Justia Minnesota Supreme Court Opinion Summaries

After completing an audit of Taxpayers' joint income tax returns, the Commissioner of Revenue issued an order assessing additional taxes. That day, a revenue tax specialist sent Taxpayers an e-mail informing them of the existence of the order. The order was attached to the e-mail. Taxpayers claimed to have been unable to open the attachment containing the letter until sixty-six days after receiving the e-mail. The specialist claimed that he also sent the order by regular mail to Taxpayers' home address, but Taxpayers contended that a mailed copy of the order never arrived. Fifty-three days after Taxpayers opened the e-mail attachment and 119 days after they received the e-mail, Taxpayers filed an appeal with the tax court. The tax court dismissed the appeal as untimely, as it was filed after the sixty-day statutory deadline. The Supreme Court affirmed, holding (1) the tax court's findings that sending the order to Taxpayers electronically and by regular mail was sufficient were not clearly erroneous; and (2) the methods by which the Commissioner sent the order did not violate Taxpayers' due process rights. View "Turner v. Comm'r of Revenue" on Justia Law

Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed several petitions for postconviction relief. Defendant's fourth petition for postconviction relief alleged that new evidence, an unsworn statement by an alleged eyewitness to the murder, entitled him to a new trial. After an evidentiary hearing, the postconviction court denied Defendant's fourth petition for postconviction relief. The Supreme Court affirmed, holding that the postconviction court (1) did not err in denying Defendant a new trial based on new evidence; (2) did not abuse its discretion in how it handled evidence that Defendant submitted after the evidentiary hearing; and (3) did not err in refusing to grant relief in the interests of justice. View "Miles v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony violation of a domestic abuse no-contact order. The court of appeals reversed and remanded for a new trial, holding (1) the failure to instruct on an element of the charged offense as a matter of law affects a defendant's substantial rights, and (2) Defendant's substantial rights were affected as a matter of law by the district court's failure to instruct the jury on the "knowingly" element of the charged offense. The Supreme Court affirmed but on different grounds, holding (1) an unobjected-to jury instruction that omits an element of the charged offense does not, as a matter of law, affect a defendant's substantial rights, but rather, the trial court must consider certain factors to determine whether the omission of an element of a charged offense from the instruction to the jury was sufficiently prejudicial to warrant a new trial; and (2) the trial court's failure to instruct on the "knowingly" element of the charged offense was an error that affected Defendant's substantial rights. View "State v. Watkins" on Justia Law

Wapiti Park Campgrounds, Inc. operated a campground on land in the City of Elk River. The City enacted a series of zoning ordinances that first allowed campgrounds as a conditional use and then removed campgrounds as either a conditional or a permitted use. Wapiti Park obtained a conditional-use permit from the City while campgrounds were allowed as a conditional use. The City later revoked the conditional-use permit and asserted that Wapiti Park was no longer authorized to operate the campground. Wapiti Park filed this action against the City. The district court determined that Wapiti Park's operation of the campground was a nonconforming use that could not be terminated by revocation of the conditional-use permit. The court of appeals reversed. The Supreme Court reversed, holding (1) the City lacked the statutory authority to terminate Wapiti Park's nonconforming use as a campground by revoking the conditional-use permit; and (2) the City acted within its authority when it required Wapiti Park to obtain an interim-use permit before approving replacement of a destroyed accessory building and resumption of the regulated use. View "White v. City of Elk River" on Justia Law

A subcontractor on a public project filed suit against the general contractor and an insurance company that provided a payment bond seeking to recover money owed under the subcontract after the general contractor defaulted. The subcontractor asserted a payment-bond claim against the insurance company and breach of contract, unjust enrichment, and other claims against the general contractor. The insurance company filed a motion for summary judgment on the payment-bond claim because the subcontractor mailed its pre-suit notice of claim to the general contractor listed on the subcontract rather than the address listed on the payment bond. The district court denied the motion and granted judgment against the insurance company. The court of appeals reversed. The Supreme Court affirmed, holding (1) pursuant to Minn. Stat. 574.31(2)(a), a claimant must serve notice on the contractor at its address as stated in the bond as a prerequisite to filing suit; and (2) the subcontractor in this case did not comply with the statutory notice requirements. View "Safety Signs, LLC v. Niles-Wiese Constr. Co., Inc." on Justia Law

Through the exercise of its eminent-domain power, the County of Dakota acquired a commercial property owned by Appellant. Following an administrative hearing, three condemnation commissioners awarded Appellant $655,000 in damages. Appellant appealed, arguing that under Minnesota's minimum-compensation statute, he was entitled to an award of damages that would allow him "to purchase a comparable property in the community." The trial court concluded Appellant was entitled to $997,056 in damages after finding that certain property, which was located within the same city as the condemned property, qualified as a comparable property in the community under the statute. The court of appeals affirmed. At issue on appeal was what qualified as a "comparable property" located in the same "community" as the condemned property. The Supreme Court affirmed, holding (1) the phrase "comparable property" in the minimum-compensation statute refers to an existing property that has enough like characteristics or qualities to another property that the value of one can be used to determine the value of the other; and (2) the district court did not err when it determined that the disputed property qualified as a "comparable property in the community" of the condemned property. View "County of Dakota v. Cameron " on Justia Law

Defendant was charged with first-degree premeditated murder for the benefit of a gang. Defendant was acquitted of the first-degree murder offense but convicted of the lesser-included offense of second-degree intentional murder for the benefit of a gang. The Supreme Court vacated the second-degree murder conviction on appeal. On remand, a second grand jury indicted Defendant with first-degree felony murder for the benefit of a gang and second-degree intentional murder for the benefit of a gang. After Defendant unsuccessfully filed a motion to dismiss the felony murder charge on the grounds that the charge violated constitutional and statutory prohibitions against double jeopardy, Defendant was found guilty of the first-degree felony murder and second-degree intentional murder charges. The trial court convicted Defendant on the second-degree murder offense. The Supreme Court (1) affirmed the conviction of second-degree intentional murder for the benefit of a gang, holding that the State presented sufficient evidence to support the conviction; and (2) reversed the district court's denial of Defendant's pretrial motion to dismiss, holding that the court failed properly to analyze the double jeopardy issue. View "State v. Chavarria-Cruz" on Justia Law

Johnson Controls, Inc. contracted with a school district (the District) to provide design services. Johnson then subcontracted with Architectural Resources, Inc. Marshall Helmberger subsequently submitted a request to Johnson under the Data Practices Act for a copy of the subcontract. Johnson denied the request and withheld the contract. Thereafter, Helmberger filed a complaint with the Office of Administrative Hearings (OAH). An administrative law judge (ALJ) dismissed the complaint after a hearing, concluding that Helmberger did not establish that Johnson was performing a governmental function for the District within the meaning of Minn. Stat. 13.05(11)(a). The court of appeals reversed. The Supreme Court reversed, holding that Johnson was not obligated to disclose the subcontract under the Act because the subcontract was not public data under section 13.05(11)(a). View "Helmberger v. Johnson Controls, Inc." on Justia Law

After a jury trial, Respondent was convicted of third-degree criminal conduct in violation of Minn. Stat. 609.344(1)(l)(i) (the clergy-sexual-conduct statute) based on a sexual relationship between Respondent, a Roman Catholic priest, and a parishioner. The court of appeals reversed, holding (1) the clergy-sexual-conduct statute is not facially unconstitutional; but (2) the statute violated the Establishment Clause as applied to Respondent. the Supreme Court affirmed in part and reversed in part, holding (1) the clergy-sexual-conduct statute does not facially violate the Establishment Clause; and (2) Respondent did not prove that the clergy-sexual-conduct statute as applied violated the Establishment Clause. Remanded. View "State v. Wenthe" on Justia Law

After a jury trial, Appellant was convicted of three counts of first-degree murder and sentenced to three concurrent sentences of life imprisonment with the possibility of release. Appellant subsequently filed three petitions for postconviction relief, all of which were denied. This appeal involved Appellant's third petition for postconviction relief in which Appellant alleged he was entitled to a new trial based on newly discovered evidence. The Supreme Court affirmed, holding (1) the postconviction court did not abuse its discretion when it concluded that Appellant was not entitled to a new trial based on newly discovered evidence; and (2) the chief judge of the district court did not abuse his discretion when he denied Appellant's motion to remove all current and former judges of the Fourth Judicial District for cause. View "Hooper v. State" on Justia Law