Justia Minnesota Supreme Court Opinion Summaries

Minn. Stat. 260C.301(1)(b)(4) provides that parents who previously have had their parental rights to children involuntarily terminated are presumed to be palpably unfit to parent other children. In this case, a few weeks after Hennepin County filed a petition to terminate Parents’ rights to their four children, Mother gave birth to a fifth child. The juvenile court terminated Parents’ rights to their four older children. The County subsequently filed a petition to terminate Parents’ rights to the newborn pursuant to section 260C.301(1)(b)(4). The juvenile court found that both parents failed to overcome the presumption of unfitness and that it was in the child’s best interests to terminate their parental rights. The court of appeals affirmed. Mother filed a petition for judicial review, arguing that the presumption of palpable unfitness found in section 260C.301(1)(b)(4) violates the Equal Protection Clause of the Minnesota and United States Constitutions. The Supreme Court affirmed, holding that section 260C.301(1)(b)(4) is narrowly tailored to serve the government’s compelling interest, and therefore, the statute does not violate the equal protection provisions of the State or Federal Constitutions. View "In re Welfare of the Child of R.D.L. & J.W." on Justia Law

Appellant was charged with, and pleaded guilty to, first-degree murder while committing domestic abuse. The district court accepted Appellant’s guilty plea, convicted him, and sentenced him to life imprisonment with the possibility of release. Appellant later filed a motion to withdraw his guilty plea, asserting that enforcing his guilty plea was manifestly unjust because the plea was not accurate, intelligent, or voluntary. The postconviction court denied relief. The Supreme Court affirmed. Appellant then filed a second postconviction petition, alleging that his guilty plea was inaccurate and that the attorney who represented him on his first postconviction petition provided ineffective assistance. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court (1) did not abuse its discretion when it concluded that Appellant’s challenge to his guilty plea was procedurally barred; and (2) did not abuse its discretion when it summarily denied Appellant’s ineffective assistance of postconviction counsel claim because the petition and records conclusively showed that Appellant was not entitled to relief. View "Lussier v. State" on Justia Law

Alice Staab sued Diocese of St. Cloud for negligence. The jury awarded compensatory damages of $224,200, attributing fifty percent of the negligence that caused Alice’s injuries to the Diocese and fifty percent to Alice’s husband, Richard. Richard was not named as a party in the lawsuit. The district court entered judgment for $224,200 against the Diocese, concluding that Minn. Stat. 604.02(1), which limits liability for a severally liable person, does not apply when only one defendant is named in a lawsuit. The Supreme Court reversed, holding that section 604.02(1) applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor. On remand, the district court entered judgment against the Diocese for the entire damages award, concluding that an uncollectible share of damages attributable to a nonparty tortfeasor can be reallocated under Minn. Stat. 604.02(2). The court of appeals affirmed the reallocation. The Supreme Court reversed, holding that a party who is severally liable under section 604.02(1) cannot be ordered to contribute more than that party’s equitable share of the total damages award through the reallocation-of-damages provision in section 604.02(2). Remanded. View "Staab v. Diocese of St. Cloud" on Justia Law

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