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

This case concerns whether a 16-year-old juvenile who killed his parents and two younger siblings with an ax should be referred for prosecution as an adult under Minn. Stat. § 260.125. The district court denied the state's reference petition, relying on prior precedent that substantial evidence of amenability to juvenile treatment precluded certification. The court of appeals reversed, and the Minnesota Supreme Court affirmed that reversal. The court held that 1980 legislative amendments to the juvenile code's purpose clause, which prioritize public safety and the integrity of criminal law, along with a statutory matrix allowing a prima facie case for reference in first-degree murder cases involving juveniles age 16 or older, required a multi-factor analysis. Applying that analysis to the offense's severity, the manner of its commission, expert testimony on treatment prospects, and other Rule 32.05 factors, the court concluded the state met its burden of proving by clear and convincing evidence that the juvenile was unamenable to treatment in the juvenile system consistent with public safety.

criminal lawfamily law

The case involved the conviction of Norman Dean Hayes for the gross misdemeanor of using an artificial light to locate a wild animal while possessing a bow, based on his presence in a van with two others who shone a spotlight on a deer in a rural area. The Minnesota Supreme Court reviewed the trial court's jury instructions on aiding and abetting, which had defined acquiescence in a way that could suggest mere passive acceptance was sufficient for liability. The court determined that the instructions were inadequate because they failed to clarify that the defendant must have intentionally participated by word or deed rather than merely acquiescing, but concluded that any error was harmless given the strength of the evidence showing the defendant's active involvement. The court therefore affirmed the conviction without ordering a new trial.

criminal lawprocedure

In Kuiters v. County of Freeborn, a landowner appealed the tax court's denial of his petition to reduce the assessed value of his agricultural property for 1983 after the court determined the assessor had set the value above market value. The tax court refused to lower the assessment to market value, citing concerns that doing so would create unconstitutional inequality because other agricultural properties in the county were assessed at an average of 115% of market value, and it declined to address equalization with other property classes. The Minnesota Supreme Court reversed and remanded, ruling that the tax court lacked jurisdiction over the constitutional uniformity and equal protection issues because they were not raised in district court prior to transfer, and that the statute required reduction of the assessment to market value regardless of other properties' assessments since those owners had not pursued their statutory remedies.

taxespropertyprocedurecivil rights

This case involved a custody dispute over the minor child of Warren and Connie Lenz following their separation in 1984. The trial court found that neither parent was the primary caretaker and awarded custody to the father based on the child's best interests as determined by a court services study. The court of appeals reversed this decision, identifying the mother as the primary caretaker. The Minnesota Supreme Court reversed the court of appeals, reinstating the trial court's custody award to the father, on the grounds that the trial court's findings were supported by the evidence and it had not abused its discretion.

family law

In State v. Thompson, the defendant was convicted of felony theft after stealing and concealing a log splitter, with evidence including testimony from his stepson. The Minnesota Supreme Court affirmed the conviction, agreeing with the court of appeals on the sufficiency of the evidence, the statute of limitations, and the validity of a search. On the two issues it addressed in detail, the court held that Minn.R.Crim.P. 26.03 gives a criminal defendant the right to be present at a competency hearing for a child witness, which is a stage of trial, even though the federal constitution does not require it. The court also held that a trial judge ordinarily should obtain the defendant's own permission before giving a jury instruction not to draw an adverse inference from the defendant's decision not to testify.

criminal lawprocedure

The case concerned a dispute arising from a school construction project where the general contractor, Prichard Brothers, sued the architect, Grady Company, for negligence and bad faith in performing architectural services, with no direct contract between them, and also sued the school district on a vicarious liability theory. A jury found Grady 64% causally negligent and awarded damages but determined Grady was not the school's agent; the trial court then ruled as a matter of law that Grady was the school's agent and imposed joint and several liability. The court of appeals reversed and dismissed the action, concluding that the economic loss rule from Superwood barred the negligence claim and that any contract claims failed. The Minnesota Supreme Court reversed, applying its intervening McCarthy decision to hold that negligence recovery is available in service transactions and is not barred, and remanded to the court of appeals to address remaining issues such as evidence sufficiency and the school's vicarious liability.

torts & liabilityprocedure

This case involved a lawsuit by Maribelle Plath against her husband Daryl for injuries she sustained when he pushed her during a 1977 argument at home, causing her to fall and break her hip. She filed suit in 1983 alleging both intentional battery and negligence. The trial court ruled that Daryl's actions constituted battery as a matter of law, barring the claim under the two-year statute of limitations. The court of appeals reversed, finding the conduct was negligence subject to a six-year limitations period. The Minnesota Supreme Court reversed the appellate decision and reinstated the trial court's ruling, holding that the trial court's factual finding of battery was supported by the record and not clearly erroneous, so the court of appeals had improperly substituted its own judgment.

torts & liabilityprocedurefamily law

In Nelson v. Siebert, a medical malpractice plaintiff sued a doctor but the case was dismissed with prejudice under a local court rule after no party certified it ready for trial by the deadline, due to the attorney's failure to file the initial pleadings. The trial court denied the plaintiff's motion to vacate the dismissal, but the court of appeals reversed, and the Minnesota Supreme Court affirmed that reversal. The court held that motions to vacate such dismissals are governed by Minn. R. Civ. P. 60.02 and must be analyzed under the four-part Finden test, requiring the moving party to show a reasonable claim on the merits, a reasonable excuse for the neglect, due diligence after discovering the dismissal, and lack of substantial prejudice to the opposing party. Applying that standard to the record, the court concluded the plaintiff met all four elements, so the trial court abused its discretion in refusing to vacate.

proceduretorts & liabilityhealthcare

The case concerned a lawsuit by a mother against the guardian ad litem appointed to represent her minor son in paternity and child support proceedings, alleging that the guardian had negligently failed to perform his duties. The Minnesota Supreme Court held that a guardian ad litem is absolutely immune from liability for acts performed within the scope of those duties. The court reasoned that the guardian acts as a quasi-judicial officer appointed by the court to protect the child's best interests, and immunity is required to allow vigorous representation without fear of harassment from dissatisfied parents, consistent with the extension of judicial immunity to other court-appointed roles.

family lawproceduretorts & liability

Austin Mutual Insurance Company brought a declaratory judgment action against James Templin to resolve no-fault coverage issues under an insurance policy, which were not subject to arbitration. The trial court denied summary judgment to Austin Mutual and later entered a final judgment in favor of Templin on all claims. The court of appeals dismissed Austin Mutual's appeal from that judgment as premature, reasoning that the matter would not be ripe until damages were determined through arbitration. The Minnesota Supreme Court reversed and remanded, concluding that the judgment was a final adjudication of the coverage issues, appealable as of right under the declaratory judgment statutes and appellate rules, and that the Uniform Arbitration Act did not apply.

procedurebusiness & regulatory

This case concerns a workers' compensation dispute arising from Eric Shipton's July 1985 work-related injury at George A. Hormel. After temporary total benefits ended, the employer paid economic recovery compensation, but the compensation judge and Workers' Compensation Court of Appeals also awarded temporary partial benefits at the temporary total rate for a period of unemployment before Shipton found new work at reduced wages. The Minnesota Supreme Court affirmed the award of economic recovery compensation and temporary partial benefits calculated on actual post-injury wages, citing Gasper v. Northern Star, but reversed the award of temporary partial benefits at the temporary total rate, following Parson v. Holman Erection. The court awarded $400 in attorney fees to the employee.

labor & employment

The case involved the conviction of William Shamp for first-degree criminal sexual conduct under Minn. Stat. § 609.342, subd. 1(h)(v), based on multiple acts of sexual abuse against his minor sister spanning from 1978 to 1986. The court of appeals reversed and ordered a new trial, holding that the trial court erred by failing to instruct the jury not to base the conviction on acts occurring before the 1982 extension of the statute of limitations. The Minnesota Supreme Court reversed the court of appeals and reinstated the conviction, reasoning that the defendant had forfeited any claim regarding the missing instruction by conceding the applicability of the seven-year limitations period and failing to request a cautionary instruction at the proper time. The court further held that any error was not prejudicial, as the evidence of post-1982 acts was overwhelming and there was no reasonable likelihood the jury relied solely on time-barred conduct.

criminal lawprocedure

In State v. Storvick, police investigated a nighttime hit-and-run that seriously injured a pedestrian and, within about two and a half hours, developed probable cause linking the defendant to the crime and to his nearby home. Officers went to the residence, received no response to repeated knocking, heard a noise inside, and entered without a warrant, citing concerns that evidence of intoxication would dissipate. The district court suppressed the resulting evidence and dismissed charges, and the court of appeals affirmed on the ground that no exigent circumstances justified the entry under Payton v. New York. The Minnesota Supreme Court reversed, holding that the combination of strong probable cause, the serious nature of the offense, the risk of losing blood-alcohol evidence, the defendant's failure to answer the door, and the officers' belief that weapons might be present created sufficient exigent circumstances to permit the warrantless entry. The case was remanded for trial on the original charges.

criminal lawprocedure

This case concerned whether former striking employees of Geo. A. Hormel & Co. were entitled to unemployment compensation benefits after a labor dispute at the company's Austin, Minnesota plant. The Minnesota Supreme Court affirmed the court of appeals on three issues, holding that initial benefit claims were valid, that individual strikers who made unconditional offers to return remained disqualified during the dispute, and that the Commissioner properly declined to reopen the record. It reversed on the fourth issue, reinstating the Commissioner's determination that the strike and labor dispute ceased active progress on May 23, 1986, when the union trustee made an unconditional offer to return to work on behalf of all strikers. The court reasoned that under Minn. Stat. § 268.09, subd. 3, disqualification ends once strike activity terminates and workers indicate willingness to return, consistent with the statute's humanitarian purpose and precedent from other jurisdictions. It further noted that ongoing negotiations or picketing did not extend the period of active progress.

labor & employment