, Appellant pleaded guilty to second-degree attempted murder. In 2014, Appellant brought a fifth postconviction petition alleging ineffective assistance of appellate counsel. The postconviction court denied the petition without an evidentiary hearing, concluding that it was both time-barred and procedurally barred. Also in 2014, Appellant brought a second motion to correct his sentence. The postconviction court concluded that the Supreme Court had already decided the issue and denied the motion. The Supreme Court affirmed in both matters, holding (1) Appellant’s postconviction petition was time-barred under Minn. Stat. 590.01(4)(a); and (2) Appellant’s motion to correct his sentence raised the same issue that this Court decided in Appellant's previous petition had no merit, and therefore, the second motion was properly denied. View "Townsend v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life in prison. The Supreme Court affirmed. Appellant then filed a pro se petition for postconviction relief alleging, inter alia, ineffective assistance of appellate counsel and newly discovered evidence. The postconviction court summarily denied relief on all claims with the exception of the newly discovered evidence claim. After an evidentiary hearing, the postconviction court denied the newly discovered evidence claim. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it (1) summarily denied Appellant’s ineffective assistance of counsel claim because the facts alleged in the petition failed to satisfy the Strickland test; (2) denied Appellant’s newly discovered evidence claim after an evidentiary hearing because the record supported the court’s finding that the testimony of the newly discovered witnesses was doubtful; and (3) summarily denied Appellant’s remaining claims because those claims were procedurally barred. View "Carridine v. State" on Justia Law

Reichmann Land and Cattle, LLP managed a winter feeding facility. In 2011, the Minnesota Pollution Control Agency (MPCA) issued an administrative order requiring Reichmann to obtain national-pollutant-discharge-elimination-system (NPDES) and state-disposal-system (SDS) permits or discontinue the winter feeding operation. Reichmann requested a contested case hearing. An administrative law judge (ALJ) concluded that Reichmann’s winter feeding fields constituted a “concentrated animal feeding operation” and were not “pastures.” Therefore, Reichmann was required to apply for an NPDES/SDS permit. The Commissioner of the MPCA adopted the findings and conclusions of the ALJ. The court of appeals affirmed the Commissioner’s conclusion that Reichmann must apply for an SDS permit but reversed the Commission’s requirement that Reichmann must apply for an NPDES permit. The Supreme Court affirmed, holding (1) Reichmann need not obtain an NPDES permit because its winter feeding facility is not an animal feeding operation as required by 40 C.F.R. 122.23(b)(1); and (2) Reichmann is required to obtain an SDS permit because it does not qualify for the pasture exemption. View "In re Reichmann Land & Cattle, LLP" on Justia Law

Respondent sustained injuries while employed by Employer. In 2010, Respondent sought workers’ compensation benefits, claiming that as a result of his injury he developed complex regional pain syndrome (CRPS) and that he was entitled to compensation for certain medical expenses, including expenses incurred for the implantation of a spinal cord neurostimulator. The compensation judge concluded that Respondent had failed to show that the effects of his work-related injury included CRPS and therefore necessitated a neurostimulator. The Workers’ Compensation Court of Appeals (WCCA) affirmed. In 2013, Respondent filed a second request for medical benefits seeking compensation for the expenses related to the replacement of his neurostimulator. The compensation judge dismissed the claim, concluding that Respondent’s 2013 claim was barred by res judicata and collateral estoppel. The WCCA reversed. The Supreme Court vacated the decision of the WCCA, holding (1) res judicata did not preclude Respondent’s 2013 claim; but (2) in resolving the 2013 claim, the compensation judge did not determine whether Respondent’s medical condition had changed or new material facts had emerged, a determination that was necessary in order to resolve whether collateral estoppel precluded the 2013 claim. Remanded. View "Mach v. Wells Concrete Prods. Co." on Justia Law

In 1987, after a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Thereafter, Appellant filed four petitions for postconviction relief and a motion for postconviction DNA testing. All of the petitions or motions were denied. In 2014, Appellant filed his seventh request for relief raising several claims. The postconviction court denied Appellant’s petition without an evidentiary hearing, determining that his claims were time-barred under Minn. Stat. 590.01 and procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Appellant’s petition was untimely under Minn. Stat. 590.01(4)(a)(2). View "Wayne v. State" on Justia Law

The district court ordered Father to pay monthly child support. Dakota County was a party to the proceeding because Mother had applied for non-public assistance child support services. Father later retired due to disability and began receiving Social Security benefits. As a result, Mother began receiving derivative Social Security benefits on behalf of the children. Father moved to modify his child support obligation. The child support magistrate granted Father’s motion in part and offset his prospective child support obligation by the derivative Social Security benefits received by Mother. Both parties sought review. The district court concluded Father was entitled to credit for the derivative Social Security benefits received by Mother at the time Mother began receiving derivative Social Security benefits but before Father served notice of the motion to modify. The Supreme Court reversed, holding that a modification of a child support order is retroactive to the date of service of the notice of motion to modify. View "In re Dakota County" on Justia Law

Prior to his death and after consulting a lawyer about divorcing Wife, Husband changed the beneficiary on his term life insurance policy from Wife to Respondents, his parents and sister. Less than four months before Husband’s death, Wife petitioned for dissolution of marriage to Husband. Following Husband’s death, the district court dismissed the dissolution proceeding. Wife subsequently filed suit against Respondents, alleging that Husband’s transfer violated Minn. Stat. 518.58(1)(a), which prohibits the transfer of “marital assets” by a party who contemplates commencing a marriage dissolution. The district court granted summary judgment to Respondents. The court of appeals affirmed, holding that section 518.58(1)(a) did not apply to Wife’s claim because her dissolution proceeding abated upon Husband’s death and the statute applies only in current dissolution proceedings. The Supreme Court affirmed, holding that because the language of section 518.58(1)(a) limits the statute’s application to pending dissolution proceedings, the statute did not provide Wife, who was no longer a party to a marital dissolution proceeding, a remedy in this case. View "Nelson v. Nelson" on Justia Law

Yer Sumner was injured when she fell while working for Jim Lupient Infiniti. Sumner filed a claim petition for workers’ compensation benefits. Lupient denied primary liability. After Sumner filed her claim petition, eleven entities (collectively, Intervenors), including two health-care providers that provided treatment to Sumner (collectively, Relators), moved to intervene as of right. Lupient objected to the compensability of the services for which several Intervenors, including Relators, sought reimbursement. Intervenors had their claims for reimbursement denied when they failed to attend a hearing before a compensation judge. Relators and Sumner appealed. The Workers’ Compensation Court of Appeals affirmed the denial of Relators’ reimbursement claims. The Supreme Court affirmed, holding that, because Relators were absent from the hearing, and none of the exceptions to the attendance requirement was met, the compensation judge did not err when he denied Relators’ claims for reimbursement. View "Sumner v. Jim Lupient Infiniti" on Justia Law

Prior to his scheduled probation revocation hearing, Probationer moved the district court judge for disqualification or, in the alternative, to direct the chief judge of the district to determine whether the district court judge was disqualified due to what Probationer alleged was a “reasonable question” about judicial impartiality. The district court rejected Probationer’s motions in their entirety without issuing a written order and, after a probation revocation hearing, revoked Probationer’s probation and executed his sentence. On appeal, Probationer argued that Minn. R. Crim. P. 26.03(14)(3) requires the chief judge of the district court to hear requests to disqualify. The court of appeals affirmed, concluding that Probationer’s arguments failed both procedurally and on the merits. The Supreme Court reversed the decision of the court of appeals and vacated the probation revocation order, holding (1) Probationer’s appeal was not procedurally flawed; and (2) the district court erred when it declined to refer the request to disqualify to the chief judge of the district, and the error was not harmless. View "State v. Finch" on Justia Law