Glenn E. Kelley

This case involved whether vehicle searches by private security guards at the Brainerd International Raceway, which uncovered drugs and other contraband later used in criminal prosecutions, qualified as governmental action subject to Fourth Amendment limits on unreasonable searches. The trial court found the searches to be purely private and denied suppression of the evidence, but the court of appeals reversed, concluding there was enough government involvement to trigger constitutional scrutiny. The Minnesota Supreme Court reversed the court of appeals and reinstated the trial court's rulings, holding that the question of governmental involvement is a factual determination for the trial court and that its finding of insufficient involvement here was not clearly erroneous. The court noted that the security company had a contract with the private racetrack operator, its guards were mostly not police officers, and any coordination with law enforcement was limited to procedural reporting rather than direction or participation in the searches.

criminal lawcivil rightsprocedure

This case arose from a legal malpractice suit in which the Shetka plaintiffs sought to add punitive damage claims against a law firm and its individual partners based on alleged misconduct by one partner, T. Jay Salmen, during bankruptcy-related advice, and then to discover the personal financial assets of the other partners to support those claims. The trial court permitted the amendment and ordered the discovery, but the Minnesota Supreme Court reversed and directed issuance of a writ of prohibition barring enforcement of the discovery order. The court held that Minnesota statutes require prima facie evidence of willful indifference by a defendant before punitive damages may be asserted or related financial discovery allowed, and that vicarious liability of non-participating partners for another partner's acts does not meet this threshold absent any evidence of the firm's or other partners' own willful conduct.

proceduretorts & liability

This case involved an appeal of a continuation of a commitment for a person found to be mentally ill and dangerous (MID) under Minnesota law. The district court determined that DeWayne Colbert remained mentally ill due to paranoid schizophrenia but was no longer dangerous while taking medication, ordering his transfer to the Anoka Metro Regional Treatment Center. The court of appeals reversed, concluding the district court clearly erred in finding no ongoing danger. The Minnesota Supreme Court reversed the court of appeals and reinstated the district court's decision, holding that the evidence did not compel a finding of dangerousness under Minn. Stat. § 253B.02, subd. 17, which requires clear and convincing proof of a substantial likelihood of future acts causing serious physical harm.

criminal lawprocedurehealthcare

In Benson v. Northern Gopher Enterprises, Inc., a tenant sued the owner and manager of an apartment building for personal injuries allegedly caused by carbon monoxide fumes infiltrating her unit from an underground parking garage. The plaintiff relied primarily on an expert witness to link the fumes to the garage, but the trial court excluded the opinion for lack of foundation and entered summary judgment for the defendants. The Minnesota Supreme Court affirmed the trial court's rulings, concluding there was no abuse of discretion because the proposed testimony was speculative without evidence of elevated carbon monoxide levels in the garage during the time the plaintiff resided in the building. The court noted that decisions on the admissibility of expert evidence fall within the trial court's discretion on a case-by-case basis.

torts & liabilityprocedure

This case involved a farmer's lawsuit against a police officer under 42 U.S.C. § 1983 for alleged civil rights violations, along with related state tort claims, stemming from a late-night traffic stop that escalated into a vehicle chase and the use of force to effect an arrest. The trial court granted summary judgment to the defendants, the court of appeals reinstated the claims against Officer Van Hal, and the Minnesota Supreme Court reviewed that decision. The court reversed the reinstatement of the federal claims and most state claims against Van Hal, remanding only the state assault claim for trial. It reasoned that Van Hal reasonably relied on information from fellow officers regarding the initial stop and Johnson's flight, that his actions in stopping the vehicle and effecting the arrest did not constitute excessive force under the Fourth Amendment, and that the facts did not support the other tort claims.

civil rightscriminal lawproceduretorts & liability

The case involved Dennis Hannuksela's appeal from his conviction for the first-degree murder of Arthur Nelson, challenging the trial court's failure to suppress evidence from an allegedly invalid warrant, admission of his ex-wife's testimony about his observed acts and gestures during their marriage, and introduction of evidence regarding two prior aggravated forgeries he committed. The Minnesota Supreme Court affirmed the conviction, holding that none of the challenged rulings constituted reversible error. The court reasoned that the statutory marital privilege covers only confidential communications and does not extend to non-assertive conduct or gestures observed by a spouse, while the warrant and prior-crimes evidence were properly admitted under applicable standards.

criminal lawprocedure

This case arose from a contract for deed for farmland where the vendee defaulted on payments and other obligations, prompting the vendors to cancel the contract under Minn. Stat. § 559.21 and retain prior payments as liquidated damages. After repossessing the property, the vendors sued for waste to the real estate and conversion of farm machinery not described in the contract. The trial court granted summary judgment to the vendee on both claims under the election of remedies doctrine, but the court of appeals reversed. The Minnesota Supreme Court held that the waste claim did not survive cancellation because the vendors had already elected a remedy by canceling and retaining payments, reversing on that issue; however, the conversion claim could proceed to trial since the personal property was outside the contract and thus unaffected by the cancellation.

propertyproceduretorts & liability

In Aufderhar v. Data Dispatch, Inc., the plaintiff sued the defendants for negligence after a three-car accident, seeking damages for personal injuries, while also pursuing uninsured motorist benefits through arbitration with his insurer. The arbitration panel determined the plaintiff's damages to be $15,000 and apportioned fault among the drivers. The defendants then sought to bar relitigation of the damages amount in the negligence action. The Minnesota Supreme Court held that the plaintiff was collaterally estopped from relitigating damages, reasoning that the issue was identical to the one decided in the prior arbitration, there was a final judgment on the merits, the plaintiff was a party to the arbitration and had a full and fair opportunity to be heard, and Minnesota allows defensive non-mutual collateral estoppel.

proceduretorts & liability

The case involves a dispute over control of Vikings II, Inc., the corporate owner of the Minnesota Vikings NFL franchise, in which PJ Acquisition Corp. (a shareholder that acquired one-third of the voting shares in 1986) sued the company's officers and directors for alleged breaches of fiduciary duty, abuse of corporate control, excessive compensation, misuse of assets, and improper handling of stock rights of first refusal and employment contracts. The Minnesota Supreme Court affirmed the trial court's partial summary judgment dismissing all claims arising from events before July 21, 1986, including those related to the Mike Lynn employment contract and pre-acquisition misuse of corporate assets. The core reasoning was that PJ lacked standing to bring those claims directly, as they alleged injury only to the corporation itself rather than to PJ as a shareholder, making the action a derivative suit subject to the procedural requirements of Minn.R.Civ.P. 23.06.

business & regulatoryprocedure

In this case, International Harvester sued Onan Corporation for breach of warranties on engines incorporated into skid loaders purchased from Hydra-Mac, alleging repeated engine failures despite Onan's repair efforts and assurances. Onan defended by asserting warranty disclaimers in its invoices and arguing that the statute of limitations barred most claims. The Minnesota Supreme Court affirmed in part, reversed in part, and remanded, holding that the disclaimers did not apply to International Harvester, that Onan was estopped from raising the limitations defense based on its conduct, and that further proceedings were needed on lost profits.

business & regulatoryprocedure

This case involves a medical malpractice lawsuit brought by the trustee for the heirs of a patient who committed suicide while voluntarily admitted to a locked psychiatric ward at St. Mary's Hospital, after expressing severe depression and suicidal thoughts. The defendants sought to have the jury consider the patient's contributory negligence or assumption of risk under Minnesota's comparative fault statute, including a capacity-based instruction accounting for his mental illness. The Minnesota Supreme Court, answering a certified question, held that it was not error for the trial court to refuse to submit such an instruction to the jury. The court reasoned that in this specific situation—where the patient was hospitalized precisely to prevent suicide and the hospital knew of his ideations—the patient's capacity for self-care was transferred to the medical providers, distinguishing it from prior cases where mental illness was not the direct cause of the injury.

healthcaretorts & liability

This case involves a pretrial state's appeal of a trial court order suppressing statements made by defendant Ronnebaum in a prosecution for child sex abuse against his young niece. The Minnesota Supreme Court reversed the court of appeals' decision that the state had failed to show the suppression would have a critical impact on the prosecution's outcome, holding instead that the lack of the evidence would significantly reduce the likelihood of success. The court also ruled that the suppression order was erroneous because the defendant was not in custody during either interview and thus had no right to Miranda warnings or counsel, as the right to counsel had not attached prior to formal charges and the focus of an investigation alone does not trigger these protections. The matter was remanded for trial.

criminal lawprocedure

The case involved the Hennepin County Sheriff's Department implementing a revised grooming policy for uniformed personnel covering hair length, mustache length, and fingernail standards without prior negotiation with the union representing approximately 300 employees. The union sought an injunction, arguing that the policy concerned terms and conditions of employment requiring mandatory bargaining under the Public Employment Labor Relations Act, while the sheriff contended it fell under the statutory exclusion for inherent managerial policy. The trial court granted summary judgment to the sheriff, but the court of appeals reversed; the Minnesota Supreme Court reversed again, holding that the policy was an inherent managerial matter because it was designed to foster public respect and confidence essential to the sheriff's statutory law enforcement duties. The court remanded for reinstatement of the judgment in favor of the sheriff, noting that the union had conceded the employer's right to establish the policy and that only its implementation was at issue.

labor & employment

This case involved a divorced father's motion to modify the maintenance and child support obligations in a 1984 dissolution decree after his ex-wife remarried, increased her earnings as a realtor, and after federal tax laws changed in ways that eliminated prior advantages of labeling payments as maintenance. The trial court had refused to consider the tax law changes, recharacterized some maintenance as child support, and found no substantial change in circumstances warranting modification; the court of appeals affirmed. The Minnesota Supreme Court affirmed in part but reversed in part, holding that the wife's remarriage statutorily terminated maintenance and that the tax law changes plus her new income required reconsideration of the decree under modification statutes, and remanded for further proceedings applying the child support guidelines and all relevant factors.

family lawtaxes

The case involved a dispute over a $30,000 check payable to two joint payees, one of which (E.S.P., Inc.) had its endorsement forged when the check was deposited at First Bank; Midway, the payor bank, paid the check and was later sued for conversion by E.S.P. under the UCC. Midway then brought a third-party claim against First Bank for breach of the statutory warranty of title, seeking indemnity. The trial court and court of appeals held that the six-year statute of limitations for contract claims barred Midway's action because it began running at the time of the breach in 1981. The Minnesota Supreme Court reversed, holding that the claim was one for indemnity so that the limitations period did not commence until Midway sustained a loss by paying E.S.P., and therefore remanded for further proceedings.

business & regulatoryprocedure

This case involved a dispute between Flooring Removal, Inc. and defendants Dan T. Ryerson and Noah Williams and Associates over whether correspondence created an express trust requiring Ryerson to pay Flooring Removal funds received from Park Nursing Home for flooring work. The district court granted summary judgment to the defendants, but the court of appeals reversed, finding potential issues under promissory estoppel. The Minnesota Supreme Court reversed the court of appeals, holding that promissory estoppel was not raised or tried below and thus could not be considered on appeal, and that no genuine issues of material fact existed regarding the express trust claim, thereby reinstating the summary judgment for defendants.

procedurebusiness & regulatory

In this case, David Company contracted with Jim W. Miller Construction to build townhouses, but after completion of the first phase, numerous defects, code violations, and poor workmanship emerged, leading David Company to demand arbitration for breach of contract, negligence, and misrepresentation. The arbitrators awarded damages plus an order requiring Miller to purchase the property from David Company. The Minnesota Supreme Court affirmed the district court's confirmation of the award, holding that the arbitrators acted within the broad authority granted by the contract's arbitration clause, which covered all disputes arising from the contract. The court reasoned that the severity and extent of the defects, including unmarketable units and potential warranty liabilities, justified the remedy as within the arbitrators' powers rather than an excess thereof.

business & regulatorypropertyprocedure

The case involved members of the Old Order Amish religion who were cited for violating a Minnesota statute requiring slow-moving vehicles like their horse-drawn buggies to display a fluorescent orange-red triangular emblem on public highways. They argued that complying with the law conflicted with their religious beliefs about separation from the modern world and avoiding worldly symbols. The Minnesota Supreme Court held that the statute, as applied to these appellants, violated the Free Exercise Clause of the First Amendment because it burdened their sincerely held religious beliefs without a compelling justification that could not be met by less intrusive means. The court vacated the trial court's order and dismissed the charges. It did not reach the claim under the Minnesota Constitution.

criminal lawreligious liberty

This case is a marriage dissolution dispute in which the husband appealed a ruling that portions of an antenuptial agreement allocating both marital and nonmarital property were void. The court held that antenuptial contracts addressing marital assets are not invalid as a matter of law and may be enforced if they satisfy requirements of procedural fairness at formation and substantive fairness both at formation and at dissolution. It concluded that procedural fairness had been established through full disclosure of assets and the wife's opportunity to obtain independent counsel, but remanded for further findings on substantive fairness.

family lawproperty

The case concerned Everett Schmidt, a long-term patient at a state mental health facility, who challenged the constitutionality of Minn.Stat. § 253B.03, subd. 6a, governing the administration of neuroleptic medication to committed individuals. Schmidt argued that the statute violated his privacy and due process rights by failing to guarantee an adversarial court hearing and the right to counsel. After a Jarvis hearing, the district court authorized the medication and rejected the constitutional challenge. The Minnesota Supreme Court affirmed, concluding that the statute, when read together with existing court rules providing for appointed counsel and hearings, adequately protects patients' rights, and it exercised jurisdiction under the capable-of-repetition-yet-evading-review exception to mootness.

civil rightshealthcareprocedure