Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of first-degree murder of a peace officer, four counts of first-degree assault, and other offenses connected with the shooting death of a county deputy sheriff officer. The Supreme Court reversed one of the first-degree assault convictions but otherwise affirmed, holding (1) the district court did not abuse its discretion when it transferred venue to Polk County; (2) the murder prosecution was not barred by the common law “year-and-a-day rule” because the victim died eighteen months after the shooting, as the year-and-a-day rule does not apply to the Minnesota law of homicide; (3) the district court did not abuse its discretion by admitting into evidence certain photographs; and (4) the evidence was insufficient to support Defendant’s conviction on one of the first-degree assault counts. View "State v. Fairbanks" on Justia Law

Respondent, a criminal defendant, successfully filed a motion to suppress, which the State appealed. The court of appeals reversed the order granting the motion to suppress. Defendant filed a motion for attorney fees, requesting that his attorney receive $120 per hour for 30.3 hours of work performed on the appeal. The State opposed the motion, contending that the court was required to use the rate of $50 an hour set in a standing order of the district court to that portion of the work defense counsel performed after the order was issued. The court of appeals granted the amount Respondent requested. The Supreme Court affirmed, holding that, under the circumstances, the court of appeals did not abuse its discretion in awarding Respondent a consistent hourly rate of $120 per hour for attorney fees and awarding him his full attorney-fee request. View "State v. Williams" on Justia Law

After a jury trial, Appellant was convicted of several offenses, including first-degree felony murder. Appellant subsequently filed several petitions for postconviction relief. This appeal concerned the denial of Appellant’s fourth postconviction petition. Appellant argued that the postconviction court erred in summarily denying Appellant’s fourth postconviction petition as untimely under Minn. Stat. 590.01(4). Appellant contended that the earlier appeal of the denial of his third postconviction petition was a “direct appeal,” and therefore, his fourth postconviction petition was timely filed under section 590.01(4)(a)(2) because the fourth petition was filed within two years of “an appellate court’s disposition of the petitioner’s direct appeal.” The Supreme Court affirmed the summary denial of Appellant’s fourth postconviction petition, holding (1) Appellant’s reliance on section 590.01(4)(a)(2) was misplaced because his earlier appeal of his third postconviction petition was not a direct appeal; and (2) the petition, files, and records conclusively showed that Appellant’s fourth petition was time barred. View "Staunton v. State" on Justia Law

Appellant applied for unemployment benefits after she learned her temporary daytime position would be unavailable after the holiday season. Employer subsequently terminated Appellant from her position. Appellant filed an action against Employer for wrongful discharge, alleging that Employer violated public policy but terminating her employment in retaliation for her application for unemployment benefits. The district court granted summary judgment for Employer and awarded Employer costs and disbursements. The court of appeals affirmed, concluding that although “an employer may be liable for wrongful discharge if it terminates an employment relationship because of the employee’s refusal to violate the law,” Appellant’s claim did not come within the exception to the employment-at-will rule. The Supreme Court affirmed, holding (1) the public policy exception to the employment-at-will rule does not apply to a termination resulting from an employee’s application for unemployment benefits; and (2) the district court does not have discretion to consider a non-prevailing party’s status as an indigent litigant when it awards costs and disbursements to a prevailing party in a civil action. View "Dukowitz v. Hannon Sec. Servs." on Justia Law

Law enforcement officers obtained a warrant to search Appellant and Appellant’s residence after Appellant allegedly threatened a woman for stealing his drugs. At the apartment the officers seized gun and drug evidence. Appellant filed a motion to suppress, which the district court granted on the ground that the search warrant affidavit failed to establish a sufficient nexus between Defendant’s alleged criminal activity and the apartment. The court of appeals reversed. The Supreme Court affirmed, holding that, based on the totality of the circumstances, the search warrant affidavit established a sufficient nexus between Appellant’s alleged criminal activity and the place to be searched. View "State v. Yarbrough" on Justia Law

After the Minnesota Board on Judicial Standards issued a formal complaint against Judge George Perez, a former judge of the Minnesota Tax Court, a three-member fact-finding panel found that Judge Perez had violated the Code of Judicial Conduct and Minnesota law by failing to issue decisions in a timely manner, making false certifications, and making false statements in his decisions. Shortly after the panel issued its findings, the Minnesota Senate refused to confirm Judge Perez’s appointment, thereby immediately ending his judgeship. Both Judge Perez and the Board appealed the panel’s decision. The Supreme Court (1) denied Judge Perez’s motion to dismiss; (2) upheld the panel’s finding that the Board proved that Judge Perez committed misconduct; and (3) concluded that the appropriate discipline was public censure, referral to the Wisconsin Office of Lawyer Regulation, and supervision by the Court of any application for admission to the Minnesota Bar that Judge Perez may file in the future. View "Inquiry into the Conduct of Judge Perez" on Justia Law

Relator was injured while attending a required training session at the general office of her employer. A workers’ compensation judge denied Relator’s claim for benefits, finding that Relator’s injury did not arise out of and in the course of her employment. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that Relator’s injury arose out of the course of her employment, and therefore, her injury was compensable. The Supreme Court reversed and reinstated the decision of the compensation judge, holding that Relator did not meet her burden to prove her injury arose out of her employment, as required by statute. View "Dykhoff v. Xcel Energy" on Justia Law

Appellant pleaded guilty to first-degree driving while impaired (DWI). After receiving a notice advising him of the County’s intent to forfeit his vehicle pursuant to Minn. Stat. 169A.63, Appellant sought a judicial determination of the forfeiture, arguing that he was entitled to a portion of the value of the forfeited vehicle under the motor vehicle exemption, Minn. Stat. 550.37(12)(a). The district court granted summary judgment for the County on behalf of respondent vehicle, holding that the motor vehicle exemption does not apply when a vehicle is forfeited pursuant to section 169A.63. The Supreme Court affirmed, holding that neither the motor vehicle exemption nor Minn. Const. art I, 12 applies to DWI forfeiture pursuant to section 169A.63. View "Nielsen v. 2003 Honda Accord" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder while committing a drive-by shooting for the benefit of a gang. The Supreme Court stayed Appellant’s direct appeal to permit Appellant to file a petition for postconviction relief. The postconviction court subsequently denied relief. The Supreme Court consolidated Appellant’s direct and postconviction appeals into a single proceeding and held (1) the record contained sufficient evidence to support Appellant’s conviction; (2) some of the individual jury instructions in this case were erroneous, but the jury instructions, considered as a whole, did not constitute reversible error; (3) Appellant knowingly and voluntarily waived his right to testify at trial; (4) Appellant was not deprived of his right to the effective assistance of trial counsel; (5) the district court did not abuse its discretion when it denied Appellant’s motion for a mistrial; (6) the jury did not return legally inconsistent verdicts; and (7) the postconviction court did not err when it denied an evidentiary hearing on Appellant’s claim that the district court violated his right to a public trial. View "State v. Bahtuoh" on Justia Law

Respondent brought this action against Appellant, seeking to recover payment for industrial equipment it fabricated for Appellant. Appellant counterclaimed for breach of contract. The district court entered judgment in favor of Respondent. Appellant filed a motion for judgment as a matter of law or a new trial, arguing that the district court erred in granting Respondent's motion for a protective order to preclude the depositions of two out-of-state witnesses from going forward shortly before trial. The district court denied the motion. The Supreme Court reversed, holding (1) the district court abused its discretion by granting Respondent's motion for a protective order because it applied the wrong legal standard in this case; (2) Respondent did not demonstrate good cause to preclude Appellant's depositions of the out-of-state witnesses; and (3) because Appellant was prejudiced by the district court's error, a new trial was warranted. View "TC/Am. Monorail, Inc. v. Custom Conveyor Corp." on Justia Law