Justia Minnesota Supreme Court Opinion Summaries

In 1988, Appellant pleaded guilty to first-degree murder and attempted first-degree murder. Appellant was sentenced to consecutive terms of life in prison and 130 months. This appeal concerned Appellant’s fifth postconviction petition, in which Appellant claimed that his guilty pleas were not knowing, voluntary, and intelligent. Appellant filed the petition after expiration of the postconviction statute of limitations under Minn. Stat. 590.01(4)(a). The postconviction court summarily denied Appellant’s petition as time-barred. Appellant appealed, arguing that his claim was not time-barred because it satisfied three of the exceptions to the statute of limitations. The Supreme Court affirmed, holding that Appellant’s claim failed to satisfy any of the exceptions to the postconviction statute of limitations under section 590.01(4)(b), and therefore, Appellant's fifth request for postconviction relief was time-barred. View "Brown v. State" on Justia Law

This case arose from a dispute over a construction contract entered into between Contractors Edge, Inc. and the City of Mankato. Contractors Edge sued the City alleging, as relevant to this appeal, breach of contract and violation of the Prompt Payment Act. The district court dismissed the breach of contract claim in an order (the October 2012 order) that concluded, “let judgment be entered accordingly.” Neither party asked for a certification of final judgment under Minn. R. Civ. P. 54.02. The parties subsequently settled the remaining Prompt Payment Act claim. The district court entered final judgment in January 2014. Contractors Edge appealed, challenging the October 2012 order. The court of appeals dismissed the appeal as time barred, holding (1) regardless of whether the district court properly certified the October 2012 order, the partial judgment was immediately appealable, and (2) Contractors Edge’s appeal time had expired. The Supreme Court reversed, holding (1) the district court abused its discretion in certifying the October 2012 order as a final partial judgment under Rule 54.02; and (2) when a district court abuses the discretion given in Rule 54.02 to certify an order as a final partial judgment, the resulting judgment is not final and is not immediately appealable. View "Contractors Edge, Inc. v. City of Mankato" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, one count of attempted first-degree murder, and one count of burglary. Appellant committed the offenses when he was sixteen years old. The district court imposed a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction. Defendant’s convictions were affirmed on direct appeal. Nineteen years later, Appellant moved to correct his sentence based on the rule announced in Miller v. Alabama. Specifically, Appellant argued that the rule announced in Miller should be extended to statutory provisions that mandate the imposition of life imprisonment with the possibility of release and should apply to a district court’s discretionary imposition of consecutive sentences that are the functional equivalent of life imprisonment without the possibility of release. The postconviction court denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court’s decision was consistent with the Court’s recent rulings, and its ruling was a sound exercise of its discretion. View "State v. Williams" on Justia Law

Appellant was convicted of two counts of criminal sexual conduct arising from separate behavioral incidents with separate victims. The district court concluded that Appellant was not subject to lifetime conditional release under Minn. Stat. 609.3455(7)(b) because the two convictions were entered at the same hearing, and therefore, Defendant under not have a “prior sex offense conviction” under section 609.344(1)(g). The Supreme Court reversed, holding that Defendant was subject to lifetime conditional release because the definition of “prior sex offense conviction” unambiguously includes a conviction for a separate behavioral incident entered before a second conviction, whether at different hearings or during the same hearing. Remanded. View "State v. Nodes" on Justia Law

Defendant was convicted of three counts of murder in connection with the death of his two-year-old niece. While Defendant’s appeal was pending, new evidence was identified. The State then sought, and a grand jury returned, an amended indictment for five counts of murder. After a new trial, Defendant was convicted of five counts of murder. The Supreme Court reversed, holding that the district court (1) did not err when it seated jurors who knew about Defendant’s first conviction; but (2) abused its discretion when it allowed a juror who exhibited actual bias against Defendant and was not adequately rehabilitated to sit in judgment of Defendant. Remanded for a new trial. View "State v. Fraga" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder and first-degree felony murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree premeditated murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress statements he made to police; (2) the district court did not abuse its discretion when it declined to give Appellant’s requested jury instruction on circumstantial evidence; and (3) the evidence was sufficient to support Appellant’s murder convictions. View "State v. Fox" on Justia Law

After a jury trial, Appellant was found guilty of failing to register as a predatory offender. The district court imposed a presumptive sentence of sixteen months imprisonment and a ten-year conditional-release term under Minn. Stat. 422.052(3). The court imposed the conditional-release term based on a previous finding by an administrative committee of the Department of Corrections that had assessed Appellant as a high-risk, level-III offender. Several years later, Appellant moved to correct his sentence, arguing that a jury, not the judge, was constitutionally required to make the finding regarding his risk-level status. The district court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court reversed and vacated Appellant’s ten-year conditional-release term, holding that Appellant had the right to have a jury determine whether he was a risk-level-III offender at the time of his offense. View "State v. Her" on Justia Law

Appellant pleaded guilty to one count of third-degree sale of a narcotic drug and was sentenced to fifteen months’ imprisonment. Appellant later sought postconviction relief seeking to withdraw his guilty plea for lack of an adequate factual basis. Specifically, Appellant argued that because the factual basis for his plea was his admission that he gave cocaine to his wife to hide when police officers pulled over the car in which he was a passenger, his testimony at the plea hearing did not support his conviction for a “sale” because he did not admit that he relinquished possession of the controlled substance. The postconviction court denied Appellant’s petition, concluding that the statutory definition of “sell” requires only a physical transfer of the possession of the contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) the facts to which Defendant admitted during his guilty plea colloquy did not show that his conduct fell within the definition of “sell” in Minn. Stat. 152.01(15a)(1); and (2) because there was not a sufficient factual basis for Appellant’s plea, his motion to withdraw his guilty plea should be granted. View "Barrow v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree criminal sexual conduct and first-degree aggravated robbery in exchange for the State dismissing several charges. Defendant agreed to receive a sentence that was an upward durational departure. The district court sentenced Defendant according to the terms of the plea agreement. Defendant later filed a requested relief under Minn. R. Crim. P. 27.03(9), arguing that the court had impermissibly sentenced him. The district court denied relief. The court of appeals affirmed, concluding that Defendant could not challenge his sentence in a motion to correct his sentence. The Supreme Court affirmed, holding (1) because Defendant’s challenge to his sentence implicated more than simply his sentence, it is properly viewed as a petition for postconviction relief under Minn. Stat. 590.01, not as a motion to correct a sentence under Rule 27.03; and (2) Defendant’s request is time-barred by section 590.01(4)(a). View "State v. Coles" on Justia Law

A reporter from the Star Tribune submitted a request for data to the Minnesota Joint Underwriting Association (MJUA), an entity created by the Legislature to provide insurance for people or entitled who are required to have insurance and are unable to obtain insurance through ordinary methods. MJUA sought a written advisory opinion from the Commissioner of the Department of Administration as to whether MJUA was a state agency subject to the Minnesota Government Data Practices Act (MGDPA). The Commissioner declined to issue an advisory opinion. MJUA then commenced a lawsuit for declaratory relief seeking a declaration that it was not a governmental agency subject to the MGDPA. The district court granted the Star Tribune’s motion for partial judgment on the pleadings and ordered MJUA to comply with the MGDPA, concluding that MJUA is a state agency. The court of appeals reversed in part, holding that MJUA is not a governmental entity subject to the MGDPA. The Supreme Court affirmed, holding that MJUA is not a state agency subject to the MGDPA. View "Minn. Joint Underwriting Ass’n v. Star Tribune Media Co." on Justia Law