Peter M. Keith

This case concerns the classification and valuation of the Oak Ridge Conference Center for real estate tax purposes, where American Express challenged the tax court's assessment of the property at $27,300,000 using only the cost approach after classifying it as special purpose. The Minnesota Supreme Court held that the tax court's classification of the facility as special purpose property was clearly erroneous and that its exclusive reliance on the cost approach was an abuse of discretion, given the availability of data for an income approach and the fact that the property was not special purpose. The court further reasoned that the tax court had incorrectly estimated value based on value-in-use rather than market value. However, the court affirmed the tax court's use of reproduction cost, inclusion of certain cost categories, and valuation of the site as though vacant.

taxesproperty

This case concerns a challenge by waste collection companies to a sanitary district's tax and subsidy system used to fund a solid waste processing facility and reduce tipping fees. The Minnesota Supreme Court held that the arrangement does not violate the Dormant Commerce Clause because it imposes no differential burden on out-of-state commerce and lacks discriminatory purpose. The court reasoned that any incidental burden on interstate commerce is outweighed by the local benefits of the environmental programs funded by the tax. The decision reverses the lower courts' rulings on discriminatory effect and remands the case.

environmentbusiness & regulatoryfederal powertaxes

In State v. Robinson, the Minnesota Supreme Court considered whether the state had jurisdiction under Public Law 280 to prosecute an enrolled member of the Leech Lake Band of Chippewa Indians for underage alcohol consumption, failure to yield to an emergency vehicle, and fleeing a police officer, all occurring on the reservation. The district court dismissed the consumption and failure-to-yield charges as civil/regulatory rather than criminal/prohibitory and dismissed the fleeing charge for lack of probable cause. The court reversed in part and affirmed in part, applying a two-step version of the Cabazon test to classify the laws by determining whether the relevant conduct was generally prohibited or permitted subject to regulation and by examining the state's public policy concerns.

criminal lawfederal power

The case involved whether the State of Minnesota had jurisdiction to enforce various traffic and driving-related laws against members of the White Earth Band of Chippewa Indians for violations occurring within the boundaries of their reservation. The Minnesota Supreme Court affirmed the lower courts' dismissal of the charges, holding that the state lacked jurisdiction under Public Law 280. The court reasoned that the laws in question were civil/regulatory rather than criminal/prohibitory in nature, as they did not prohibit conduct but instead regulated it, and there were no exceptional circumstances justifying state enforcement without express federal authorization.

criminal lawfederal power

This case involved a dispute over modifying a spousal maintenance award in a divorce proceeding. After the original 1983 dissolution judgment provided Sandra Hecker with temporary maintenance of $800 per month for 121 months, she moved in 1993 to increase the amount and make it permanent, citing her failure to complete vocational training and become self-supporting due to child-rearing responsibilities. The district court granted the modification, awarding $2,000 per month permanently, and the Minnesota Supreme Court affirmed, reducing it to $1,375 per month. The court reasoned that Sandra's unexpected failure to rehabilitate during the temporary period constituted a substantial change in circumstances that rendered the original award unreasonable and unfair under the modification statute, consistent with precedents like Nardini v. Nardini. The decision emphasized the parties' stipulation for temporary maintenance while recognizing the recipient's duty to make reasonable efforts toward self-sufficiency.

family law

The case involved Minnegasco, a natural gas utility, challenging a 1993 rate order from the Minnesota Public Utilities Commission that imputed goodwill revenue from an affiliate and allocated certain costs, resulting in a lower approved rate increase than requested. After a related decision (MAC) held that the Commission lacked statutory authority for imputing such revenue, the court of appeals ruled that the Commission could not retroactively modify the final rate order even on remand. The Minnesota Supreme Court reversed, holding that the Commission has implied authority under the utility statutes to order revenue recoupment to compensate Minnegasco for losses from the unlawful imputation. The core reasoning was that the overall structure of chapter 216B supports providing a meaningful remedy for the Commission's overreach, and a superseding rate order does not eliminate that authority on remand.

business & regulatoryprocedure

In State v. Griese, the defendant was convicted by a jury of two counts of first-degree murder for the 1995 stabbing deaths of his tenants, Thomas Trafton and Susan Bishop, over disputes involving unpaid rent. On appeal, Griese challenged the trial court's limits on expert testimony regarding his mental condition and intoxication, alleged prosecutorial misconduct in witness questioning and closing arguments, the dismissal of second-degree murder counts from the indictment, and the sufficiency of evidence showing premeditation. The Minnesota Supreme Court affirmed the convictions, holding that the evidentiary rulings were proper, any errors did not prejudice the outcome, the indictment dismissals were not reversible, and the evidence supported findings of premeditation based on the circumstances and Griese's statements and actions. The court rejected claims of insufficient evidence and found no basis for a new trial.

criminal lawprocedure

The case concerned four related companies in the three-dimensional photography business that sued 3M in Texas state court for breach of express and implied warranties after a defective emulsion and backcoat sauce caused photographs to fade, leading to lost profits and business failure. Two of the plaintiffs had not directly purchased or acquired the 3M products. The Texas Supreme Court certified questions of Minnesota law to the Minnesota Supreme Court, which answered that under Minn. Stat. § 336.2-318, a seller is not liable to a non-acquiring party for pure economic damages unaccompanied by personal injury or property damage, and that multiple such parties therefore cannot recover lost profits jointly as a single economic unit. The court based its holding on the statute's text and legislative history, prior Minnesota precedent such as Hydra-Mac, Inc. v. Waycrosse, Inc., and the distinction between warranty claims involving physical harm and those seeking only economic loss.

business & regulatoryprocedure

This case involved a dispute over whether insurance companies must cover cleanup costs and legal defense for environmental contamination at a former tar refining plant in Minnesota that became a Superfund site. Domtar sued its primary and excess insurers from 1956-1970 after the state pollution agency demanded response actions, claiming breach of the duty to defend and seeking indemnification. The trial court allocated cleanup costs pro rata based on the years each policy was in effect, held the insurers liable for defense and litigation costs, and the court of appeals affirmed. The Minnesota Supreme Court affirmed those rulings but reversed the award of defense costs incurred before Domtar formally requested a defense from the insurers, applying policy terms and prior precedent on expected versus unexpected damage.

environmentbusiness & regulatorytorts & liability

The case involved a challenge by Douglas Schaller to Blue Earth County's construction of County State Aid Highway 90, specifically the segment crossing a ravine on his family homestead, under the Minnesota Environmental Rights Act (MERA). Schaller alleged two counts: projected traffic noise exceeding state standards by 2010, and material adverse effects on natural resources including wildlife habitat, forest, quietude, and historical features of the Century Farm. The district court granted summary judgment to the county on the noise count and dismissed the resources count after a hearing; the court of appeals affirmed, and the Minnesota Supreme Court also affirmed. The court held that Schaller failed to establish a prima facie case that noise violations were likely under MERA and that the resource impacts, including roadkill and forest fragmentation without affecting rare species, did not constitute a material adverse effect on the environment.

environment

The case involved a negligence lawsuit by the widow of Patrick Denais against Hennepin County and its psychiatrist Dr. Keith Horton, alleging that the county mental health center failed to hospitalize Denais or properly monitor his depression and suicide risk after he sought treatment in 1993, leading to his suicide at home. The Minnesota Supreme Court affirmed the court of appeals' reversal of the trial court's dismissal, holding that the defendants were not protected by statutory immunity under Minn. Stat. § 466.03, subd. 6, or official immunity. The court reasoned that while broad policy decisions about providing mental health services may be discretionary, the specific treatment decisions here—such as not hospitalizing the patient and prescribing medication with follow-up—were professional judgments implementing established policy rather than protected discretionary functions, and extending immunity would create unequal liability between public and private medical providers.

torts & liabilityhealthcare

The case involved Nancy Irene Fitzgerald's conviction for boarding unlicensed dogs and failing to clean up dog waste. She appealed arguing that police made an unlawful warrantless entry into her home, leading to an invalid search warrant based on that entry. The state claimed the entry was justified by an emergency exception due to a report that the occupant might need help. The court concluded the state failed to prove an emergency, noting the informant waited until the next day to report and the information did not indicate urgency, and therefore reversed the court of appeals' decision affirming the convictions while remanding for the trial court to assess whether other independent information supported the warrant.

criminal lawprocedure

This case concerned the effect of a Schmidt v. Clothier substitution by an underinsurer on its separate liability for uninsured motorist coverage. After Gusk was injured in an accident involving both an uninsured and an insured driver, he reached a tentative settlement with the insured driver's insurer, which Farm Bureau substituted with its own payment to preserve subrogation rights. Following a trial where the jury awarded damages resulting in Farm Bureau owing less than the substitution amount overall, the lower courts rejected Farm Bureau's claim that the substitution offset its uninsured motorist obligations. The Minnesota Supreme Court affirmed, holding that the substitution payment as underinsurer does not affect the insurer's contractual duty to provide uninsured motorist benefits, as these coverages are independent.

torts & liabilityprocedure

The case concerned whether the City of Eagan, a statutory city without a home rule charter, could impose a road unit connection charge on all building permits to fund major street improvements prompted by new development. Homebuilding contractors challenged the charge as unauthorized and sought refunds. The district court upheld the city's authority under its police and planning powers, but the court of appeals reversed. The Minnesota Supreme Court affirmed, holding that statutory cities possess only powers expressly granted by statute or necessarily implied, and no Minnesota statute authorized such a road impact fee—unlike specific provisions for water and sewer charges—making the fee an invalid exercise of municipal authority rather than a permissible regulatory measure.

business & regulatorytaxes

This case involves a products liability lawsuit by Kyle Olson against Ford Motor Company, alleging that a defective seat belt in his 1985 truck contributed to his injuries in a 1993 car accident under the crashworthiness doctrine, with claims based on strict liability, negligence, and breach of warranty. The U.S. District Court certified a question to the Minnesota Supreme Court on whether Minnesota's seat belt gag rule, Minn. Stat. § 169.685, subd. 4, bars introduction of evidence of the plaintiff's seat belt use in such an action. The court answered the certified question in the affirmative, holding that the statute prohibits such evidence. The core reasoning is that the statute's plain language unambiguously bars proof of seat belt use or nonuse in any litigation involving personal injuries resulting from motor vehicle operation, with no exception for crashworthiness claims involving alleged seat belt defects, consistent with prior precedent and the absence of legislative action to amend it.

torts & liabilityprocedure

This case concerned whether a judgment entered after mandatory nonbinding arbitration under Minn. Gen. R. Prac. 114.09 could be vacated for excusable neglect under Minn. R. Civ. P. 60.02. After an arbitrator awarded Nguyen underinsured motorist benefits from State Farm following a car accident, State Farm's counsel served but failed to file a timely request for trial de novo due to a clerical error; the trial court then entered judgment on the award and denied State Farm's motion to vacate. The Minnesota Supreme Court reversed, holding that Rule 60.02 relief remains available because the rules are not in irreconcilable conflict and long-standing policy protects innocent clients from their counsel's excusable neglect when the Finden factors are met. The court therefore vacated the judgment and allowed the case to proceed to trial.

proceduretorts & liability

The case involved a passenger with fibromyalgia who alleged that Northwest Airlines violated the federal Air Carriers Access Act by refusing assistance with carry-on baggage and also asserted a state common-law negligence claim for resulting injuries. The district court granted summary judgment to the airline, finding the ACAA claim time-barred under the one-year MHRA limitations period and the negligence claim preempted by the MHRA. The court of appeals reversed on both points, applying a six-year personal-injury statute of limitations and holding the negligence claim survived. The Minnesota Supreme Court reversed again on the ACAA claim, reasoning that the most analogous state limitations period is the MHRA's one-year period for disability discrimination, but affirmed that the common-law negligence claim is not preempted because it rests on independent duties owed by common carriers to disabled passengers.

civil rightsproceduretorts & liabilitybusiness & regulatory

The case involved Dakota County's petition to involuntarily terminate the parental rights of Aveiy Hobbs and Tamara Growette with respect to their child D.D.G., based on allegations of substance abuse, domestic violence, and related criminal conduct that led to the child's placement with grandparents. The mother's rights were terminated by default, and Hobbs initially consented on the record to voluntary termination during the hearing, acknowledging it was in the child's best interests and that the decision was final. Hobbs later moved to vacate the termination order, arguing his consent was not knowing or voluntary, but the trial court denied the motion. The Minnesota Supreme Court reversed the court of appeals and upheld the termination, reasoning that the record contained ample evidence that Hobbs' consent was knowing, voluntary, and supported by good cause under the statute.

family lawprocedure

The case involved the civil commitment of Dennis Darol Linehan under Minnesota's Sexually Dangerous Persons Act after his criminal sentence for sex-related crimes was nearing completion. Linehan challenged the constitutionality of the Act on grounds of substantive due process, equal protection, ex post facto laws, and double jeopardy, and also disputed the sufficiency of evidence predicting his future dangerousness due to his antisocial personality disorder. The Minnesota Supreme Court affirmed the commitment, holding that the Act is constitutional and that the district court did not err in finding it highly probable that Linehan would engage in harmful sexual conduct in the future based on his history and mental disorder.

criminal lawcivil rights

This case involves Dennis Darol Linehan's challenge to his final indeterminate commitment under Minnesota's Sexually Dangerous Persons Act following a required 60-day review hearing after his initial commitment. The district court found clear and convincing evidence that Linehan continued to meet the SDP criteria based on expert testimony regarding his personality disorders and high risk of reoffending. Linehan contended that the review hearing should permit relitigation of the initial commitment order and that clinical predictions of future dangerousness were too unreliable. The Minnesota Supreme Court affirmed, holding that the review hearing is limited to assessing whether the committed person's condition has changed since the initial order and that the evidence was sufficient where Linehan did not show any change and the court properly discounted non-new expert testimony on prediction accuracy.

criminal lawprocedure