Minnesota Supreme Court Decisions 2018

Justia Opinion Summary: The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court concluding that future, contingent earn-out payments are nonmarital property because they are property acquired…

Justia Opinion Summary: The Supreme Court reversed the court of appeals affirming the district court’s competency determination in this criminal case, holding that the court of appeals erred when it did not follow State v. Ganpat, 732 N.W. 2d…

Justia Opinion Summary: The Supreme Court affirmed the decision of the court of appeals affirming the decision of the postconviction court that Defendant was entitled to a new trial because a juror was actually biased and not sufficiently…

Justia Opinion Summary: The Supreme Court reversed the decision of the court of appeals holding that Minn. Stat. 609.342(1)(h) does not require the State to prove that “sexual penetration” occurred, holding that the plain language of the…

Justia Opinion Summary: The Supreme Court affirmed the decision of the tax court upholding the decision of the Commissioner of Revenue to include Pell grants in its calculation of Relators’ household income, holding that “nontaxable scholarship…

Justia Opinion Summary: The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court that concluded that a fee agreement between the parties was not void and thus ordering arbitration, holding that…

Justia Opinion Summary: The Supreme Court reversed the judgment of the court of appeals affirming the district court’s grant of summary judgment for The Blake School (the school) on Appellant’s negligence action based on a fatal accident caused…

Justia Opinion Summary: The Supreme Court affirmed the decision of the district court denying Appellant’s motion to correct his sentences under Minn. R. Crim. P. 27.03(9), holding that the district court did not commit reversible…

Justia Opinion Summary: The Supreme Court affirmed the postconviction court’s summary denial of Defendant’s second postconviction petition, holding that the record conclusively showed that Defendant was not entitled to relief. Defendant was…

Justia Opinion Summary: The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing the claims filed by Depositors Insurance Company against Craig Dollansky after concluding that…

Justia Opinion Summary: The Supreme Court affirmed the postconviction court’s denial of Appellant’s petition for postconviction relief challenging his conviction for first-degree murder for the benefit of a gang, holding that Appellant’s claims…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the district court dismissing this qui tam action filed under the Minnesota False Claims Act, Minn. Stat. 15C.02 (MFCA), claiming that Respondents intentionally failed to pay…

Justia Opinion Summary: In this divorce proceeding, the Supreme Court affirmed the decision of the court of appeals concluding that the certain contingent earn-out payments set forth in a purchase agreement selling a company in which Husband…

Justia Opinion Summary: At issue was whether a notice to remove an assigned tax court judge was timely and, if so, whether the assigned judge erred in finding that it was impracticable to honor the notice. OCC, LLC, a property owner in…

Justia Opinion Summary: The Supreme Court held that the decision of the United States Supreme Court in Birchfield v. North Dakota, 579 U.S. __ (2016), and this Court’s decisions in State v. Trahan, 886 N.W.2d 216 (Minn. 2016), and State v.…

Justia Opinion Summary: The Supreme Court held that a warrantless narcotics-dog sniff in the hallway outside Defendant’s apartment did not violate Defendant’s right to be free from unreasonable searches under the Minnesota and United States…

Justia Opinion Summary: The Supreme Court held that the classification of a prior offense under Minnesota Sentencing Guidelines 2.B.7.a for the purpose of calculating a defendant’s criminal history score is determined by the Minnesota offense…

Justia Opinion Summary: The Supreme Court held that a statutory city does not have express authority under Minn. Stat. 462.358(2)(a) to condition approval of a subdivision application on the payment of an infrastructure charge for future…

Justia Opinion Summary: The Supreme Court affirmed the decision of the postconviction court denying Appellant’s petition for postconviction relief without an evidentiary hearing, holding that the postconviction court did not abuse its…

Justia Opinion Summary: The Supreme Court held that Minnesota’s Legend Drug Tax, Minn. Stat. 295.52(4), applies to a non-resident pharmacy’s delivery of prescription drugs to Minnesota-based patients and doctors and that such application does…

Justia Opinion Summary: The Supreme Court affirmed the decision of the court of appeals upholding Defendant’s conviction of fifth-degree criminal sexual conduct and indecent exposure for sending a picture of his genitals to a minor over…

Justia Opinion Summary: The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that Plaintiff’s injury “arose out of” her employment under the “increased-risk” test the Court applied in Dykhoff v. Xcel…

Justia Opinion Summary: The Supreme Court held that Minn. Stat. 609.344(1)(b) and 609.345(1)(b), which prohibit sexual penetration and sexual conduct where the complainant is between thirteen and sixteen years of age and the actor is more than…

Justia Opinion Summary: The Supreme Court held that a “school zone,” as defined by Minn. Stat. 152.01(14)(a), includes the entire area of a city block that is situated kitty-corner to school property when the land surrounding the school…

Justia Opinion Summary: The Supreme Court held that separation-of-powers principles do not prevent the judiciary from ruling on whether the Legislature has violated its duty under the Education Clause of the Minnesota Constitution or violated…

Justia Opinion Summary: At issue was whether a former employee’s (Employee) delay in returning his employer’s (Employer) property excused Employer from paying a commission otherwise due to Employee. The district court concluded that a…

Justia Opinion Summary: The Supreme Court held that the tax court lacked jurisdiction to consider a motion filed in a case arising from a tax petition that was automatically dismissed by operation of law. Ronald and Dee Johnson challenged the…

Justia Opinion Summary: The Supreme Court held that the forfeiture-of-office provision of the Minnesota Open Meeting Law, under which pubic officials who violate the Open Meeting Law may be removed from office, requires three separate, serial…

Justia Opinion Summary: The Supreme Court held that four irrevocable inter vivos trusts (the Trusts) lacked sufficient relevant contacts with Minnesota during the relevant tax year to be permissibly taxed, consistent with due process, on all…

Justia Opinion Summary: The Supreme Court affirmed Appellant’s conviction for first- and second-degree murder on an aiding-and-abetting theory. The Court held (1) even if it was error for the district court to admit into evidence Appellant’s…

Justia Opinion Summary: The tax court correctly dismissed the appeals brought by several cooperatives (the Cooperatives) challenging the valuation orders of the Commissioner of Revenue for the 2014, 2015, and 2016 tax years because the appeals…

Justia Opinion Summary: The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that the compensation judge failed fully to consider the extent to which each of Respondent’s employers sought to shift…

Justia Opinion Summary: The Commissioner of Revenue properly invoked her alternative-apportionment authority under Minn. Stat. 290.20(1) and applied an alternative apportionment method that fairly reflected the income of Associated Bank, N.A.…

Justia Opinion Summary: The Supreme Court affirmed the decision of the Minnesota Tax Court affirming the order of the Commissioner of Revenue that assessed Terrance Sargent’s income tax liability for tax years 2010-2014, holding that Sargent’s…

Justia Opinion Summary: The Supreme Court has applied the rule of contra proferentem - “a doctrine that ambiguities in a contract are to be construed unfavorably against the drafter” - only after an attempt is made to determine the parties’…

Justia Opinion Summary: Security Bank & Trust Company (Security Bank) lacked standing both in its capacity as personal representative of Gordon P. Savoie’s estate and in its capacity as trustee of the Gordon P. Savoie Revocable Trust to bring…

Justia Opinion Summary: In a complaint seeking an injunction for breach of contract, the district court was not required to find irreparable harm based solely on the language of a private agreement and did not abuse its discretion by declining…

Justia Opinion Summary: The Supreme Court reversed the decision of the court of appeals reversing the district court’s denial of Father’s motion to increase his parenting time to every other week, holding that Father’s proposed modification was…

Justia Opinion Summary: The Supreme Court reversed the decision of the court of appeals declaring the City of Rochester’s competitive bidding process and the resulting contract awarded to First Transit invalid. The City owned a fleet of buses…

Justia Opinion Summary: The Supreme Court affirmed the decision of the court of appeals interpreting Minn. Rev. Stat. 524.3-101 to allow real property to devolve immediately upon a testator’s death to a residual devisee. Plaintiff, in her…

Justia Opinion Summary: State law did not preempt a proposal to amend the charter of the City of Bloomington to require voter approval before the City can implement organized collection of solid waste. Appellants petitioned the City for a…

Justia Opinion Summary: The Supreme Court affirmed the postconviction court’s denial of Petitioner’s petition for postconviction relief, holding that the postconviction court did not abuse its discretion. Petitioner was found guilty of…

Justia Opinion Summary: The Supreme Court affirmed in part and reversed and remanded in part the postconviction court’s denial of Petitioner’s second petition for postconviction relief without holding an evidentiary hearing. Petitioner was…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the court of appeals reversing the district court’s grant of partial summary judgment in favor of Father on Son’s personal injury suit, holding that the Recreational-Use…

Justia Opinion Summary: At issue was the proper method for calculating the quantum meruit value of an attorney’s services when a client terminates the contingent-fee agreement before a matter concludes. Respondent retained Appellant-law firm…

Justia Opinion Summary: The Supreme Court reversed the judgment of the court of appeals affirming the decision of the district court concluding that a grain-handling contract between the parties in this case that was to “continue indefinitely”…

Justia Opinion Summary: The Supreme Court affirmed Appellant’s conviction of two counts of first-degree premeditated murder for the shooting deaths of his long-time girlfriend and his girlfriend’s fifteen-year-old daughter. On appeal,…

Justia Opinion Summary: The Supreme Court affirmed Defendant’s conviction for first-degree murder, holding that any error in the admission into evidence of testimony from Defendant’s physicians and a burn expert did not substantially influence…

Justia Opinion Summary: The Supreme Judicial Court affirmed the district court’s summary denial of Appellant’s ninth petition for postconviction relief, holding that Appellant’s petition was time barred or otherwise rested upon a meritless…

Justia Opinion Summary: The common law governs provisions of an antenuptial agreement that do not fall within the safe harbor of Minn. Stat. 519.11(1), and the multifactor Kinney test is the common-law test applicable to antenuptial agreements.…

Justia Opinion Summary: The clear-and-convincing standard applies when determining the existence of an oral contract for the conveyance of farmland when only money damages are sought for the claimed breach of that contract. Plaintiff argued…

Justia Opinion Summary: The limited right to counsel recognized in Friedman v. Commissioner of Public Safety, 473 N.W. 2d 828 (Minn. 1991), applies only to implied-consent cases. The district court in this case suppressed the results of a…

Justia Opinion Summary: In a proceeding to terminate parental rights that is governed by the Indian Child Welfare Act (ICWA) and the Minnesota Indian Family Preservation Act (MIFPA), qualified expert witness testimony is required to support the…

Justia Opinion Summary: Claims brought against the manufacturer of a component part of an improvement to real property fell under an exception to the ten-year statute of repose because the improvement was “machinery installed upon real…

Justia Opinion Summary: Appellant failed to establish that he was prejudiced by the implied consent advisory read to him after he was arrested on suspicion of driving while impaired, and therefore, Appellant was not entitled to a rescission of…

Justia Opinion Summary: The Supreme Court reversed the decisions of the court of appeals and district court that Respondent’s due process rights were violated when he was read an inaccurate implied consent advisory after his arrest on suspicion…

Justia Opinion Summary: A defendant who files a motion under Minn. R. Crim. P. 27.03, subd. 9 to correct a sentence after the time for direct appeal has passed bears the burden to prove the sentence was based on an incorrect criminal history…

Justia Opinion Summary: At issue was whether Hennepin County properly refused to comply with part of Appellant’s government-data request under the Minnesota Government Data Practices Act (the Data Practices Act). The Supreme Court held (1)…

Justia Opinion Summary: The legislative amendments to the State Auditor’s responsibilities over audits of Minnesota counties do not violate either the Separation of Powers Clause, Minn. Const. art. III, 1 or the Single Subject Clause, Minn.…

Justia Opinion Summary: At issue was whether an indemnity clause in a rental agreement required the renter to indemnify the rental company for the rental company’s negligence. The Tower Tap & Restaurant entered into an agreement to rent…

Justia Opinion Summary: The “actual notice” provision of the Civil Damages Act, see Minn. Stat. 340A.802(2), popularly known as the Dram Shop Act, requires actual notice of sufficient facts to put a liquor licensee on inquiry notice of a…

Justia Opinion Summary: The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder and his sentence of life in prison without the possibility of release. The State in this case initially filed a complaint charging…

Justia Opinion Summary: The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers’ Compensation Court of Appeals (WCCA) upholding the decision of the compensation judge ordering that Atlas Staffing, Inc.…

Justia Opinion Summary: The Supreme Court affirmed a postconviction order that summarily denied Appellant’s public-trial claim on the grounds that the claim was barred by the rule announced in State v. Knaffla, 243 N.W.2d 737 (Minn.…

Justia Opinion Summary: Law enforcement officers did not violate Defendant’s Fifth Amendment privilege against self-incrimination when, after Defendant invoked his privilege against self-incrimination, they later asked him if he was willing to…

Justia Opinion Summary: A district court “participates” in a plea bargaining negotiation (see State v. Johnson, 156 N.W.2d 218 (Minn. 1968) when it provides unsolicited comments regarding the propriety of the parties’ competing settlement…

Justia Opinion Summary: A seller’s fraudulent statements about the fitness of a vehicle for the purpose for which it was purchased make disclaimers in purchase documents stating that the buyer purchased the vehicle “as is” ineffective. The…

Justia Opinion Summary: In this case where a petitioner’s former attorneys appealed an order of the district court dismissing a postconviction petition as moot following the death of the petitioner, the Supreme Court dismissed the appeal,…

Justia Opinion Summary: In this case regarding the determination of the tax court valuing Minnesota Energy Resources Corporation’s (MERC) natural gas pipeline distribution system for the years 2008 through 2012, the Supreme Court affirmed the…

Justia Opinion Summary: The warrantless search of Defendant’s property violated Defendant’s Fourth Amendment rights in this case. Here, an officer entered Defendant’s property, examined a stolen camper trailer and then, after obtaining…

Justia Opinion Summary: The Supreme Court affirmed the decision of the court of appeals affirming the district court’s denial of Father’s request for additional parenting time to provide before- and after-school child care for the parties’ son,…

Justia Opinion Summary: Failing to register is a continuing crime that includes the entire range of dates on which Defendant failed to register in this case, and a jury was not required to find the date of Defendant’s current…

Justia Opinion Summary: In this case involving the constitutionality of the Minnesota Unclaimed Property Act the Supreme Court held (1) owners of interest-bearing bank accounts have a constitutionally protected property right that is taken when…

Justia Opinion Summary: The Supreme Court affirmed Defendant’s convictions for two counts of first-degree murder, two counts of second-degree murder, and one count of attempted second-degree murder, holding that any alleged errors, whether…

Justia Opinion Summary: The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272…

Justia Opinion Summary: A passenger who grabs the steering wheel of a moving vehicle is “operating” the motor vehicle under the criminal-vehicular-operation statute, Minn. Stat. 609.2113(1). Defendant was charged with criminal vehicular…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the court of appeals affirming the district court’s conclusion that Respondent untimely filed his complaint challenging the forfeiture of his vehicle but reversed the district…

Justia Opinion Summary: A person is “carry[ing] a pistol on or about the person’s clothes or person” for purposes of Minn. Stat. 624.7142(1)(4) when that person is driving a vehicle with a handgun in the center console. During an inventory…

Justia Opinion Summary: At issue on certiorari was what evidence a tax court may rely upon in deciding whether the taxpayer has overcome the presumptive validity of the county’s assessment. Here, Taxpayer contested the County’s assessment of…

Justia Opinion Summary: Contrary to the holding of the district court, Appellant filed a timely legal-malpractice claim under Minn. Stat. 541.05(1)(5). Respondent, Appellant’s attorney, prepared an antenuptial agreement for Appellant and his…

Justia Opinion Summary: Past physical abuse, standing alone, can support the issuance of an order for protection (OFP) under the Domestic Abuse Act, Minn. Stat. 518B.01, because the Act imposes no temporal requirement on when the “domestic…

Justia Opinion Summary: The Supreme Court affirmed the denial of Appellant’s third petition for postconviction relief, which asserted several claims based on facts alleged in two sworn affidavits, holding that the affidavits were legally…

Justia Opinion Summary: A facsimile transmission is not a “delivery” under Minn. R. Civ. P. 3.01(c), which requires that a summons be “delivered” to the sheriff before an action is commenced, because Rule 3.01(c) contemplates personal delivery…

Justia Opinion Summary: At issue in this case was whether Defendant committed burglary when he entered another guest’s hotel room without that guest’s consent and committed a crime in that room. The Supreme Court affirmed the judgment of the…

Justia Opinion Summary: The Supreme Court reversed the postconviction court’s summary denial of Appellant’s pro se petition for postconviction relief, in which Appellant argued that his trial counsel was ineffective and that the prosecutor…

Justia Opinion Summary: The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone. The police lawfully seized a cellphone from Defendant and…

Justia Opinion Summary: The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder, holding that there was no abuse of discretion. On appeal, Defendant argued that the district court abused its discretion when it…

Justia Opinion Summary: Applying Minn. R. Civ. P. 6.02 to extend the lis pendens deadline in Minn. Stat. 582.043(7)(b) is prohibited because to do so would impermissibly modify the substantive rights provided by the statute. The Supreme Court…

Justia Opinion Summary: Appellant Emile Rey pleaded guilty to one count of identity theft involving eight or more direct victims. The district court ordered Rey to pay the mandatory-minimum restitution of $1,000 to each of his 66 direct…

Justia Opinion Summary: Appellant BCBSM, Inc. (“Blue Cross”) denied respondent James Linn’s insurance claim because the requested treatment was not considered medically necessary under the parties’ health-plan contract. After Blue Cross denied…