Justia Minnesota Supreme Court Opinion Summaries

An airport police narcotics investigator removed a package, which was addressed to Defendant, from a conveyor belt at the UPS mail area at the Minneapolis-Saint Paul International Airport, and placed the package on the floor. A trained narcotics-detection dog was brought into the area and alerted to the package. Based on the dog’s alert, an airport police narcotics investigator obtained a warrant authorizing him to open and search the package, which contained cocaine and methamphetamine. Appellant was charged with two counts of a first-degree controlled substance crime. Appellant filed a motion to suppress, arguing that the movement of the package to the floor constituted a seizure, that the dog sniff constituted a search, and that the package was seized and searched without a reasonable, articulable suspicion of criminal activity. The district court denied Petitioner’s motion, concluding that the detention and dog sniff did not constitute a search or seizure. The court of appeals affirmed on other grounds, determining that there was both a search and a seizure but that there was reasonable, articulable suspicion for both. The Supreme Court affirmed on the same basis as the district court, holding that there was neither a search nor a seizure under the facts of this case. View "State v. Eichers" on Justia Law

Minn. Stat. 504B.177 generally places a limitation on late fees for residential housing tenants at eight percent of the overdue rent payment. In this case, Respondent, a tenant living in federally subsidized housing, failed to pay late fees assessed by the Housing and Redevelopment Authority of Duluth (HRA) under his lease. The HRA filed this eviction action for nonpayment of rent. The total amount in arrears was $50. At issue before the district court was whether the monthly $25 late fee provided in the parties’ lease violated section 504B.177. The district court entered judgment for the HRA, concluding that federal law preempts the state limitation on late fees with respect to public housing authorities. The court of appeals reversed. The Supreme Court affirmed, holding (1) the eight percent limitation on late fees in section 504B.177(a) is not preempted by federal law and does not conflict with a federal statute, regulation, or handbook under section 504B.177(b); and (2) therefore, the HRA was subject to the eight percent limitation. View "Housing & Redevelopment Auth. of Duluth v. Lee" on Justia Law

Respondent filed a complaint against his former employer, U.S. Steel Corporation, alleging retaliatory-discharge and threat-to-discharge claims under the Workers’ Compensation Act. The district court granted U.S. Steel’s pretrial motion to quash Respondent’s demand for a jury trial on the retaliatory-discharge claim. After a bench trial, the district court entered judgment for Respondent on his threat-to-discharge claim and rejected Respondent’s retaliatory-discharge claim. The court of appeals affirmed in part and reversed in part, concluding (1) Respondent’s retaliatory-discharge claim, which sought only money damages, was legal rather than equitable in nature, and therefore, Respondent was entitled to a jury trial on that claim; and (2) the district court correctly denied U.S. Steel’s motion seeking to assert a Faragher/Ellerth affirmative defense to vicarious liability for Respondent’s threat-to-discharge claim. The Supreme Court affirmed, holding (1) Respondent had the right to a jury trial on his retaliatory-discharge claim; and (2) U.S. Steel may not assert a Faragher/Ellerth affirmative defense to Respondent’s threat-to-discharge claim. View "Schmitz v. U.S. Steel Corp." on Justia Law

Defendant was charged with third-degree assault. Defendant’s defense theory was that he acted in self-defense during a hallway confrontation with a non-resident of his apartment building. Before the case was submitted to the jury, the district court instructed the jury that Defendant had a duty to retreat if reasonably possible before acting in self-defense. A jury subsequently found Defendant guilty of third-degree assault and the lesser included offense of fifth-degree assault. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant had a duty to retreat if reasonably possible while in a non-exclusive hallway of his apartment building. View "State v. Devens" on Justia Law

Police officers followed a Chevrolet Monte Carlo that drove away from a house suspected of hosting drug trafficking. The officers subsequently stopped the vehicle after learning that the Monte Carlo’s registration had been revoked and that it was registered to Defendant, whose driver’s license had also been revoked. The driver, who was identified as Defendant, indicated that the car was not insured. The officers decided to tow and impound the vehicle. During an inventory search, the officers found drug and drug paraphernalia in a purse on the passenger seat of the Monte Carlo. Defendant was charged with possession of a controlled substance and possession of drug paraphernalia. Defendant filed a motion to suppress, aruing that the initial stop was lawful but that the search was unconstitutional because the police were not authorized to impound the vehicle, and the inventory search itself was pretextual. The district court denied the motion. The court subsequently found Defendant guilty on both counts. The Supreme Court reversed, holding that the impoundment was unreasonable, and therefore, the resulting inventory search was unconstitutional. View "State v. Rohde" on Justia Law

Appellant was stopped by police officers while driving in a 2003 Chevy Tahoe on suspicion that he did not have a valid driver’s license. Appellant was subsequently issued a traffic citation. The officers proceeded to conduct an inventory search of the Tahoe and found 225 grams of methamphetamine. The officers then searched Appellant and found $611 in cash. Appellant was charged with first-degree possession of a controlled substance. The vehicle and cash were seized, and Appellant was served with notice and intent to forfeit the seized property. Appellant filed a civil complaint demanding a judicial determination of forfeiture, arguing that the Fourth Amendment exclusionary rule applies to civil forfeiture actions and that the evidence supporting forfeiture was illegally obtained and must be suppressed. The district court granted summary judgment for the County. The court of appeals affirmed, concluding that the Fourth Amendment exclusionary rule does not apply to civil forfeiture actions. The Supreme Court reversed, holding (1) the exclusionary rule is applicable to civil forfeiture actions brought under Minn. Stat. 609.531-.5319; and (2) Appellant had standing to challenge the forfeiture of the vehicle and cash. Remanded. View "Garcia-Mendoza v. 2003 Chevy Tahoe" on Justia Law

Relator was injured while working for Employer. Relator began receiving workers’ compensation benefits in 2010. In 2012, Relator began receiving a retirement annuity from the Public Employees Retirement Association (PERA). At some point, Relator began receiving federal social security retirement benefits. While Employer was entitled under Minn. Stat. 176.101(4) to offset Relator’s permanent total disability benefits by the amount of her social security retirement benefits, the parties disagreed as to whether Employer was entitled to apply the offset to Relator’s PERA retirement benefits. A compensation judge granted Employer the offset. The Workers’ Compensation Court of Appeals (WCCA) affirmed, concluding that Relator’s PERA retirement annuity was an “old age and survivor insurance benefit.” The Supreme Court reversed, holding that, under the reasoning in Ekdahl v. Independent School District #213, also decided today, section 176.101(4) does not permit permanent total disability benefits to be offset by public employee pension benefits. Remanded. View "Hartwig v. Traverse Care Ctr." on Justia Law

Relator was injured while working for a School District. Relator eventually sought and was awarded permanent total disability (PTD) benefits. Relying on Minn. Stat. 176.101(4) and claiming that the statute authorizes an offset for “any old age and survivor insurance benefits,” the School District sought to offset its PTD benefit payment by the amount of government-service pension benefits Relator was receiving. A compensation judge concluded that the School District was not entitled to the offset. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that government-service pension benefits are included in the phrase “old age and survivor insurance benefits” and therefore can be offset from the School District’s disability-benefit payment. The Supreme Court reversed the WCCA and reinstated the decision of the compensation judge, holding that the phrase “old age and survivor benefits” refers only to federal social security benefits, and therefore, the WCCA erred when it applied section 176.101(4) to Relator’s retirement annuity. View "Ekdahl v. Indep. Sch. Dist. #213" on Justia Law

Employee was injured in a work-related accident. Employee obtained approval for surgery from a union-sponsored benefit plan (the Fund) and proceeded with the surgery at a Hospital. After a hearing, a workers’ compensation judge concluded that the surgery was not reasonable and necessary and ordered Employer to reimburse the Fund for the medical bills but also concluded that Employer could seek reimbursement of the expenses from the medical providers. The Hospital was not given notice of that hearing. Before a second hearing on Employer’s request for reimbursement, the Hospital intervened. The compensation judge ordered the Hospital to reimburse Employer. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that the automatic-reimbursement rule announced in Brooks v. A.M.F., Inc. should be extended to the Hospital because it was not given notice of the first hearing. The Supreme Court reversed after declining to extend its decision in Brooks and require automatic payment of a medical provider’s treatment expenses when an employer fails to give the medical provider notice of its right to intervene in a workers’ compensation proceeding to determine responsibility for those expenses, holding that the Hospital was not entitled to automatic payment of its medical bills for Employee’s treatment. Remanded. View "Gamble v. Twin Cities Concrete Prods." on Justia Law

The State filed a complaint against Defendant charging him with third- and fourth-degree criminal sexual conduct. Defendant waived his right to a jury trial during a pretrial hearing. Thereafter, the State filed an amended complaint adding a charge of first-degree criminal sexual conduct. Defendant did not personally waive his right to a jury trial on the amended charge. Defendant was subsequently found guilty of all three counts. Defendant appealed, arguing that the district court erred when it failed to obtain a personal waiver of his right to a jury trial after the State amended the complaint. The court of appeals affirmed Defendant’s first-degree sexual conduct conviction. The Supreme Court reversed the court of appeals, vacated Defendant’s conviction for first-degree criminal sexual conduct, and remanded, holding (1) when the State charges a defendant with an additional offense after the defendant has waived his or her right to a jury trial, the court must obtain a new waiver before dispensing with a jury; and (2) in this case, the district court’s failure to obtain a personal waiver of Defendant’s right to a jury trial on the charge of first-degree criminal sexual conduct constituted a plain error that affected Defendant’s substantial rights. View "State v. Little" on Justia Law