Justia Minnesota Supreme Court Opinion Summaries

The Chief Deputy of the Steele County Sheriff’s Office evaluated the performance of Respondent, a sergeant, and gave him a negative review. Respondent appealed the Sheriff’s decision with the Minnesota Department of Administration by submitting a statement explaining why he disagreed with portions of the performance evaluation. The Department summarily dismissed the administrative appeal. The court of appeals reversed and remanded the case for informal resolution or a contested-case proceeding under the Data Practices Act (Act). The Supreme Court affirmed, holding (1) the Department wrongly concluded that Respondent’s appeal categorically fell outside the scope of the Act; (2) there was no support for the Department’s argument that dismissal was proper because the appeal raised new challenges and relied on new evidence; and (3) the Department does not have unqualified and unreviewable authority to dismiss any appeal brought under the Act. View "Schwanke v. Minn. Dep’t of Admin." on Justia Law

Appellant was convicted for the first-degree premeditated murder of Devan Hawkinson. Appellant and Hawkinson were friends before Hawkinson was murdered. On appeal, Appellant argued that the district court erred by admitting evidence of his past conduct and relationship with Hawkinson, contending that the evidence violated his rights under the Confrontation Clause because it included testimonial statements that Hawkinson made to the police before his death and that it was irrelevant. The Supreme Court affirmed, holding (1) any error in admitting the evidence was harmless; and (2) none of the claims raised in Appellant’s pro se briefs entitled him to relief. View "State v. Rossberg" on Justia Law

The question presented in this case was whether the plausibility standard announced in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal applies to civil pleadings in Minnesota state court. Defendant in this case moved to dismiss Plaintiff’s complaint pursuant to Minn. R. Civ. P. 12.02(e) for failure to state a claim upon which relief can be granted, alleging that the complaint failed to allege enough facts to state a plausible claim. Using the Twombly plausibility standard, the district court dismissed Plaintiff’s complaint with prejudice, concluding that Plaintiff failed to establish facts giving rise to a plausible claim for relief. The court of appeals reversed after applying the state’s traditional pleading standard. The Supreme Court affirmed, holding (1) the Twombly plausibility standard does not govern civil pleadings in Minnesota; and (2) Plaintiff’s complaint satisfies the traditional pleading standard for civil actions in Minnesota. View "Walsh v. U.S. Bank, N.A." on Justia Law

Appellant pleaded guilty to one count of aiding and abetting first-degree premeditated intentional murder. The district court sentenced Appellant to a mandatory life sentence with the possibility of release after thirty years. More than eight years after Appellant was sentenced, the district court issued its restitution order, which ordered that Defendant be jointly and severally liable for paying $23,060 in restitution along with several of his codefendants. The Supreme Court affirmed in part, vacated in part, and remanded, holding (1) Defendant forfeited his argument that the restitution order improperly included restitution for losses for which an insurance company had already reimbursed the victim’s estate; (2) the order improperly calculated the restitution Appellant and his codefendants should pay for damage done to the victim’s car; and (3) the district court had statutory authority to order that the codefendants were jointly and severally liable for the restitution award. View "State v. Johnson" on Justia Law

In 1984 and 1985, James Stevens injured both shoulders while working for S.T. Services and CNA Insurance Companies (collectively, S.T. Services). In 1994, Stevens and S.T. Services entered into a stipulation for settlement under which the parties agreed that Stevens was permanently totally disabled and would receive ongoing permanent total disability benefits. A compensation judge entered an award on the stipulation, and Stevens received benefits until 2011. Stevens began working as a plumbing specialist in 2008 and disclosed his job to S.T. Stevens but continued to receive workers’ compensation benefits. In 2011, S.T. Services filed a petition with the Workers Compensation Court of Appeals (WCCA) to discontinue paying benefits on the grounds that Stevens was no longer permanently totally disabled. A compensation judge granted S.T. Services’ petition to discontinue, and the WCCA affirmed. The Supreme Court reversed, holding that S.T. Services was not allowed by statute to file a petition to discontinue benefits under the circumstances of this case. View "Stevens v. S.T. Servs." on Justia Law

Employee filed an amended complaint seeking indemnity benefits and medical benefits from compensable injuries to his spine. Employee, however, decided not to pursue his indemnity claims at the compensation hearing. The compensation judge found that Respondent had sustained a Gillette injury to his spine and awarded him medical benefits. Employee subsequently sought reimbursement from Employer for attorney fees under Minn. Stat. 176.081. The compensation judge concluded that Employee was entitled to attorney fees under the statute. Employer appealed, arguing that to be eligible for attorney fees, section 176.081 requires an employee to address all related issues at the same time, and so when Employee pursued only a claim for medical benefits, he forfeited his statutory right to all attorney fees. The Supreme Court affirmed, holding that the compensation judge in this case followed the appropriate legal framework in determining the attorney fee award and did not abuse his discretion in the amount awarded. View "Braatz v. Parsons Elec. Co." on Justia Law

After Gordon Brown’s debt to Citizens State Bank Norwood Young America (Bank) became delinquent, Gordon petitioned to dissolve his twenty-three-year marriage to Judy Brown. The Browns executed a marital termination agreement that was incorporated into the marital dissolution decree. Pursuant to the dissolution judgment and decree, Gordon transferred to Judy several assets. When it was unable to collect from Gordon on the original judgment, the Bank brought this action under Minnesota’s Uniform Fraudulent Transfer Act (MUFTA) to levy execution on the assets Gordon transferred to Judy, alleging that the transfers were made with the intent to defraud the Bank. The district court granted summary judgment in favor of the Bank, determining that the transfers were voidable under MUFTA. The court of appeals affirmed. The Supreme Court affirmed the district court’s judgment granting the Bank authority to levy execution on assets fraudulently transferred to the extent necessary to satisfy the Bank’s claim, holding that MUFTA applies to transfers made pursuant to an uncontested marital dissolution decree. View "Citizens State Bank Norwood Young Am. v. Brown" on Justia Law

Defendant was convicted of stalking and violating an order for protection. The district court imposed a sentence for each offense and ordered the two sentences to be served consecutively. The court held that Minn. Stat. 609.035, subd. 1, generally limits the number of sentences a defendant may receive for multiple convictions arising out of a single course of conduct; Minn. Stat. 518B.01, subd. 16, does not create an exception to Minn. Stat. 609.035, subd. 1; if separate sentences are not precluded by Minn. Stat. 609.035, subd. 1, the fact that the convictions involve a single course of conduct does not prevent a district court from imposing permissive consecutive sentences in accordance with Minn. Sent. Guidelines II.F.2.b. In this case, because the court concluded that the district court and the court of appeals erred by conflating two distinct issues - whether separate sentences may be imposed and how separate sentences should be served - the court reversed and remanded with instructions to vacate the sentence imposed for violating an order of protection. View "State v. Jones" on Justia Law

Appellant argued that he is entitled to a new trial because the court found that the judge who presided over his conviction and sentencing failed to reside in her judicial district from July 1, 2009, to September 30, 2009. The court held that Minn. Stat. 351.02(4) does not apply to a district court judge residing in Minnesota but outside her judicial district because a district court judge does not hold a "local" office as that term is used in the statute. Accordingly, because this portion of the statute does not apply to the judge in this case, the court affirmed. View "State v. Irby" on Justia Law

The funds filed suit alleging that, among other things, the pharmacies engaged in fraudulent, misleading, or deceptive practices in connection with the sale of merchandise by failing to pass on the funds the entire difference between the acquisition cost of the generic prescription drug dispensed and its brand name equivalent as required by Minn. Stat. 151.121, subd. 4. The district court granted the pharmacies's Rule 12 motion to dismiss the complaint. The court held that section 151.21, subd. 4 does not create a private cause of action in favor of union-sponsored health and welfare benefit funds against pharmacies for failing to pass on the difference between the acquisition cost of brand name drugs and substituted generic prescription drugs; an omission-based consumer fraud claim is actionable under Minn. Stat. 325F.69, subd. 1 when special circumstances exist that trigger a legal or equitable duty to disclose the omitted facts; the amended complaint did not allege facts that would trigger a legal or equitable duty for the pharmacies to disclose prescription-drug acquisition costs; and, therefore, the complaint failed to state a claim upon which relief can be granted under Minn. Stat. 325F.69, subd. 1. Accordingly, the court affirmed in part and reversed in part. View "Graphic Communications Local 1B, et al. v. CVS Caremark Corp., et al." on Justia Law