Douglas K. Amdahl

In State v. Friberg, defendants were convicted of trespassing after staging a sit-in at a St. Paul Planned Parenthood clinic. They appealed on grounds that delays in their trial violated their right to a speedy trial under Minn.R.Crim.P. 6.06 and that a probation condition barring them from coming within 500 feet of the clinic unconstitutionally restricted their First Amendment rights. The Minnesota Supreme Court affirmed the convictions and upheld the probation condition, concluding that the delays were attributable to court calendar congestion and the defendants' own actions such as a judge removal, without sufficient prejudice shown, and that the geographic restriction was a reasonable exercise of the trial court's discretion in sentencing. The court rejected arguments that the condition imposed greater limits than necessary on protected expression.

criminal lawprocedurefree speech

This case involved an appeal by Godfrey Stich challenging a trial court's award of $200 monthly permanent spousal maintenance and $500 in attorney fees to his former spouse Lois Stich following their divorce. The Minnesota Supreme Court reversed the court of appeals decision that had upheld the award, holding that the trial court's findings were inadequate. The court explained that appellate review of maintenance awards requires detailed findings showing consideration of all statutory factors under Minn. Stat. § 518.552, including the parties' expenses and the payor's ability to pay. Because the trial court made findings only on income and not on those other elements, the matter was remanded for additional findings, with the trial court authorized to hold further hearings and to reconsider attorney fees afterward.

family lawprocedure

This case arose from a 1985 lawsuit by the State of Minnesota against asbestos manufacturers seeking damages for hazardous materials in state-owned buildings. After the trial court entered a partial summary judgment under Minn. R. Civ. P. 54.02 that defined the participating buildings, products, and manufacturers, and no timely appeal was filed, the state later obtained an order vacating part of that judgment to add a newly disclosed building. W.R. Grace & Co. appealed the vacatur order, but the court of appeals dismissed the appeal, finding no rule authorizing it. The Minnesota Supreme Court reversed, holding that an order vacating an appealable final judgment is itself appealable as of right based on longstanding principles of judgment finality, and remanded the matter for merits review.

proceduretorts & liability

The case concerned whether the Minnesota State Board of Medical Examiners could publicly release portions of its final disciplinary decision discussing complaints against psychiatrist John Doe that had been dismissed, including allegations of sexual relations with former patients. After the Board reprimanded and fined Doe for misprescribing medication but dismissed the other charges, Doe sought an injunction under the Minnesota Government Data Practices Act to prevent public disclosure of references to the dismissed matters. The district court granted a permanent injunction limiting disclosure, but the court of appeals reversed. The Minnesota Supreme Court held that the Board's final decision, including discussion of dismissed complaints, constitutes public data under the Data Practices Act and Medical Practices Act, as the statutes classify such decisions as public without carving out exceptions for dismissed charges and the 1985 amendments did not restrict this scope.

healthcareprocedurebusiness & regulatory

In this case, the defendant challenged the admission of a statement he gave to police after requesting counsel, who then declined to represent him; the police provided a new Miranda warning and obtained the statement, which the defendant argued violated the Edwards v. Arizona rule against further interrogation. The Minnesota Supreme Court granted review solely on the suppression issue but declined to resolve whether the trial court had erred in admitting the statement. Instead, the court determined that any possible error was harmless beyond a reasonable doubt, citing precedents such as Milton v. Wainwright and State v. Robinson. The court therefore affirmed the underlying judgment without addressing the constitutional claim on its merits.

criminal lawprocedure

This case involved a father, G.W., in juvenile court proceedings concerning visitation with his children after allegations of sexual abuse; the trial court conditioned even supervised visitation on his admission of the abuse as part of a case plan and therapy requirements. The court of appeals reversed that aspect of the order, finding it violated the father's Fifth Amendment privilege against self-incrimination. The Minnesota Supreme Court affirmed the remand to the trial court for further proceedings but clarified the analysis from its prior decision in Matter of Welfare of J.W. The court held that a juvenile court cannot directly compel a parent to admit guilt as a prerequisite to visitation or treatment, as that would violate the privilege, but a parent's failure to make such an admission may practically prevent successful completion of therapy without constituting an improper state penalty. On remand, the trial court was instructed to clarify its order consistently with these principles.

family lawcriminal lawcivil rights