Justia Minnesota Supreme Court Opinion Summaries

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

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