Thomas F. Gallagher

In State v. Adkison, the defendant was charged with criminal negligence after a fatal car accident and pleaded guilty in district court following an earlier conviction for driving after license revocation. On appeal, he argued that his guilty plea resulted from a misunderstanding of his legal position, allegedly induced by advice about possible maximum sentences and the Habitual Offender Act, and that his court-appointed counsel had provided inadequate representation. The Minnesota Supreme Court affirmed the conviction and sentence, holding that the record showed the defendant had been fully informed of the charges, penalties, and rights; had explicitly confirmed that no promises or threats influenced his plea; and had received adequate consultation from counsel with no evidence of misadvice or deficient preparation. The court found no basis to withdraw the plea or reverse on due process grounds.

criminal lawprocedure

The case involved Donald Stokes, an employee of J.L. Shiely Company, who sought workers' compensation benefits after a November 1963 truck accident caused injuries including a sore ankle and later fainting spells or blackouts. A referee awarded temporary total and permanent partial disability benefits, which the Industrial Commission affirmed, but the commission later denied Stokes' petition to vacate the award for a rehearing. The Minnesota Supreme Court remanded to the Industrial Commission to set aside the award and grant a new hearing. The court reasoned that evidence unavailable at the original hearing, including information on the potential permanence of Stokes' fear of trucks and the origin of his blackouts, justified reopening the matter under Minn. St. 176.461 in the interest of justice.

labor & employmentprocedure

This case concerned whether an employer had simultaneous workers' compensation coverage from two insurers on the date an employee was injured, and whether one insurer could obtain contribution from the other for benefits paid. The Industrial Commission found no coverage by American Insurance on the injury date of May 17, 1965, and denied Bituminous Casualty's claim for contribution; the Minnesota Supreme Court affirmed. The court held that production of the policy by Bituminous did not establish a prima facie case of coverage because Bituminous was neither the insured nor a beneficiary, and the evidence supported the commission's finding that the employer never accepted American's policy, which was returned for flat cancellation. The court noted that issuance of a policy is only an offer that requires acceptance to form a binding contract, and the commission's findings had sufficient evidentiary support.

labor & employmentprocedure

The case involved a petition for habeas corpus by a defendant convicted of aggravated robbery after pleading guilty to robbing a liquor store while armed; he was sentenced to up to 10 years in prison. The relator claimed the trial court erred by denying his right of allocution before sentencing, failing to order a presentence investigation, and denying the habeas petition without a hearing. The Minnesota Supreme Court affirmed the denial, reasoning that an extensive pre-sentencing examination of the defendant by the court, combined with statements from his attorney on mitigating factors, satisfied allocution requirements and provided adequate background information, distinguishing the facts from prior cases like Searles where sentences were vacated.

criminal lawprocedure

A 71-year-old widow living in a Duluth apartment building was injured when a discarded water heater fell on her in the basement. She sued the building owner, who had hired a plumber to replace a leaking heater, and the plumber, claiming negligence in leaving the old heater in a dangerous position. The jury returned a verdict for the plaintiff against the owner only, and the trial court denied the owner's post-trial motions for judgment notwithstanding the verdict, indemnification from the plumber, or a new trial. On appeal, the Minnesota Supreme Court affirmed, finding sufficient evidence that the owner breached his duty to keep the common basement area reasonably safe, that the plumber was not negligent, and that the basement qualified as a common area under the owner's supervision.

propertytorts & liability

The case concerned a habeas corpus petition challenging a third-degree murder conviction based on a confession obtained during police interrogations while the petitioner was in custody on a related arson charge. The Washington County District Court granted the writ, finding that the Hennepin County trial court had failed to make a reliable preliminary determination of the confession's voluntariness before submitting it to the jury, violating the petitioner's due process rights under the Fourteenth Amendment. The Minnesota Supreme Court affirmed, holding that the procedure used at trial did not comply with the requirements established in Jackson v. Denno and that this constitutional standard applies retroactively. The court remanded the matter to the trial court for a separate hearing to determine whether the confession was voluntary, with a new trial required only if it was found to be coerced.

criminal lawprocedurecivil rights