Justia Minnesota Supreme Court Opinion Summaries

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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

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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

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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

Posted in: Injury Law
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Appellant was convicted of felony-level failure to provide care and support to his children due to his omission and failure to pay court-ordered child support. The court of appeals affirmed the conviction, concluding (1) the phrase “care and support” in Minn. Stat. 609.375(1) refers exclusively to a person’s financial obligations to a spouse or child; and (2) the district court did not err when it excluded Appellant’s evidence that he had provided nonmonetary care to his children. The Supreme Court reversed, holding (1) to obtain a conviction under section 609.375(1) the State must prove beyond a reasonable doubt that a defendant knowingly omitted and failed to provide both care and support to a spouse or child; and (2) the State did not present any evidence that Appellant knowingly omitted and failed to provide care to his children, and therefore, insufficient evidence supported Appellant’s conviction under the care-and-support statute. View "State v. Nelson" on Justia Law

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After a jury trial, Defendant was convicted of first-degree murder and sentenced to life in prison. Defendant subsequently filed two petitions for postconviction relief, both of which were denied. The instant appeal concerned the postconviction court’s summary denial of Defendant’s second petition for postconviction relief. On appeal, Defendant raised three claims: ineffective assistance of appellate counsel, prosecutorial misconduct, and ineffective assistance of trial counsel. The Supreme Court affirmed, holding that the postconviction court did not err by summarily denying Defendant’s second petition for postconviction relief because all three of Defendant’s claims failed as a matter of law. View "Erickson v. State" on Justia Law

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

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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