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

The case involved a school bus driver who sued her union, its local chapter, and a co-worker who served as union president, alleging breach of the duty of fair representation, discrimination, tortious interference with employment and union contracts, conspiracy, reprisal, and emotional distress. These claims arose from disputes over bus route scheduling, alleged harassment and unsafe driving reports, the union's handling of internal complaints, and the plaintiff's eventual transfer to another position. The Minnesota Supreme Court affirmed summary judgment of dismissal, modifying the court of appeals' analysis, because the plaintiff failed to establish prima facie cases or genuine issues of material fact on the preserved claims. The court reasoned that the union's investigation and decisions did not breach the collective bargaining agreement or its constitution in a way that created liability, as the complaints did not implicate the CBA and other allegations lacked evidentiary support.

labor & employmentcivil rightsprocedure

This case arose when a construction worker employed by subcontractor Imperial Developers was injured on a project and sued the general contractor Kraus-Anderson, which then sought indemnity from Imperial under their subcontract. The district court and court of appeals held Imperial liable for the damages and related costs based on its contractual promise to obtain insurance covering Kraus-Anderson. The Minnesota Supreme Court reversed, holding that the subcontract's insurance provision was ambiguous and did not specifically require coverage for Kraus-Anderson's own negligence as mandated by Minn. Stat. § 337.05. The court reasoned that while agreements to procure specific insurance are enforceable, the contract language here failed to clearly allocate risk for the general contractor's fault, distinguishing it from valid indemnity or insurance provisions.

torts & liabilitybusiness & regulatory

The case concerned Marlene Meath's denied claim for compensation from Minnesota's Harmful Substance Compensation Board under the Environmental Response and Liability Act. The court of appeals had asserted jurisdiction to review the denial on constitutional grounds, but the Minnesota Supreme Court reversed, holding that neither it nor the court of appeals had authority to review the Board's decision. The core reasoning was that the Board's grant or denial of compensation is not a quasi-judicial act because it does not bind the parties or finally resolve rights; instead, the statute creates a non-binding alternative process that leaves claimants free to pursue civil actions against responsible parties, whether the claim is denied or an award is rejected.

environmentprocedure

The case involved a dispute over underinsured motorist benefits after Raymond Casper suffered a work-related injury in a car accident caused by an underinsured driver. Casper received workers' compensation benefits from his employer, settled his tort claim against the driver for the $50,000 policy limit, and obtained a $120,000 arbitration award under his employer's auto policy issued by Western National. The court ruled that the insurer could offset the full $50,000 settlement but not the workers' compensation payments against the award. It reasoned that underinsured motorist coverage aims to put the insured in the same position as if the tortfeasor had been fully insured, the mandated distribution of settlement proceeds does not alter the tortfeasor's insurance amount, and the arbitration award addressed only uncompensated damages.

torts & liabilitylabor & employmentbusiness & regulatory

The case involved Francis and Barbara Brun, enrolled members of the Red Lake Band of Chippewa Indians who earned income on the reservation but owned and occupied a home off-reservation in Bemidji for periods between 1979 and 1988. The Minnesota Tax Court held that their reservation-earned income was exempt from state taxation because the Bruns were domiciled on the reservation and did not intend to abandon it. The Minnesota Supreme Court reversed and remanded, ruling that the Bruns had not shown they resided on the reservation throughout the period and that their income was therefore subject to state tax for the time spent off-reservation. The court reasoned that states lack authority to tax tribal members living and earning income on a reservation, but tribal members who reside beyond reservation boundaries are subject to nondiscriminatory state tax laws, with actual residence rather than domicile controlling the inquiry under Minnesota statutes and federal precedents.

taxesfederal power

In State v. Lewis, the defendant was convicted by a jury of first-degree felony murder and attempted first-degree felony murder based on his alleged participation with two others in armed robberies and shootings in St. Paul on April 1, 1994, which resulted in one victim's death. On direct appeal, the defendant argued that the trial court erred by admitting evidence of his prior participation in two violent street robberies under Minn. R. Evid. 404(b) to prove identity, and that the prosecutor committed prejudicial plain error in closing argument. The Minnesota Supreme Court affirmed the convictions, holding that the prior crimes were sufficiently similar to the charged offenses to be admissible for identification purposes and that any error in the closing argument was not plain or prejudicial. The court reasoned that the shared elements of group street robberies involving violence supported the evidentiary ruling under Rule 404(b) and prior precedent like State v. Spreigl.

criminal lawprocedure

This case was a class action brought by physicians whose medical licenses were issued or renewed between April 1 and September 30, 1992, challenging the assessment of a $400 license surcharge due by December 15, 1992, under Minn. Stat. § 147.01, subd. 6 (1992). The district court and court of appeals ruled in favor of the State, Minnesota Board of Medical Practice, and Department of Human Services, and the Minnesota Supreme Court affirmed. The court held that the statute's text was clear and unambiguous in requiring the board to bill and collect the surcharge according to the specified schedule for physicians whose licenses fell into the April-September window, that the 1993 amendment was not needed to clarify its application, and that imposing the surcharge did not constitute improper retroactive legislation. The court also rejected an equal protection challenge, finding the billing classification rationally related to the legitimate purpose of raising funds for the general fund to support Medicaid matching.

healthcarebusiness & regulatorytaxes

The case involved a claim by Mark Blackowiak against Richard Kemp for damages from alleged sexual abuse that occurred in 1970 or 1971 when Blackowiak was a child. The Minnesota Supreme Court reinstated the trial court's summary judgment dismissing the complaint, ruling that it was barred by the six-year statute of limitations under Minn. Stat. § 541.073 because Blackowiak knew or had reason to know prior to 1986 that his injuries were caused by the abuse. The court reasoned that sexual abuse and resulting injury are essentially inseparable as a matter of law, and evidence of the plaintiff's early awareness and reactions to the abuse established that the limitations period had expired.

proceduretorts & liability

This case concerns whether three dentists providing services at James Boily's Minnesota dental clinic qualify as employees or independent contractors under the state's economic security law for tax purposes. The Minnesota Supreme Court affirmed the court of appeals' conclusion that the dentists are independent contractors, while rejecting characterizations of the commissioner's decision as arbitrary and of a 1988 audit as a prior determination of status. Applying the five-factor test from Guhlke v. Roberts Truck Lines (right to control means and manner of performance, mode of payment, furnishing of tools, control of premises, and right to discharge), with greatest weight on control, the court found limited oversight by Boily (who resides in California), that the dentists set their own schedules and treatments, receive percentage-based compensation rather than salary, and supply their own instruments and malpractice insurance. The court noted the absence of any formal determination from the 1988 audit and that Minnesota law lacks a provision treating audit results as conclusive on employment status.

labor & employmentbusiness & regulatorytaxes

This case concerns the property tax assessments for a 13.06-acre tract in Minnesota that was contaminated with tetrachloroethylene from prior industrial use and listed on state and federal superfund priority lists. The owners challenged the county assessor's estimated market values of $470,100 for 1992 and $876,800 for 1993, arguing the property had no market value due to cleanup costs exceeding $2.8 million and stigma from pollution. The tax court accepted an appraiser's analysis showing that after deducting the present value of remediation costs and stigma, the net value was zero or negative, and ordered the values reduced to $0 for both years. The Minnesota Supreme Court affirmed, holding that the evidence on stigma discounts and cleanup costs supported the tax court's determination that the impaired market value was $0.

taxespropertyenvironment

The case involved an employee who suffered a serious workplace injury covered by workers' compensation, after which he and his wife negotiated a $200,000 settlement with the third-party property owner that purported to resolve all claims, including the employer's subrogation interest. The workers' compensation insurer, Zurich, had already paid over $280,000 in benefits and objected to the settlement, refusing to endorse the check or release its subrogation rights. The plaintiffs sought a writ of mandamus to compel the insurer's participation, but the district court dismissed the petition and the court of appeals affirmed. The Minnesota Supreme Court held that Minn. Stat. § 176.061, particularly subdivision 8a, governs such settlements and requires the employer's or insurer's consent when the agreement compromises the subrogation interest, unlike a limited Naig settlement that addresses only non-compensable damages. The court reasoned that the comprehensive statutory scheme allocates rights and proceeds among the employee, employer, and third-party tortfeasor, preventing an employee from unilaterally binding the insurer.

labor & employmenttorts & liability

The case involved a district court's order restricting Barbara Burns' communications with the court after she filed multiple actions and engaged in unauthorized contacts. The district court issued an order to show cause, held a hearing, and imposed restrictions when Burns failed to justify her conduct. The court of appeals reversed, but the Minnesota Supreme Court reinstated the district court's order, reasoning that it was a proper exercise of the court's inherent authority to enforce procedural rules and maintain order, not requiring a full adversarial hearing.

procedure

In State v. Barlow, defendant Rico Barlow was convicted by a jury of first-degree murder, first-degree burglary, and first- and second-degree assault arising from a home burglary and shooting in Brooklyn Park, Minnesota, along with related burglaries. On appeal, Barlow sought a new trial, arguing that the trial court erred by denying several challenges for cause (forcing him to use peremptory challenges) and by excluding expert testimony on the reliability of eyewitness identifications. The Minnesota Supreme Court affirmed the convictions, holding that any error in jury selection was not prejudicial because Barlow received additional peremptory challenges and the alternate jurors did not participate in deliberations, and that the exclusion of the expert testimony was proper under established precedent because it would not have been sufficiently helpful to the jury. The court applied rules from Minn.R.Crim.P. 26.02 and Minn.R.Evid. 702 in its analysis.

criminal lawprocedure

In this case, a dermatologist sued his former law firm for legal malpractice, alleging negligence in failing to tender defense of an employment termination lawsuit brought by his prior employer to his commercial general liability insurer. The suit involved claims of breach of restrictive covenants in the employment and termination agreements, liquidated damages, unfair competition, and related issues stemming from the doctor's solicitation of patients and opening of a competing practice. The trial court granted summary judgment to the law firm, finding no insurance coverage for the claims, but the court of appeals reversed; the Minnesota Supreme Court reinstated the summary judgment. The court reasoned that the policy's advertising injury coverage did not apply, as the underlying complaint alleged only breach of contract (explicitly excluded) and did not assert any of the specific covered offenses like libel, privacy violations, or unauthorized taking of advertising ideas. Additionally, any potential coverage was defeated by the insured's failure to notify the insurer or obtain consent before settling.

torts & liabilitybusiness & regulatorylabor & employment