Justia Minnesota Supreme Court Opinion Summaries

Skyline Materials applied for a variance from the setback requirements of Houston County's zoning ordinance. The County granted the variance. Respondents, owners of property that was adjacent to the property owned by Skyline, sought to exercise their statutory right of appeal. The parties, however, disagreed as to the proper method of service. The district court concluded that Minn. R. Civ. P. 5.02, rather than Minn. R. Civ. P. 4.03, controlled, and therefore, the court had jurisdiction over Respondents' appeal. The Supreme Court reversed, holding that Respondents were required to effect service pursuant to Rule 4.03, and because they did not do so, the district court lacked jurisdiction to hear their appeal. Remanded for dismissal. View "In re Application of Skyline Materials, Ltd. for Zoning Variance" on Justia Law

Defendant, who was HIV positive, engaged in consensual anal intercourse. Defendant was subsequently charged with attempted first-degree assault by transferring a communicable disease for violating Minn. Stat. 609.2241(2). A jury found Defendant violated section 609.2241(2)(2), which applies to the "transfer of blood, sperm, organs, or tissue." The court of appeals reversed the conviction, concluding that section subdivision 2(2) applies only to medical procedures instead of applying to acts of sexual conduct. The Supreme Court affirmed, holding (1) subdivision 2(2) applies only to the donation or exchange for value of blood, sperm, organs, or tissue; and (2) because Defendant's conduct indisputably did not involve the donation or exchange for value of his sperm, subdivision 2(2) was inapplicable to Defendant's conduct.View "State v. Rick" on Justia Law

In 1986, the City of Duluth and the Fond du Lac Band of Lake Superior Chippewa (the Band) entered into several agreements establishing a joint venture to operate gaming activities in Duluth. The agreements required that the Band seek approval before creating any additional Indian Country. In 1994, the Band and the City created a series of new agreements and amendments to the 1986 agreements. In 2010, the Band acquired a plot of land. The Band sought to have the plot placed in trust but did not seek the City’s approval to do so, as required by the 1986 agreements. The City commenced this action in state district court seeking a court order requiring the Band to withdraw its trust application. The district court dismissed the lawsuit, concluding that it lacked subject matter jurisdiction because the Band had only consented to suit in federal court in the 1994 agreements. The court of appeals reversed. The Supreme Court reversed the court of appeals’ decision and reinstated the district court’s judgment for the Band, holding that the Court lacked jurisdiction to decide the issue of whether the Band breached the 1986 agreements because it required interpretation of the 1994 agreements, which was a matter vested in the federal courts. View "City of Duluth v. Fond du Lac Band of Lake Superior Chippewa" on Justia Law

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