Justia Minnesota Supreme Court Opinion Summaries

Defendant was the driver of a vehicle that was involved in a single-vehicle rollover crash. The accident resulted in one fatality. At the time of the accident, an officer obtained a blood draw from Defendant, and later testing of that blood revealed an alcohol concentration of 0.20. The State charged Defendant with three counts of criminal vehicular operation resulting in death, two counts of fourth-degree driving while impaired, reckless driving, and careless driving. Defendant filed a motion to suppress the alcohol concentration test results on the grounds that his blood was drawn without a warrant and without his consent. The district court suppressed the alcohol concentration test results, concluding that the State failed to satisfy the exigent circumstances exception as applied in Missouri v. McNeely. The court of appeals reversed, concluding that the State established that exigent circumstances justified the warrantless blood draw. The Supreme Court affirmed, holding that the State proved the existence of exigent circumstances justifying the warrantless blood draw. View "State v. Stavish" on Justia Law

The City of Rochester contracted with Rochester City Lines, Co. (RCL) for more than thirty years to operate the municipal bus service in Rochester. In 2011, the Federal Transit Administration informed the City that, in order to continue to receive federal funding, the City needed to initiate a competitive bidding process for its next contract. During the City's ensuing bidding process, RCL filed a lawsuit against the City, claiming that the City’s actions were an unconstitutional taking of RCL’s property. The City subsequently awarded the contract to First Transit, Inc. RCL subsequently amended its complaint to add claims against members of the City Council and First Transit. The district court granted summary judgment to Defendants on each of RCL’s claims. The court of appeals affirmed. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) RCL presented sufficient evidence to create a genuine issue of material fact on the question of whether the City awarded the contract to First Transit based on an unfair and biased process; and (2) the district court properly granted summary judgment on the remainder of RCL’s claims. View "Rochester City Lines, Co. v. City of Rochester" on Justia Law

Appellant was convicted of third-degree driving while impaired. At trial, the court admitted test results showing Appellant’s alcohol concentration at the time of the incident that were based on a warrantless blood draw. After the court of appeals affirmed the conviction, the Supreme Court decided Missouri v. McNeely, which held that the dissipation of alcohol in the blood does not create a single-factor exigency justifying a warrantless blood draw of suspected drunk drivers. Defendant petitioned for review to determine whether, in light of McNeely, her blood draw was an unconstitutional search. The Supreme Court vacated the court of appeals’ decision and remanded for further proceedings in light of McNeely. On remand, the court of appeals again affirmed. The Supreme Court affirmed, holding (1) McNeely applies to cases on direct review at the time of decision; but (2) the test results from Appellant’s blood draw, even if obtained in violation of Appellant’s constitutional rights, need not be suppressed because the officer who facilitated the blood draw acted in objectively reasonable reliance on binding appellate precedent. View "State v. Lindquist" on Justia Law

After the Dakota County Assessor estimated the market value of Westview Mall, owned by KCP Hastings, LLC, KCP challenged the estimated assessments. After a trial, the tax court adopted market valuations of the property that exceeded the County’s estimated assessments. The Supreme Court affirmed in part, vacated in part, and remanded, holding that the tax court (1) did not clearly err by using the mall’s gross building area rather than its gross leasable area in its calculations of market value; (2) clearly erred when it rejected KCP’s discounted-cash-flow analysis, which KCP’s appraiser used to arrive at his income-approach valuation; and (3) abused its discretion by determining the value of the subject property relying solely on the sales-comparison approach. View "KCP Hastings, LLC v. County of Dakota" on Justia Law

The property at issue in this appeal was the ethanol-production facility owned by Guardian Energy, LLC. After the county assessor estimated the market value of the property, Guardian Energy challenged the assessments by filing petitions with the tax court. The tax court determined that the assessed value of the property was significantly higher than the values proposed by either party. Guardian Energy sought review. The Supreme Court (1) affirmed the tax court’s determination that twenty-seven tanks used in the ethanol-production process were taxable real property; but (2) vacated the tax court’s valuation of the ethanol plant, holding that the tax court failed adequately to explain its calculation of external obsolescence, and therefore, the court’s valuation of the facility was not reasonably supported by the record as a whole. View "Guardian Energy, LLC v. County of Waseca" on Justia Law

Relators were sixteen electric cooperatives located in Minnesota. The cooperatives filed amended sales-tax returns for tax periods spanning the years 2004-06 to recover sales taxes they had paid for the portion of the revenues that they later converted into equity. The Commissioner of Revenue initially granted the refunds claimed on the cooperatives’ amended returns. However, the Commissioner later determined that the refund was made in error and assessed the cooperatives to recover the amounts refunded to them. The cooperatives appealed. The tax court concluded that the cooperatives were not legally entitled to sales-tax refunds for any earnings that they later converted into equity and that the challenged assessments were timely. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) electric cooperatives may not reclassify portions of monthly payments by their customers as equity contributions and receive sales-tax refunds based on the reclassification; and (2) when the Commissioner assesses a taxpayer based on a deficiency created by an erroneous refund, the two-year statute of limitations for erroneous refunds generally applies. View "Connexus Energy v. Comm’r of Revenue" on Justia Law

After a jury trial in 1995, Appellant was found guilty of first-degree premeditated murder and attempted first-degree premeditated murder. The district court imposed a sentence of life imprisonment with the possibility of release for the first-degree murder offense and a consecutive sentence of 180 months’ imprisonment for the attempted first-degree murder offense. In 2014, Appellant, who is African American, moved to correct his sentence, arguing that his sentence was unlawful under Minn. Sent. Guidelines II.F and that his sentence violated his right to equal protection because his sentence was more severe than the sentences of other similarly situated offenders who were not African American. The postconviction court denied relief. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by denying Appellant’s motion to correct his sentence. View "Nunn v. State" on Justia Law

Appellant was convicted of first-degree murder of a peace officer. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a postconviction petition, which the district court denied. The Supreme Court affirmed. Thereafter, Appellant filed a motion for relief from judgment alleging a number of claims, including ineffective assistance of trial and appellate counsel. Treating Appellant’s motion as a second postconviction petition, the district court denied relief, concluding that all of Appellant’s claims were untimely under Minn. Stat. 590.01(4). The Supreme Court affirmed, holding (1) even if the district court had treated Appellant’s request for relief as a motion under Minn. R. Civ. P. 60.02, his request would have been untimely; and (2) Appellant’s claims were also untimely under the postconviction statute. View "Evans v. State" on Justia Law

Based on an indirect audit that the Commissioner of the Minnesota Department of Revenue conducted of the sales and use tax returns for Conga Corporation for the tax periods from January 1, 2007 through March 31, 2010, the Commissioner determined that Conga had unreported revenues for the relevant tax periods and issued an order assessing additional sales, use, and entertainment taxes, plus penalties and interest. The tax court affirmed the Commissioner’s order with respect to the assessment of 2007 taxes but reversed with the penalty assessment for tax years 2008-2010, concluding that the Commissioner’s decision to use an indirect audit was not supported by the record. The Supreme Court reversed, holding that the Commissioner’s decision to use an indirect audit to assess taxes was supported by the record. Remanded. View "Conga Corp. v. Comm’r of Revenue" on Justia Law

On July 13, 2007, Appellant was charged with fifth-degree controlled substance crime. Appellant pleaded guilty. On February 27, 2009, the court stayed adjudication of Appellant’s case under Minn. Stat. 152.18(1), placing him on probation. On May 24, 2011, Appellant admitted to violating the terms of his probation. The district court revoked the stay of adjudication and entered a judgment of conviction. On May 23, 2013, Appellant filed a petition for postconviction relief requesting that he be permitted to withdraw his guilty plea. The postconviction court summarily denied the petition on the ground that it was untimely under Minn. Stat. 590.01(4)(a)(1) because it was filed more than two years after the order staying adjudication. The court of appeals affirmed, holding that a stay of adjudication is a “sentence” under Minn. Stat. 590.01(4)(a)(1) that triggers the two-year statute of limitations for filing a postconviction petition. The Supreme Court reversed, holding that a stay of adjudication under Minn. Stat. 152.18(1) is not a judgment of conviction or sentence under Minn. Stat. 590.01(4)(a)(1), and therefore, the district court erred by concluding that Appellant’s petition was time-barred. View "Dupey v. State" on Justia Law