Justia Minnesota Supreme Court Opinion Summaries

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

Interstate Traffic Signs, Inc. (“Interstate”) rented traffic control equipment to contractors working on road construction projects. Prior to April 2010, Interstate charged sales tax on the equipment rental charge but did not charge tax on its delivery and “pick-up” charges, which included costs associated with retrieving and returning the rental equipment to Interstate. Beginning in April 2010, Interstate charged sales tax on the delivery charges but did not charge tax on pick-up charges. After an audit, the Commissioner of Revenue assessed an additional $37,838 in sales and use tax, determining that Interstate should have been charging sales tax on its pick-up charges. The tax court upheld the Commissioner’s assessment, concluding that the pick-up charge was subject to sales tax pursuant to Minn. Stat. 297A.62(1). The Supreme Court affirmed, holding that pick-up charges fall within the definition of “sales price” under section Minn. Stat. 297A.61(7), making those charges subject to sales tax under section 297A.62(1). View "Interstate Traffic Signs, Inc. v. Comm’r of Revenue" on Justia Law

One day before Appellant was scheduled to be released from prison, where he served a sentenced imposed following a guilty plea to third-degree criminal sexual conduct, Sibley County filed a petition to have Appellant civilly committed as a sexually dangerous person. After a commitment hearing, the district court concluded that clear and convincing evidence demonstrated that Appellant met the statutory requirements for commitment as a sexually dangerous person. The court of appeals affirmed. The Supreme Court reversed, holding (1) the risk of harmful sexual conduct occurring must be “highly likely” based on consideration of the factors set forth in In re Linehan and all relevant evidence; and (2) because it could not be determined whether the district court adhered to the Linehan factors after considering the other evidence, reconsideration of the unique and specific facts of Appellant’s case was warranted. View "In re Civil Commitment of Ince" on Justia Law

In 2001, Respondent was found guilty of first-degree murder while committing or attempting to commit criminal sexual conduct and first-degree premeditated murder. Respondent was a juvenile when he committed the crime. The district court sentenced Respondent to life without the possibility of release (LWOR) under the mandatory sentencing scheme in Minn. Stat. 609.106(2)(1). After the U.S. Supreme Court decided Miller v. Alabama in 2012, Respondent filed a petition for postconviction relief, arguing that his sentence violated the Eighth Amendment. The postconviction court granted Respondent’s petition and resentenced him to life in prison with the possibility of release after thirty years. The Minnesota Supreme Court subsequently issued its decision in Chambers v. State, which held that the Miller rule does not apply retroactively to a juvenile whose sentence of LWOR under section 609.106(2)(1) became final before the Miller rule was announced. Thereafter, in the instant case, the Supreme Court reversed the postconviction court’s order and reinstated the original sentence of LWOR, holding that the postconviction court’s legal conclusion was in direct conflict with Chambers, and the circumstances of this case did not warrant granting relief to Respondent under the Court’s supervisory powers to ensure the fair administration of justice. View "Roman Nose v. State" on Justia Law

Plaintiff applied for a job within the Mounds View Police Department, which commenced a background investigation. Mounds View contacted the Minneapolis Police Department, where Plaintiff previously worked, and interviewed Sergeant Janice Callaway, one of Plaintiff’s former supervisors, who allegedly made defamatory statements about Plaintiff. Plaintiff subsequently sued Callaway and the City of Minneapolis for intentional interference with prospective economic advantage and for defamation. The district court granted Defendants’ motion for summary judgment with respect to the intentional interference claim but allowed the defamation claim to proceed. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not err in denying summary judgment on the defamation claim, as absolute privilege did not apply to the allegedly defamatory statements made by Callaway. View "Minke v. City of Minneapolis" on Justia Law

In 2005, Paul Alan Brandon, a church volunteer who was an ordained Assemblies of God minister, sexually abused Plaintiff. In 2011, Plaintiff filed a negligence action against the Minnesota District Council of the Assemblies of God (“District Council”) because it recommended the renewal of the ministerial credentials of Brandon. The district court granted summary judgment in favor of the District Council on the negligence claim, concluding that the District Council did not owe Plaintiff a duty of care. The court of appeals reversed, determining that there was sufficient evidence for a jury to conclude that the District Council’s conduct created a foreseeable risk of injury to a foreseeable plaintiff, and thus, under Domagala v. Rolland, the District Council owed Plaintiff a duty of care, even in the absence of a special relationship. The Supreme Court reversed, holding, as a matter of law, that the District Council had no duty to Plaintiff, as there was no special relationship between the District Council, and Plaintiff and the District Council did not create a foreseeable risk of injury to a foreseeable plaintiff. View "Doe v. Brandon" on Justia Law

B.A.H. was charged with first-degree criminal sexual conduct under Minn. Stat. 609.342(1)(g) for acts he committed with his cousin, then age thirteen, when B.A.H. was age fourteen. After a bench trial on stipulated evidence, the district court found B.A.H. guilty of the charge and adjudicated him delinquent. The court of appeals reversed, holding that subdivision (1)(g) violated B.A.H.’s constitutional rights to due process and equal protection. The Supreme Court reversed, holding that B.A.H.’s deliquency adjudication did not violate his constitutional rights to due process and equal protection, as (1) subdivision (1)(g) was not unconstitutionally vague; and (2) the State’s reasons for charging B.A.H. and not his cousin were rational, and therefore, constitutional. View "In re Welfare of B.A.H." on Justia Law

Plaintiffs, owners of a dairy farm, sued Wright-Hennepin Cooperative Electric Association for stray voltage that allegedly injured their herd of dairy cows. The jury found that Wright-Hennepin had been negligent, had created a nuisance, and had trespassed and returned a special verdict awarding Plaintiffs $753,200 in damages. Wright-Hennepin moved, post-trial, that the district court issue supplemental findings itemizing the $753,200 judgment. The district court granted the motion. The court of appeals affirmed in part, reversed in part, and remanded for a new trial on the issue of damages, determining that the district court lacked authority to amend the judgment to itemize the jury’s damages award. The Supreme Court affirmed, holding that the district court had no authority, by rule or by inherent power, to amend the judgment to itemize the jury’s damages award. View "Poppler v. Wright Hennepin Coop. Elec. Ass’n" on Justia Law