Mary Jeanne Coyne

In this case, Galen Willis, a former county employee, sued Sherburne County and a colleague after his termination, claiming wrongful discharge, breach of employment contract, disability discrimination, defamation, and interference with employment. The district court dismissed the wrongful discharge claim on summary judgment but allowed the others to proceed, while the court of appeals affirmed that ruling and additionally held there was no subject matter jurisdiction over the breach of contract claim due to Willis's failure to seek timely review by writ of certiorari. The Minnesota Supreme Court affirmed the court of appeals in full. The core reasoning was that decisions by a county board to terminate a public employee are quasi-judicial acts subject to limited review only through certiorari, not through ordinary civil actions alleging breach of contract or similar claims, though claims like discrimination and defamation could be pursued separately.

labor & employmentcivil rightsprocedure

This case involved a dispute between two auto insurers over priority for uninsured motorist coverage after Marla Decker was struck and injured by an uninsured driver while standing near a parked car owned by Malcolm McMillan. Decker's insurer, Allied Mutual, paid her benefits and sued Western National Mutual (McMillan's insurer) for indemnity, arguing Western was primary under Minn. Stat. § 65B.49, subd. 3a(5) if she was "occupying" the McMillan vehicle. The Minnesota Supreme Court reversed the district court and court of appeals, holding that Decker was not occupying the vehicle under the policy definition ("in, upon, getting in, on, out or off") because she was a pedestrian with no immediate expectation of entering the locked car and no causal connection to it, making Allied's coverage primary. The court directed entry of judgment for Western National.

business & regulatorytorts & liability

This case involved claims by two employees, Robert Hasnudeen and Tracy Hines, against their employer Onan Corporation under the Minnesota Human Rights Act, alleging that their terminations were discriminatory based on race, national origin, and association with someone of a different race. The employees, who were in a dating relationship and had experienced a racially charged work environment, were fired after engaging in a physical altercation at work, with one also cited for lying during the investigation. The trial court applied the McDonnell Douglas framework and found that the plaintiffs failed to prove their terminations were discriminatory. The court of appeals reversed, but the Minnesota Supreme Court reversed that decision and reinstated the judgment for the employer, clarifying that the standards from Anderson v. Hunter and St. Mary's Honor Center v. Hicks are consistent and that this was not a mixed-motive case. The court held that the plaintiffs did not meet their ultimate burden of showing that the employer's reasons were pretextual or that discrimination motivated the firings.

labor & employmentcivil rights

This case concerned whether an auto insurer, American Standard, which had defended its insured Le under a reservation of rights in a personal injury suit brought by Nguyen after a highway altercation and collisions, was required to pay Le's attorney fees incurred in a related declaratory judgment action to determine coverage. The trial court awarded those fees after a jury found Le had not intentionally injured Nguyen, but the Minnesota Supreme Court reversed, holding that attorney fees are recoverable in such actions only when the insurer has breached its contractual duty to defend. The court clarified that no breach occurred here because the insurer had assumed the defense, and it overruled prior decisions suggesting a broader right to fees; it also addressed the timeliness of post-trial motions under Rule 59.03 but focused its review on the fee issue.

proceduretorts & liability

In State v. Zenanko, the defendant was convicted by a jury of burglary, first-degree felony murder, first-degree premeditated murder, and attempted first-degree premeditated murder after he entered an apartment at night and stabbed two men to death while attempting to attack his former romantic interest. The trial court imposed consecutive life sentences for the murders along with additional prison terms. On appeal, the Minnesota Supreme Court affirmed the convictions, holding that the evidence, though circumstantial, was overwhelming and consistent with guilt on all counts while inconsistent with innocence, and that any alleged evidentiary errors, prosecutorial misconduct, or security measures did not prejudice the defendant or warrant a new trial.

criminal lawprocedure

The case involved an employee who alleged she was terminated in retaliation for reporting sexual harassment by a coworker, asserting claims of sexual harassment and reprisal under the Minnesota Human Rights Act as well as retaliation under the Whistleblower Act. The trial court dismissed the Whistleblower claim on summary judgment, finding it preempted by the Human Rights Act's exclusivity provision, and then ruled against the employee on the remaining claims after a bench trial. The court of appeals reversed, holding that the exclusivity provision did not bar the Whistleblower claim and that the employee could proceed to a jury trial. The Minnesota Supreme Court reversed the court of appeals and reinstated the summary judgment, concluding that the Human Rights Act's exclusivity provision bars a parallel retaliation claim under the Whistleblower Act when both arise from the same alleged discriminatory conduct and seek the same relief.

labor & employmentcivil rights