James H. Gilbert

In State v. Sanchez-Diaz, the Minnesota Supreme Court reviewed the conviction of Sergio Sanchez-Diaz for first-degree murder while committing domestic abuse and second-degree murder of an unborn child after he stabbed his pregnant partner to death in 2001. The court addressed challenges regarding the sufficiency of evidence to establish a past pattern of domestic abuse, the accuracy of the jury instruction on that pattern, the admission of the defendant's police statements containing interpreter errors, and the imposition of a consecutive sentence for the unborn child's murder. The majority affirmed the convictions, holding that the evidence was sufficient to prove multiple prior incidents of abuse, that the jury instruction was not erroneous when read as a whole, that any issues with the interpreted statements were harmless, and that consecutive sentencing was within the district court's discretion. The decision rested on a detailed review of trial testimony, forensic evidence, and the defendant's statements describing the relationship and events.

criminal law

The case involved a challenge to the admission of evidence of a prior alleged domestic assault by the defendant against his wife in his trial for misdemeanor domestic assault. The district court allowed the evidence under Minn. Stat. § 634.20 without requiring it to meet the clear and convincing evidence standard of Minn. R. Evid. 404(b), but the court of appeals reversed the conviction on that ground. The Minnesota Supreme Court reversed, holding that evidence of similar prior conduct in domestic abuse cases may be admitted under the statute without first being proven by clear and convincing evidence, and noting that no such evidence had actually been admitted at trial. The court reasoned that the specific provisions of § 634.20 control over the general requirements of Rule 404(b) and overruled contrary statements in prior decisions as dicta.

criminal lawprocedure

This case involved a judgment creditor's attempt to execute on a fraud judgment against Thomas Sweno by forcing a sheriff's sale of real property he held in joint tenancy with his spouse. Sweno designated the property as his homestead and claimed the full $200,000 statutory exemption under Minn. Stat. § 510.02 exceeded his undivided one-half interest. The district court initially blocked the sale on joint-tenancy grounds, but the court of appeals allowed foreclosure and a credit-bid sale; the Minnesota Supreme Court reversed, holding that the sale improperly failed to protect the non-debtor spouse's homestead rights and violated the statutory exemption requirements. The court therefore ordered the sheriff's sale voided and remanded for further proceedings consistent with the exemption statutes.

propertyprocedure

This case involved the conviction of respondent Alan George Olhausen, Jr. for three counts of first-degree controlled substance crimes (aiding and abetting sale, conspiracy to sell, and possession of methamphetamine), as well as fleeing a peace officer and first-degree criminal damage to property. The court of appeals reversed the controlled substance convictions on the ground that scientific testing of the actual substance was required, but the substance had been disposed of during the defendant's flight. The Minnesota Supreme Court reversed the court of appeals and reinstated the convictions, holding that the evidence was sufficient to support the jury's verdict even without lab testing. The court reasoned that the combination of the defendant's repeated representations and actions to sell what he described as genuine methamphetamine, the undercover officer's experienced observations and handling of the packaged substance, and the absence of any indication it was fake formed a complete chain of circumstantial evidence proving the substance's identity beyond a reasonable doubt.

criminal law

This case involved three telecommunications companies seeking refunds of sales taxes paid on purchases of network equipment used in local exchange, wireless, and long-distance services, claiming the equipment qualified for exemption as capital equipment used to manufacture tangible personal property. The Minnesota Supreme Court reversed the tax court's denial of the refunds. The court held that the equipment manufactured tangible personal property because it transformed voice and data into electronic signals that qualify as corporeal personal property under the statutory definition in effect during the relevant period. The decision rested on de novo review of the stipulated facts and interpretation of the sales tax exemption statutes, determining that the signals were capable of being physically perceived.

taxesbusiness & regulatory

Darren Paul Odell was charged with first-degree murder for shooting his father and raised an insanity defense under Minnesota's M'Naghten rule statute, claiming he did not understand the wrongfulness of his actions due to mental illness. After a bench trial, the court found him guilty in the guilt phase and rejected the mental illness defense in the second phase, sentencing him to life in prison. On appeal, the Minnesota Supreme Court affirmed, holding that the evidence was sufficient to show Odell knew the nature and wrongfulness of the act. The court reasoned that the trial judge properly weighed conflicting expert opinions, crediting those who concluded the defense did not apply based on the defendant's behavior and statements, and conducted a rigorous review of the record supporting the finding that the defendant failed to prove the defense by a preponderance of the evidence.

criminal law

The case involved David Wayne Washington's appeal from the denial of his fifth petition for postconviction relief following his 1992 convictions for first-degree premeditated murder and related charges. The Minnesota Supreme Court affirmed the postconviction court's summary denial, holding that most of Washington's claims—regarding the admission of witness testimony, his own statements to police, and judicial bias—were procedurally barred under the Knaffla rule because they were known but not raised on direct appeal. The court also rejected claims about an omitted jury instruction on accomplice testimony, finding the instruction was actually given, and thus there was no ineffective assistance of counsel.

criminal lawprocedure

This case concerned whether Minnesota's No-Fault Automobile Insurance Act and related statutes require commercial automobile insurance policies to extend uninsured or underinsured motorist (UM/UIM) coverage to employees using out-of-state rental vehicles. The Turners, injured in a Louisiana accident while driving a rental car arranged by their employer Express Scripts, sought coverage under the employer's commercial policy issued by Liberty Mutual after liability limits from the other driver's insurer were exhausted. The district court ruled that Minn. Stat. § 60A.08, subd. 12 mandated UM/UIM coverage under the commercial policy for the rental vehicle, but the court of appeals reversed. The Minnesota Supreme Court affirmed, holding that the statute only requires commercial policies to cover damage and loss of use for rented vehicles under Minn. Stat. § 65B.49, subd. 5a, not UM/UIM coverage, based on the plain statutory language and the 1985 legislative amendments narrowing UM/UIM coverage to tie it to specifically insured vehicles rather than individuals.

business & regulatorytorts & liability

This case involves residents living near a Ramsey County compost site in Maplewood, Minnesota, who sued the county for nuisance and negligent failure to warn, alleging that operations from 1984 to 1996 produced foul odors and exposed them to harmful bioaerosols, interfering with their property use and causing health issues. The county had exceeded its permitted capacity of 9,000 cubic yards under MPCA rules and faced restrictions in conditional use permits from the city regarding grass clippings and odors. The Minnesota Supreme Court affirmed the denial of official immunity on the nuisance claim but reversed on the negligent failure to warn claim, reasoning that the county's discretionary decisions regarding site operations did not shield it from nuisance liability while immunity applied to the failure-to-warn allegations.

environmentpropertytorts & liability

In Peterson v. BASF Corp., a nationwide class of farmers sued BASF alleging that its marketing of the herbicides Poast and Poast Plus violated the New Jersey Consumer Fraud Act by misleading farmers into believing Poast Plus could not be used on minor crops like sugar beets, thereby inducing purchases of the higher-priced Poast. The trial court certified the class, applied New Jersey law, rejected federal preemption defenses, and entered judgment for the farmers, which the court of appeals affirmed. On appeal, the Minnesota Supreme Court affirmed, holding that class certification and application of New Jersey law were proper, that FIFRA did not preempt the consumer fraud claims because they concerned marketing rather than labeling, and that the evidence was sufficient to establish a violation under the NJCFA. The court reasoned that BASF's strategy of limiting Poast Plus labeling to major crops while promoting Poast for minor crops supported the fraud findings and resulting damages.

business & regulatoryfederal power

The case involves appellant Ronald Lewis Greer, who was convicted of first- and second-degree murder and sought postconviction relief based on claims of judicial bias by the trial judge, including alleged ex parte contacts with the jury and statements from former law clerks indicating the judge denied defense challenges for cause out of anger. Greer had previously raised similar bias and recusal issues multiple times, leading to a remand for a Schwartz hearing that found no improper influence on the verdict. The Minnesota Supreme Court affirmed the denial of relief, holding that the new claims were not novel and were barred by the Knaffla doctrine because they related to prior allegations of bias that had already been reviewed and rejected, and that adverse rulings alone do not establish bias.

criminal lawprocedure

This case concerned criminal misdemeanor charges against a corporate CEO for alleged building code violations involving grading and drainage at a residential development, where the work had been performed by independent subcontractors. The district court convicted the defendant under the responsible corporate officer doctrine, treating the violation as a strict liability public welfare offense, and the court of appeals affirmed. The Minnesota Supreme Court reversed, holding that Minn. Stat. § 16B.69 is not a public welfare or strict liability statute because violations can result in imprisonment and carry moral condemnation, meaning a mens rea element is required. The court therefore did not reach the question of liability under the responsible corporate officer doctrine and vacated related findings.

criminal lawbusiness & regulatory

This case involved a workers' compensation claim by Dale Banken for two separate injuries from different employers, leading to a dispute between the employers and their insurers over contribution and reimbursement. The compensation judge awarded attorney fees including an additional amount under Minn. Stat. § 176.081, subd. 7, allocating responsibility between the parties. The Workers’ Compensation Court of Appeals reversed the subdivision 7 fees, but the Minnesota Supreme Court reversed that decision and reinstated the award. The court reasoned that under precedent like Irwin v. Surdyk’s Liquor, the additional fees apply even when base fees are awarded pursuant to Minn. Stat. § 176.191 in disputes primarily between employers and insurers.

labor & employmentprocedure

In Miller v. One 2001 Pontiac Aztek, the appellant faced forfeiture of her vehicle after two DWI convictions within a year, which qualified as a first-degree DWI offense under Minnesota statutes allowing seizure of vehicles involved in designated offenses. The district court partially granted relief by limiting forfeiture to $1,000 based on her financial hardship, but the court of appeals reversed, ruling that personal financial circumstances are irrelevant and that the forfeiture was not grossly disproportionate to the offense. The Minnesota Supreme Court affirmed, applying the gross disproportionality test from United States v. Bajakajian and the Solem factors, and held that the forfeiture did not violate the Excessive Fines Clauses of the U.S. or Minnesota Constitutions. The court declined to incorporate the appellant's financial situation as a factor in the analysis.

criminal lawproperty

The case involved respondent John Colosimo's conviction under Minnesota statute for refusing a conservation officer's request to inspect his boat for fish after a fishing trip on Rainy Lake. The district court found him guilty following a bench trial, but the court of appeals reversed, holding that the officer needed probable cause to request the inspection and that the approach amounted to an unlawful stop. The Minnesota Supreme Court reversed the court of appeals, reinstating the conviction. It reasoned that the officer's initial approach and conversation did not constitute a seizure, and once the officer confirmed the group had been fishing and was transporting fish, state law authorized inspection of the boat without probable cause.

criminal lawcivil rightsenvironment

The case involved a workers' compensation dispute between Duder and McGlynn Bakeries, Inc. The Minnesota Supreme Court reviewed a decision from the Workers’ Compensation Court of Appeals dated June 11, 2003. The court affirmed that decision without issuing its own opinion. The affirmation was based on the files, records, and proceedings in the case and was issued under Minn. R. Civ. App. P. 136.01.

labor & employment

In State v. Miller, the defendant was convicted by a jury of first- and second-degree murder for the 2001 killing of Wendy Bozeman, whose dismembered remains were discovered in a Minneapolis park, and was sentenced to life in prison. On appeal, Miller argued that the trial court erred by admitting DNA evidence obtained through PCR-STR testing along with related statistical match probabilities, as well as testimony about a list of his sexual partners and a plastic sex toy found in his possession. The Minnesota Supreme Court affirmed the convictions, holding that the DNA evidence fell within the court's established exception to limits on statistical probability evidence and that admission of the other items did not constitute reversible error. The court also rejected Miller's claims of ineffective assistance of counsel.

criminal lawprocedure

In State v. Henning, a driver whose vehicle displayed special WZ-series plates (issued after prior license revocation for DUI) was stopped solely based on those plates under Minn. Stat. § 168.0422, leading to charges for driving after revocation and related offenses; the driver challenged the stop as lacking reasonable suspicion and the statute as unconstitutional. The Minnesota Supreme Court reversed the Court of Appeals, holding that the statute violates the Fourth Amendment and the Minnesota Constitution by authorizing suspicionless stops. The court's core reasoning was that displaying the plates does not constitute valid consent to such stops, that the statute cannot override constitutional protections against unreasonable seizures, and that no other basis for the stop existed in this case.

criminal lawcivil rights

This case involved former employee Sharon Langeslag suing her employer KYMN Inc. and owner Wayne Eddy for breach of contract, whistleblower statute violations, MHRA claims including sexual harassment and reprisal, and other employment-related issues, while Eddy counterclaimed for intentional infliction of emotional distress, defamation, and interference with contract. After a jury found for Eddy on the counterclaims and awarded $535,000 in damages for IIED, and the district court and court of appeals upheld the verdict, the Minnesota Supreme Court reversed on the IIED claim. The court held that the counterclaim should not have gone to the jury because the alleged conduct was not extreme and outrageous as a matter of law, Eddy failed to present evidence of severe emotional distress such as medical testimony, and the large damages award lacked any probative support like economic losses.

labor & employmentcivil rightstorts & liability

This case concerned the interpretation of a 1995 agreement and subsequent lease between Alpha Real Estate and Delta Dental/Sui Generis for a dental clinic property, including an option to purchase and a clause requiring additional rent of five percent of adjusted cash receipts above $1 million for the first ten years. Alpha sought specific performance of the purchase option, but Sui Generis conditioned it on continued payment of the additional rent after closing. The district court construed the documents together and held that the additional rent obligation survived the option closing while also finding no violation of federal or state law; the court of appeals affirmed under a narrow scope of review. The Minnesota Supreme Court reversed in part, holding that the lease's merger clause prevented incorporating the 1995 agreement's survival language, so the additional rent clause did not survive closing, and remanded the legality question for de novo review as a question of law.

propertybusiness & regulatoryprocedure