Justia Minnesota Supreme Court Opinion Summaries

The State acquired three parcels of land for use during construction of Interstate 394. Because the State no longer needed the parcels, it planned to convey the land to the Golden Valley Housing and Redevelopment Authority (HRA). Webb Golden Valley owned nearby land and argued that the conveyance violated Minn. Stat. 161.44(1). The district court (1) granted Defendants’ motion to dismiss as to two of the parcels for lack of standing, and (2) dismissed the complaint in its entirety when Webb failed to post a surety bond. The court of appeals reversed, holding (1) Webb’s interest in purchasing the two parcels was sufficient to confer standing to challenge the State’s proposed transfer; and (2) the HRA’s allegations of public harm were not supported by evidence in the record, and therefore the district court erred in granting the HRA’s motion for an order directing Webb to post a surety bond. The Supreme Court affirmed in part and reversed in part, holding (1) Webb had standing to bring this suit; but (2) the district court did not abuse its discretion by ordering Webb to post a surety bond, and because Webb did not post the surety bond, the district court did not err in dismissing Webb’s lawsuit with prejudice. View "Webb Golden Valley, LLC v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to terroristic threats. The victim filed a request for restitution, including the cost of hiring an employee to help the victim perform his job while his injuries healed. The district court concluded that the language of Minn. Stat. 611A.045(1) does not prohibit consideration of the victim’s fault and thus awarded the victim only half of the employment-related expenses that he sought because the victim was the initial aggressor. The court of appeals reversed and remanded with instructions to the district court to consider only the factors identified in section 611A.045(1) when determining the amount of restitution. The Supreme Court affirmed, holding that a victim’s role as an initial aggressor may not be considered when determining the amount of restitution to award for economic loss sustained by the victim as a result of the offense. View "State v. Riggs" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court (1) did not err in admitting evidence from Appellant’s cell phone because the police lawfully seized the cell phone under the plain-view exception to the warrant requirement; (2) did not err in admitting evidence obtained from the execution of numerous search warrants because the search warrants were supported by probable cause; and (3) did not abuse its discretion in dismissing a juror for cause. View "State v. Holland" on Justia Law

After a jury trial, Respondent was convicted of unintentional second-degree murder. During trial the State sought to introduce evidence, through the admission of evidence of Respondent’s prior bad acts, that Respondent had a pattern of shifting blame and falsely asserting self-defense after being the aggressor in an altercation. Respondent appealed, claiming that the admission of evidence relating to three previous assaults constituted impermissible character evidence. The court of appeals reversed and remanded for a new trial, concluding that the evidence did not tend to disprove the elements of self-defense and therefore unfairly prejudiced the defense. The Supreme Court reversed, holding (1) evidence of Respondent’s pattern of shifting blame and falsely asserting self-defense was relevant to one or more of the elements of Defendant’s self-defense claim; and (2) the trial court did not commit reversible error when it admitted the previous incidents of assault. View "State v. Welle" on Justia Law

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct for sexually penetrating a member of the parish where he served as a priest. The court of appeals reversed and ordered a new trial, holding that the district court erred in (1) failing to provide a specific-unanimity instruction; (2) failing to instruct the jury that State was required to prove that Defendant had subjective knowledge of the purpose of the meeting at which sexual penetration occurred; and (3) denying Defendant’s motion to admit evidence of the complainant’s sexual history after it admitted the State’s evidence of the victim’s sexual inexperience. The Supreme Court reversed, holding (1) the district court’s failure to provide a specific-unanimity jury instruction did not affect Defendant’s substantial rights; (2) the clergy sexual conduct statute does not require the clergy member to know that the complainant seeks or is receiving spiritual counsel; and (3) even assuming the district court abused its discretion in disallowing Defendant’s sexual-history evidence, any error was harmless beyond a reasonable doubt. View "State v. Wenthe" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder committed for the benefit of a gang and first-degree premeditated murder. Appellant was convicted of first-degree premeditated murder, and the district court imposed a sentence of life without the possibility of release. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, alleging, inter alia, newly discovered evidence of the recantations of two witnesses. The Supreme Court remanded the case to the postconviction court for an evidentiary hearing on the witness recantation claim. Thereafter, Appellant filed a second petition for postconviction relief, alleging that his sentence was unconstitutional and that he was entitled to retroactive application of Miller v. Alabama. The postconviction court consolidated both matters, conducted an evidentiary hearing, and (1) denied Appellant’s witness recantation claim from his first postconviction petition, and (2) denied Appellant’s second postconviction petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to a new trial on his witness recantation claim; and (2) Appellant’s second petition for postconviction relief was time-barred. View "Martin v. State" on Justia Law

Respondent suffered a significant injury in a motor vehicle accident and was totally disabled for approximately five months. During her period of disability, Respondent was unable to perform most household duties. Respondent later filed a claim for replacement service loss benefits with her no-fault insurance provider, Western National Mutual Insurance Co. (Appellant), alleging that she was entitled to the reasonable value of the home care and maintenance services she was unable to perform. Appellant refused to pay Respondent’s claim, asserting that it would not reimburse Respondent for household services that were not replaced in some way. An arbitrator awarded Respondent’s entire claim. The district court denied Appellant’s motion to vacate the arbitration award. The court of appeals affirmed, concluding that Minn. Stat. 65B.44(5) does not require replacement of household services when the injured person is primarily responsible for household duties. The Supreme Court affirmed, holding that an injured person who has primary responsibility for care and maintenance of the household need not replace household services as a condition to recovering the reasonable value of such services under section 65B.44(5). View "Schroeder v. Western Nat’l Mut. Ins. Co." on Justia Law

Appellant was denied a promotion after based on the results of a civil service test conducted by the Richfield Police and Fire Civil Service Commission. Appellant filed a petition for writ of certiorari with the Court of Appeals, arguing that the Commission’s promotional process failed to meet the requirements of Minn. Stat. 419.06(9). The Supreme Court reversed, holding (1) the Court of Appeals erred by determining that the term “records” under section 419.06(9) includes a candidate’s interview responses at the time the candidate is applying for a promotion; and (2) the Commission violated section 419.06(9) when it failed to consider records “kept in the regular course of the administration of civil service” as required by statute. View "Peterson v. Richfield Civil Serv. Comm’n" on Justia Law

After a jury trial, Appellant was convicted of unlawful possession of a firearm and first-degree felony murder. The district court sentenced Appellant to life in prison with the possibility of release. The Supreme Court affirmed, holding that the district court (1) erred in instructing the jury on the intent element of burglary, the predicate offense for the felony-murder charge, but the error did not constitute reversible plain error; (2) erred in suggesting the order in which the jury should consider the charges when instructing the jury, but the error was not plain; (3) did not abuse its discretion by excluding alternative-perpetrator evidence of Appellant’s alleged bad acts; and (4) did not violate Minn. R. Crim. P. 26.03(1) by proceeding with the trial in Appellant’s absence. View "State v. Davis" on Justia Law

Appellant was convicted of second-degree unintentional murder. Appellant waived his right to a sentencing jury. The district court imposed a 420-month sentence, an upward durational departure of 168 months, determining that Defendant’s concealment of the victim’s body was an aggravating factor sufficient to justify the upward durational departure. The court of appeals affirmed the sentence. The Supreme Court affirmed, holding that concealment of a murder victim’s body is an aggravating factor on which a district court may base an upward departure, and therefore, the district court did not abuse its discretion when it imposed an upward durational departure on Appellant’s sentence for second-degree unintentional murder. View "State v. Hicks" on Justia Law