Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of criminal vehicular homicide for causing the death of ninety-three-year-old Edith Schouveller in a motor vehicle accident. The accident occurred on March 28, 2010. Schouveller was transported to the hospital with several life-threatening injuries. For the next twenty-two days, Schouveller was either hospitalized or in a nursing home. Schouveller developed lung problems while in the hospital, which led to pneumonia. On April 19, 2010, Schouveller experienced acute respiratory failure. Doctors determined that she needed to be placed on a respirator in order to continue to live, but relying on Schouveller's living will, the doctors declined to place her on respiratory support. Schouveller died that evening. The Supreme Court affirmed Defendant's conviction, holding (1) the district court properly instructed the jury on causation; (2) the State presented sufficient evidence to demonstrate a causal chain between the injuries Shouveller sustained in the accident and the pneumonia and aspiration that ultimately led to her death; and (3) the evidence was sufficient for the jury to conclude that the do-not-resuscitate order in Souveller's living will was not a superseding cause of her death. View "State v. Smith" on Justia Law

Appellants, approximately 750 employees, brought a class action against their employers (Employers), alleging five causes of action, including unlawful deductions made in violation of Minn. Stat. 181.79. The jury found Employers did not violate section 181.79. After the verdict, Appellants unsuccessfully requested judgment as a matter of law (JMOL) on their section 181.79 claim. The Supreme Court reversed, holding that Appellants were entitled to JMOL on their claim under section 181.79, as there was no legally sufficient basis for a reasonable jury to find that Employers did not make unlawful deductions from Appellants' wages in violation of section 181.79. Remanded with instructions to enter JMOL in favor of Appellants on liability for their section 181.79 claim.View "Karl v. Uptown Drink, LLC" on Justia Law

A snowplow driver for the City of Alexandria collided with Donald Fernow's vehicle. Fernow brought a personal injury action against the City. At the same time, Fernow's insurance company (Insurer) sought arbitration against the City, seeking repayment in basic economic loss benefits paid to Fernow. In the personal injury action, the district court denied the City's motion for summary judgment on the basis that Fernow's claim was barred by statutory discretionary immunity, common law official immunity, and statutory snow and ice immunity. The court of appeals affirmed. Meanwhile, the arbitrator awarded Insurer basic economic loss benefits, concluding that the defense of governmental statutory immunity did not apply to the matter because of the denial of the City's motion for summary judgment. The district court confirmed the award. The court of appeals reversed, concluding that the arbitrator exceeded her authority when she determined that the defense of governmental statutory immunity did not apply to the matter. The Supreme Court affirmed on different grounds, holding that claims of immunity, including necessary questions of fact, should be determined by the district court prior to arbitration on the merits under the Minnesota No-Fault Automobile Insurance Act. Remanded.View "Fernow v. Gould" on Justia Law

After Scott Schuette, who was working as a police officer at the time, responded to an accident at the local high school he began experiencing mental health problems. Schuette was later diagnosed with post-traumatic stress disorder (PTSD). Schuette filed a claim petition seeking workers’ compensation benefits for PTSD. A compensation judge denied Schuette’s claim, finding that Schuette’s PTSD lacked a physical component and was thus not a compensable injury under Minnesota law. The Workers’ Compensation Court of Appeals (WCCA) affirmed, determining (1) to be compensable under Lockwood v. Independent School District No. 877, an injury must include a physical component; and (2) the compensation judge’s findings that Schuette’s PTSD did not result in a physical brain injury had substantial evidentiary support. The Supreme Court affirmed, holding (1) the compensation judge’s findings were not manifestly contrary to the evidence; and (2) applying the doctrine of stare decisis, Schuette’s request to overrule Lockwood was declined. View "Schuette v. City of Hutchinson" on Justia Law

Defendant was convicted of murder in the first degree while committing domestic abuse and with a past pattern of domestic abuse. Defendant subsequently filed a petition for postconviction relief, arguing, among other things, that there was insufficient evidence to establish a past pattern of domestic abuse beyond a reasonable doubt. After an evidentiary hearing, the postconviction court denied the petition. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury’s finding that Defendant engaged in a past pattern of domestic abuse against the victim; (2) the district court did not err in its jury instructions on a past pattern of domestic abuse; and (3) the district court did not commit plain error by admitting evidence connected to orders for protection obtained by the victim, as Appellant’s substantial rights were not affected by the admission of this evidence. View "Gulbertson v. State" on Justia Law

Law enforcement officers stopped a truck driven by Thomas Anthony, a suspected drug dealer. Charles Lemert was a passenger in Anthony’s car. Officers ordered Lemert to get out of the truck and proceeded to conduct a pat search of Lemert. Based on the evidence discovered during the pat search, the State charged Lemert with a fifth-degree controlled-substance offense. Lemert moved to suppress the evidence, arguing that the search was unlawful because the officers lacked a reasonable, articulable suspicion that Lemert might have been armed and dangerous. The district court denied the motion and convicted Lemert of the charge. The court of appeals affirmed. The Supreme Court affirmed, holding that, under the circumstances, the officers had a reasonable, articulable suspicion that Lemert might have been armed and dangerous, and therefore, the district court did not err when it denied Lemert’s motion to suppress. View "State v. Lemert" on Justia Law

After a jury trial in 1994, Defendant was convicted of first-degree murder and sentenced to life in prison with the possibility of release. Seven months later, Defendant pleaded guilty to second-degree attempted murder. The court sentenced Defendant to an additional seventy-two months in prison to run consecutively to his life sentence. In 2012, Defendant filed a pro se motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The district court treated the motion as a petition for postconviction relief and then denied the motion on the grounds it was time barred and procedurally barred. The Supreme Court affirmed, holding that even if Defendant's motion was not time barred or procedurally, barred, his argument that the overall length of his imprisonment should be reduced failed on the merits.View "Townsend v. State" on Justia Law

After Washington County assessed the value of one of properties owned by Kohl's Department Stores for the years 2007-2009, Kohl's challenged the valuation. The tax court adjusted the County's assessment by increasing the valuations for 2007 and 2008 and decreasing the valuation for 2009. The Supreme Court affirmed, holding the tax court not err (1) by failing to adjust its capitalization rate to account for the property taxes paid by the owner on vacant space and for the neighborhood's excessive vacancy; and (2) when it calculated the property's fair market rent using comparable leases rather than a percentage of retail sales method. View "Kohl's Dep't Stores, Inc. v. County of Washington" on Justia Law

The Commissioner of Revenue informed Sharon Soyka by a notice that it would file a tax return on her behalf for the 2008 tax year and asserting that Soyka owed $2,201 in income taxes, interest, and penalties. Exactly sixty-one days after the Commissioner mailed the notice, Soyka mailed her notice of appeal to the Minnesota Tax Court. The tax court dismissed Soyka’s appeal, concluding that it was untimely under Minn. Stat. 271.06(2), which generally requires a notice of appeal to be filed within sixty days after notice of an order by the Commissioner. At issue before the Supreme Court was whether, when the Commissioner serves notice of an order by United States mail, Minn. R. Civ. P. 6.05 extends the sixty-day statutory deadline for filing an appeal with the tax court. The Supreme Court reversed and directed the tax court to reinstate Soyka’s appeal, holding that Rule 6.05 applies and extends the statutory filing deadline by three days when the Commissioner serves the notice by United States mail. View "Soyka v. Comm’r of Revenue" on Justia Law

Respondent was injured when Hennepin County Sheriff’s Deputy Jason Lee Majeski’s emergency vehicle struck Respondent’s vehicle as Majeski was responding to an emergency call. Respondent commenced a personal injury lawsuit against Majeski and Hennepin County, alleging negligence by Majeski and vicarious liability on the part of the County. The district court held that because Majeski was responding to an emergency at the time of the accident, Majeski’s conduct was protected by official immunity as a matter of law, and accordingly, the County was protected by vicarious official immunity. The court of appeals reversed and remanded for trial, concluding that a jury must determine whether Majeski proceeded cautiously through the intersection as required by public safety. The Supreme Court reversed, holding (1) Majeski did not, as a matter of law, violate a ministerial duty in his conduct while traveling through the intersection, and Majeski’s conduct was not willful or malicious; and (2) therefore, Majeski was entitled to official immunity and the County was entitled to vicarious official immunity. Remanded. View "Vassallo v. Majeski" on Justia Law