Justia Minnesota Supreme Court Opinion Summaries

The State charged Respondents with first-degree burglary under Minn. Stat. 609.582 for breaking into a home and allegedly stealing a locked safe that contained a handgun. The district court dismissed the first-degree burglary charges for lack of probable cause, concluding that section 609.582(1)(b), which requires possession of a dangerous weapon during the burglary, requires knowing possession of a dangerous weapon during the burglary. The Supreme Court reversed, holding (1) section 609.582(1)(b) does not include a mens rea requirement with respect to a defendant’s possession of a dangerous weapon; and (2) therefore, the district court erred in reading an additional knowledge requirement into the statute. View "State v. Garcia-Gutierrez" on Justia Law

The Minnesota Laborers Health and Welfare Fund (“the Funds”) filed a declaratory judgment action against Granite Re, Inc. seeking clarification of their right to payment on a surety bond. The district court granted summary judgment to Granite Re, concluding, among other things, that the Funds’ lawsuit was time-barred because the Funds failed to commence litigation within the one-year contractual limitations period set out in the bond. The court of appeals reversed and remanded, concluding that fraudulent concealment by the bond principal tolled the limitations period set out in the bond. The Supreme Court affirmed, holding (1) fraudulent concealment can be applied to a surety that was not involved in the fraudulent concealment by the principal; and (2) therefore, the one-year contractual limitations period set out in the bond may be tolled against Granite Re. View "Minn. Laborers Health & Welfare Fund v. Granite Re, Inc." on Justia Law

Appellant entered into a mortgage with Aegis Lending Corporation. The mortgage was later assigned to Pacifica L. Ninteen, and the servicing rights were eventually transferred to Vantium Capital, Inc. (“Acqura”). After foreclosure proceedings were commenced against Appellant, Appellant filed suit against Acqura, alleging numerous state law claims. Specifically, Appellant claimed that Acqura’s violated its Servicer Participation Agreement with Fannie Mae by failing to follow guidelines applicable under the federal Home Affordable Modification Program. The district court dismissed the lawsuit, holding that Minn. Stat. 58.18(1) did not provide a private cause of action for Appellant to pursue damages for Acqura’s alleged violation of its agreement with Fannie Mae and that Appellant therefore lacked standing. The court of appeals affirmed. The Supreme Court reversed, holding that section 58.18(1) provides for a private right of action and therefore gave Appellant standing to pursue her claim. View "Gretsch v. Vantium Capital, Inc." on Justia Law

After a jury trial, Defendant was found guilty of felony failure to pay child support. After Defendant filed his notice of appeal, the district court issued a warrant for Defendant’s arrest because Defendant failed to appear for a hearing on an alleged probation violation. The State moved to dismiss Defendant’s appeal on the ground that he was a fugitive who had forfeited his right to an appeal. The court of appeals denied the motion on the grounds that Minnesota has not yet adopted the fugitive-dismissal rule. On review, the Supreme Court adopted the fugitive-dismissal rule, holding that appellate courts have the discretion to dismiss an appeal brought by a fugitive. The Court then reversed and directed the court of appeals to dismiss Defendant’s appeal if he did not surrender within ten days, holding that Defendant was a fugitive and his status as a fugitive granted an appellate court the discretionary authority to dismiss his appeal. View "State v. Hentges" on Justia Law

Appellant Ronald Greer sought post-conviction relief from his murder conviction. The trial court denied relief, and he appealed that denial to the Supreme Court. Finding that the trial court did not abuse its discretion in denying Greer's petitions for relief, the Supreme Court affirmed. View "Greer v. Minnesota" on Justia Law

John Gieseke, on behalf of Diversified Water Diversion, Inc., filed a complaint against IDCA, Inc., asserting claims for, inter alia, tortious interference with Diversified’s prospective economic advantage. The district court found for Diversified on the tortious interference claim and awarded $220,000 in damages. IDCA filed motions for judgment as a matter of law and for a new trial or remittitur, asserting (1) Minnesota does not recognize a cause of action for tortious interference with a prospective economic advantage; (2) even if such a tort were available, Diversified failed to show a reasonable expectation of economic advantage; and (3) the damages awarded in this case were excessive. The district court denied the post-trial motions. The court of appeals affirmed. The Supreme Court reversed and vacated the judgment on the tortious interference claim, holding (1) tortious interference with prospective economic advantage is a viable claim in Minnesota; but (2) Diversified’s claim failed as a matter of law because Diversified failed to specifically identify any third parties with whom it had a reasonable expectation of a future economic relationship and failed to prove damages caused by the wrongful interference with such a relationship. Remanded. View "Gieseke, on behalf of Diversified Water Diversion, Inc., v. IDCA, Inc." on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree premeditated murder, two counts of first-degree felony murder, and three counts of first-degree aggravated robbery. The Supreme Court affirmed Appellant's convictions, holding that the district court did not err by (1) overruling Defendant's Batson objection to the State's peremptory challenge of an African-American prospective juror, as Defendant failed to prove that the challenge constituted purposeful racial discrimination; and (2) admitting evidence that Defendant assaulted and threatened a witness two days before trial to prove consciousness of guilt, as the district court correctly weighed the probative value of the evidence against the danger of unfair prejudice and provided safeguards to ensure the evidence would not unduly influence the jury's verdict.View "State v. Diggins" on Justia Law

Mark Hilde hired Big Lake Lumber (Big Lake), Wruck Excavating (Wruck), and J. DesMarais Construction (DesMarais) to help him build a "spec home." 21st Century Bank (Bank) recorded a mortgage against the property to finance the purchase of the property and the home construction. After the Bank foreclosed on its mortgage, Big Lake commenced this mechanic's lien foreclosure action. The district court found that the mechanic's liens of Big Lake and DesMarais related back to the date Wruck commenced work on the improvement project, and thus, the mechanic's liens of Big Lake and DesMarais had priority over the mortgage of the Bank. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred by adopting and then applying a new "integrated analysis" to find the Bank's mortgage superior to the liens; and (2) the district court did not clearly err when it found that Wruck, Big Lake, and DesMarais contributed to the same project of improvement, and accordingly, under the relation-back doctrine, the mechanic's liens of Big Lake and DesMarais had priority over the Bank's mortgage.View "Big Lake Lumber, Inc. v. Sec. Prop. Invs., Inc." on Justia Law

Respondent was charged by juvenile petition, as both a principal and an accomplice, with criminal sexual conduct and other crimes arising out of the rape of a fourteen-year-old girl. After a hearing, the juvenile court concluded that Respondent had not overcome the presumption in favor of certification to adult court and certified Respondent for prosecution as an adult. The court of appeals reversed, concluding that the juvenile court abused its discretion by failing to expressly weigh the seriousness of the alleged offense and Respondent’s prior record of delinquency separate from other public safety factors and by failing to specifically delineate how its determination of the two factors impacted its certification decision, as required by Minn. Stat. 260B.125. The Supreme Court reversed, holding (1) the court of appeals erroneously interpreted section 260B.125(4); and (2) the juvenile court did not abuse its discretion by concluding that Respondent failed to overcome the presumption in favor of certification. View "In re Welfare of J.H." on Justia Law

Defendant was convicted of two counts of aiding suicide in violation of Minn. Stat. 609.215(1), which makes it illegal to intentionally “advise, encourage, or assist another in taking the other’s own life.” Defendant had responded to posts on suicide websites by encouraging the victims to hang themselves, falsely claiming that he would also commit suicide. Defendant appealed, arguing that section 609.215(1) violated the First Amendment. The court of appeals affirmed, holding that the statute prohibited speech that was unprotected by the First Amendment. The Supreme Court reversed, holding (1) the State may prosecute Defendant for assisting another in committing suicide but not for encouraging or advising another to commit suicide, and thus the words “advises” and “encourages” must be severed from the statute as unconstitutional; and (2) because the district court did not make a specific finding on whether Defendant assisted the victims’ suicides, the case must be remanded. View "State v. Melchert-Dinkel" on Justia Law