Justia Minnesota Supreme Court Opinion Summaries

Lyon filed a breach of contract action against Illinois Paper in federal district court, alleging that Illinois Paper had breached a contractual representation and warranty that all lease transactions presented to Lyon for review would be "valid and fully enforceable agreements." The Seventh Circuit certified questions to the court under Minn. Stat. 480.065. The court reformulated the questions and held that a claim for breach of a contractual representation of future legal compliance is actionable under Minnesota law without proof of reliance. View "Lyon Financial Services, Inc. v. Illinois Paper and Copier Co." on Justia Law

Sinuon and Lawrence Leiendecker, husband and wife, were involved in litigation with Asian Women United of Minnesota (AWUM), a nonprofit organization, for a decade. In this lawsuit, the fifth suit between the parties,the Leiendeckers sought to recover for injuries allegedly inflicted by AWUM and other defendants through the suits the defendants brought against the Leiendeckers in the past. AWUM moved for dismissal under Minnesota’s anti-SLAPP statutes. The district court denied AWUM’s anti-SLAPP motion, concluding that the allegations in the Leiendeckers’ complaint were sufficient to defeat the motion. The Supreme Court reversed, holding that the anti-SLAPP statutes required the Leiendeckers to produce evidence to defeat the anti-SLAPP motion rather than rely solely on the allegations in their complaint. View "Leiendecker v. Asian Women United of Minn." on Justia Law

The Commissioner of Revenue notified JME of Monticello (JME), a waste management service provider, that it intended to audit JME’s waste management returns for a certain period. After the audit, JME was assessed approximately $87,000 in additional solid waste management taxes and interest. The Commissioner reached this determination after concluding that JME improperly calculated its waste management tax based on JME’s incorrect interpretation of Minn. Stat. 297H.04. JME appealed and brought a motion for summary judgment. The tax court upheld the Commissioner’s tax order. The Supreme Court affirmed, holding that the Commissioner correctly interpreted section 297H.04 and had correctly calculated the tax. View "JME of Monticello, Inc. v. Comm’r of Revenue" on Justia Law

After a jury trial in 1992, Appellant was found guilty of two counts of first-degree murder and two counts of attempted first-degree murder. Appellant was fifteen years old at the time. Under a mandatory sentencing scheme, the district court imposed life sentences with the possibility of release after thirty years for the first-degree murder convictions. After the United States Supreme Court decided Miller v. Alabama in 2012, Appellant filed a postconviction motion to correct his sentence, arguing that his sentence violated the rule announced in Miller. The postconviction court denied the motion, concluding that Appellant’s sentence was lawful because Miller was not retroactive. The Supreme Court affirmed without reaching the issue of Miller’s retroactivity, holding that Miller did not make the sentencing scheme at issue here unlawful because the mandatory sentencing scheme did not require life imprisonment without the possibility of release. View "Ouk v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder and sentenced to a term of life imprisonment. The Supreme Court affirmed on appeal. After Appellant’s first petition for postconviction relief was denied, Appellant filed the petition for postconviction relief at issue in this appeal. Defendant requested an evidentiary hearing and court-appointed counsel to assist with his petition. The postconviction court denied Appellant’s requests and summarily denied the petition, concluding that the petition was procedurally barred. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion denying the petition without appointing counsel and without holding an evidentiary hearing. View "Hughes v. State" on Justia Law

After she was arrested for driving while impaired, Driver took a urine test, which revealed an alcohol concentration of twice the legal limit. Pursuant to the state’s implied consent law, Driver’s license was revoked. Driver sought judicial review, arguing that her license should not have been revoked because she acted out of necessity to protect herself from her violent husband. After an implied consent hearing, the district court upheld the revocation, concluding that necessity is not an affirmative defense that drivers may raise to challenge a civil license revocation. The Supreme Court affirmed, holding that the plain language of Minn. Stat. 169A.53(3) does not permit a driver to raise the affirmative defense of necessity at an implied consent hearing. View "Axelberg v. Comm’r of Pub. Safety" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed Appellant’s conviction, holding (1) Appellant’s constitutional challenges to the first-degree premeditated murder statute were procedurally barred; (2) sufficient evidence supported Appellant’s conviction; (3) trial court did not err in instructing the jury on premeditation; (4) any error in allowing Appellant’s former wife to testify did not prejudice Appellant; and (5) any error in the admission of hearsay statements from certain witnesses under the residual hearsay exception was harmless. View "State v. Moore" on Justia Law

The State filed a delinquency petition charging Appellant, who was then fourteen years old, with first-degree felony murder (drive-by shooting), second-degree felony murder (drive-by shooting), and attempted first-degree felony murder (drive-by shooting). Defendant pled guilty to the murder charges, but the Supreme Court vacated the convictions. On remand, the case proceeded to trial, and a jury found Appellant guilty of all three counts. The Supreme Court affirmed, holding (1) the district court had original and exclusive jurisdiction over Appellant’s offenses; (2) sufficient evidence supported Appellant’s convictions; (3) assuming that the district court improperly instructed the jury on the elements of drive-by shooting, Appellant did not establish that the error affected his substantial rights; (4) Appellant’s mandatory life sentence with the possibility of release was not unconstitutional under the principles of Miller v. Alabama; (5) the district court did not abuse its discretion by imposing a longer sentence upon Appellant after his trial and conviction; and (6) the postconviction court did not err when it summarily denied Appellant’s petition for postconviction relief. View "State v. Vang" on Justia Law

James Bergstrom and Vanessa Rew dissolved their marriage in 2008. In 2002, 2007, and 2008, Rew obtained a series of one-year orders for protection (OFPs) against Bergstrom. In 2010, before the extended expiration date of the 2008 OFP, Rew filed an application under Minn. Stat. 518B.01(6)(a) to extend the terms of the 2008 OFP. After an evidentiary hearing, the district court extended the OFP for up to fifty years in favor of Rew and the couple’s minor children. The Supreme Court affirmed in part and reversed in part, holding (1) section 518B.01(6)(a) does not require a finding of domestic abuse before a district court may extend the duration of an OFP; (2) the extension of an OFP under section 518B.01(6)(a) does not facially violate the First Amendment to the United States Constitution or Minn. Const. art. I, 3; (3) the record was insufficient to conclude that the extended OFP was constitutional with respect to Bergstrom’s children; and (4) the extension of an OFP for up to fifty years does not implicate the prohibition against double jeopardy or the Ex Post Facto Clause of either the United States of Minnesota Constitutions. Remanded. View "In re Rew" on Justia Law

In 2010, the State retained Covington & Burling, LLP (“Covington”) to represent it in a natural resource damages case against 3M Company (“3M”) involving the manufacture and disposal of perfluorochemicals, which are a subset of all fluorochemicals. In 2012, 3M moved to disqualify Covington as counsel for the State because Covington had previously represented 3M in legal and regulatory matters related to 3M’s fluorochemicals business from 1992 to 2006. The district court granted 3M’s disqualification motion. Both the State and Covington appealed. The court of appeals dismissed Covington’s appeal for lack of standing and affirmed the disqualification of Covington. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) an attorney has standing to appeal when a district court finds that the attorney violated the rules of professional conduct and disqualifies the attorney from the representation, and therefore, Covington had standing to appeal the disqualification order; (2) the district failed to use the proper legal standard in disqualifying Covington under Minn. R. Prof. Conduct 1.9(a); and (3) remand was required to permit the district court to make the necessary factual findings and determine whether 3M waived the right to seek disqualification of Covington. View "State v. 3M Co." on Justia Law