Fallon Kelly

In State v. Bettin, the defendant was acquitted of two counts of first-degree criminal sexual conduct but convicted by a jury of the lesser-included offense of third-degree criminal sexual conduct under Minn. Stat. § 609.344(c) (1978), which requires penetration by force or coercion, and was sentenced to up to 10 years in prison. The defendant appealed, arguing that the evidence of force or coercion was insufficient, that the trial court erred in allowing the state to impeach him with a prior rape conviction if he testified, and that a mistrial should have been granted due to the jury possibly seeing him handcuffed to a witness in prison attire. The Minnesota Supreme Court affirmed the conviction, holding that the complainant's testimony and corroborating evidence of injuries and semen were sufficient to support the verdict, that the prior conviction's probative value for credibility outweighed its prejudice under Minn. R. Evid. 609(a), and that any potential jury observation of restraints or attire did not warrant a mistrial. A dissent argued that the prior conviction, being for similar conduct without elements of dishonesty, should have been excluded to avoid undue prejudice.

criminal lawprocedure

The case involved a defendant convicted of possessing cocaine and a handgun without a permit after police stopped him based on a bulletin and searched his car, finding a gun under the seat and later cocaine. The defendant argued the evidence should be suppressed as the product of an illegal search. The Minnesota Supreme Court affirmed the convictions, holding that the officers had reasonable suspicion to stop the defendant and that the search under the car seat was a permissible protective frisk under Terry v. Ohio to ensure officer safety.

criminal lawprocedureguns

The consolidated cases involved negligence claims against the State of Minnesota arising from two pre-1976 traffic accidents allegedly caused by defective highway and bridge designs. In Peterson v. Stanek, the trial court dismissed the claims on governmental immunity grounds; in Anderson v. City of Minneapolis, the trial court granted judgment notwithstanding the verdict to the State after a jury found it 34 percent negligent. The Minnesota Supreme Court reversed both dispositions, holding that common-law state immunity for torts before August 1, 1976, did not bar suits where a highway plan was so obviously dangerous that no reasonable person would approve it. The court reasoned that exceptions previously recognized for municipal highway liability, as set out in Paul v. Faricy, applied equally to the State because no justification existed for treating state and local governments differently in this context.

torts & liability

The case involved defendant Clark's petition for post-conviction relief after his conviction for the first-degree murder of Barbara Jiminez, raising claims including improper admission of evidence from a related trial, suppression of discovery materials, unlawful arrest and searches, improper prosecutorial arguments, and insufficiency of the evidence. The district court denied relief on all grounds, and the Minnesota Supreme Court affirmed that order. The court held that the defendant's prior testimony from the related trial of the victim's husband was admissible, that a statement overheard by a sheriff was not improperly obtained, and that the evidence was sufficient to support the conviction because the circumstances were inconsistent with any rational hypothesis of innocence. Many other issues were resolved by reference to the companion case, Clark I.

criminal law

This case involved a paternity action in which a jury found the defendant to be the father of the plaintiff's child, leading to an order for support; the defendant appealed the denial of his post-trial motion, claiming that the trial judge's questioning of a key defense witness undermined the fairness of the trial. The Minnesota Supreme Court reversed the judgment and remanded for a new trial. The court reasoned that while judges may examine witnesses under the rules of evidence, they must exercise great caution in doing so when witness credibility is central, as the judge's actions here could have improperly influenced the jury on a disputed factual issue in a paternity case. The opinion also emphasized that blood tests, which were not used, would have reduced reliance on credibility assessments and might have avoided the need for reversal.

family lawprocedure

The case involved a defendant charged in a single prosecution with both an open bottle law violation and driving while under the influence arising from the same traffic incident. After the unrepresented defendant pleaded guilty to the open bottle charge and was sentenced, the trial court convicted him of DUI on stipulated facts but deferred sentencing. The Minnesota Supreme Court determined that the offenses arose from the same behavioral incident under Minn. Stat. § 609.035, barring multiple punishments, but held that the single prosecution permitted the DUI conviction to stand even though sentencing on it was prohibited. The court reversed the district court's order vacating the DUI conviction, reasoning that the defendant's guilty plea caused the fragmentation and the state was not engaging in serialized prosecution.

criminal lawprocedure

In State v. Wiberg, the defendant was convicted by a jury of knowingly receiving stolen property after police executing a search warrant found hundreds of stolen firearms in her home, along with additional guns in a shared closet and her handbag. On appeal, she challenged the admission of her affirmative response to an officer's question about ownership of the handbag shortly after she had invoked her Miranda rights, statements made during a later interrogation following a delay before arraignment, the reliability of the search warrant affidavit, the lack of a lesser-included-offense instruction, and the sufficiency of the evidence. The Minnesota Supreme Court reversed the conviction and remanded for a new trial, holding that the officer's question violated the requirement to scrupulously honor the defendant's right to remain silent under Miranda and Michigan v. Mosley, rendering admission of her response reversible error not shown to be harmless beyond a reasonable doubt. The court found no other grounds for reversal on the existing record, including that the arraignment delay did not exceed the 36-hour limit under the criminal rules.

criminal lawprocedure

This case concerned whether Continental Can Co. violated the Minnesota Human Rights Act by discriminating against employee Willie Ruth Hawkins on the basis of sex through inadequate response to sexual harassment by male coworkers, which allegedly led to her constructive discharge. The hearing examiner found two unfair discriminatory practices and awarded back pay (with reductions), but the district court reversed. On appeal by the Department of Human Rights, the court reviewed the record under the substantial evidence standard of the Minnesota Administrative Procedure Act and determined that the examiner's findings of sex-based discrimination in employment conditions were supported by the evidence of repeated derogatory remarks, physical advances, and the employer's delayed or insufficient actions.

labor & employmentcivil rights

This case involved a dispute over whether an insurance beneficiary was entitled to accidental death benefits after the insured died by drowning in a bathtub following a rupture of a brain aneurysm that caused her to lose consciousness and fall. The trial court awarded the $5,000 accidental death benefit, finding the death was accidental and the aneurysm was not a contributing bodily disease or infirmity under the policy exclusion. On appeal, the Minnesota Supreme Court affirmed, holding that while the aneurysm qualified as a disease, it contributed to the accident but not directly to the death by drowning, making the exclusion inapplicable as the policy's exclusion for disease applied to causes of death rather than remote causes of the accident. The court reasoned that the immediate cause was drowning, an accidental event, and the aneurysm's role was too remote to trigger the exclusion.

business & regulatory

The case involved the City of Minneapolis seeking to enjoin an adults-only bookstore from operating in violation of zoning ordinances that prohibit such businesses within 500 feet of residential districts or other similar establishments. The district court denied injunctive relief, finding that criminal penalties like fines or jail time provided an adequate remedy at law. The Minnesota Supreme Court reversed, holding that under state statute, municipalities may enforce zoning ordinances by injunction, and that repeated prosecutions are inadequate for achieving compliance with continuing violations, thus mandating injunctive relief.

business & regulatoryprocedure

In State v. Adams, the defendant was convicted of third-degree felony murder after participating in an attempted robbery during which the victim was fatally shot, and he was sentenced to an extended 40-year term as a dangerous offender under Minnesota statutes based on prior felony convictions. The defendant appealed, arguing that the trial court wrongly denied a lesser-included-offense instruction, that accomplice testimony lacked sufficient corroboration, that the dangerous-offender statute was unconstitutionally vague, and that hearsay evidence was improperly admitted at the sentencing hearing while the court's dangerousness findings were erroneous. The Minnesota Supreme Court affirmed both the conviction and the sentence, holding that the evidence supported the jury's verdict, the statute's requirements were satisfied by the presentence investigation and court findings, and the sentencing procedures complied with statutory notice and hearing rules.

criminal lawprocedure

In State v. Gatlin, the defendant was convicted by a jury of kidnapping, first-degree criminal sexual conduct, and aggravated robbery, and he appealed his convictions and sentences. The Minnesota Supreme Court affirmed the judgment, holding that the defendant failed to prove a systematic policy of excluding Black jurors via peremptory challenges, that the challenged evidence—including Spreigl evidence of prior similar misconduct, police photographs, and a victim's prior statement to police—was properly admitted, and that the sentencing issue regarding consecutive terms could be raised separately in the trial court. The court reasoned that the Spreigl evidence established a relevant pattern of conduct, the photographs were not prejudicial given other evidence of prior crimes, and the victim's statement was admissible to corroborate her identification rather than as hearsay. The court also noted that the defendant did not raise the sentencing claim at trial.

criminal lawprocedure

This case arose from a 1976 collision on a snowy highway between a car carrying passenger Margaret Byrns and a county snowplow driven by Irving Johnson, in which Byrns sustained neck injuries and sued the county and Johnson for negligence. The jury found the snowplow driver non-negligent and the car driver negligent but not a direct cause of the accident, leading the trial court to enter judgment for the defendants. On appeal, the Minnesota Supreme Court reversed and remanded for a new trial, holding that the trial court erred by refusing to instruct the jury on the emergency doctrine applicable to the car driver and on concurring causation, and that defense counsel made improper closing arguments that appealed to the jurors' self-interest as taxpayers. These combined irregularities, in the context of sharply disputed facts about which vehicle crossed the centerline, required a retrial.

torts & liabilityprocedure

The case involved a defendant convicted by a jury of four prostitution-related offenses under Minnesota statutes, including inducing a person under 18 to practice prostitution, keeping a place of prostitution, transporting a prostitute, and bringing a prostitute to another person, based on evidence that he solicited a 14-year-old runaway to live with him and work as a prostitute. The court affirmed three convictions but vacated the transporting conviction as superfluous because it arose from the same act as the bringing conviction and did not affect the sentence. The court reasoned that evidence of guilt was overwhelming, prosecutorial comments in closing argument were improper but nonprejudicial, issues regarding a seized gun and witness competency lacked merit or were forfeited for lack of objection, and the evidence was sufficient for the remaining convictions.

criminal lawprocedure

The case arose from a 1974 car accident in which plaintiff Lillian Pietrzak was injured when defendant Bennie Eggen failed to stop at a stop sign and collided with the vehicle driven by her husband, who was also found negligent. Plaintiff sued for negligence, and after a jury awarded $5,000 in damages (increased by additur to $10,000), she appealed the trial court's refusal to instruct the jury on future knee reconstructive surgery costs. The Minnesota Supreme Court reversed and remanded for a new trial on damages, holding that medical testimony established to a reasonable certainty that future surgery was more likely than not to be needed, making the issue appropriate for jury consideration alongside related pain and earning capacity claims.

torts & liabilityprocedure

This case arose from a 1972 car accident in Minnesota in which plaintiff Zahler was injured; after failed settlement talks, he attempted in 1978 to sue defendants Manning and Smith by serving the Commissioner of Public Safety under the nonresident motorists statute, Minn. Stat. § 170.55. The defendants moved to dismiss for insufficient service of process, arguing they were Minnesota residents at the time of the accident and had not been continuously absent from the state. The district court denied the motion, but the Minnesota Supreme Court reversed, holding that the statute permits substituted service only on nonresidents or residents absent for six months or more and does not apply to residents like Manning or to a deceased resident like Smith. The court reasoned that the statute's plain language and purpose limit its reach to those who cannot be located through ordinary means, and no evidence showed the defendants met those criteria. The ruling left open whether the statute of limitations barred any further action against the defendants or their insurer.

proceduretorts & liability

A law firm sued to foreclose an attorney's charging lien on a patent owned by the defendant, claiming the lien arose from legal work on the patent application filed with the U.S. Patent Office. After a trial, the district court held that the lien attached to the patent and ordered its sale to cover the fees, denying the defendant's motion for a new trial. On appeal, the Minnesota Supreme Court affirmed, ruling that the lien under Minn. Stat. § 481.13 applied. The court reasoned that the statute's reference to a "proceeding" is broad enough under its ordinary meaning to encompass the nonjudicial process of applying for a patent before the Patent Office, and that the patent constituted property involved in or affected by that proceeding.

propertyprocedure

In this case, John and Mary Guildner sued First Federal Savings & Loan to declare a 1970 note and mortgage on commercial property void as usurious under the interest rate limits then in effect, after defaulting on payments; First Federal counterclaimed and filed a separate foreclosure action. The trial court granted summary judgment to the Guildners, finding the loan usurious and First Federal not exempt as a mutual building association. On appeal, the Minnesota Supreme Court reversed, holding that Minn. Stat. § 334.011 (enacted in 1977), which permits higher interest rates on business loans, applies retroactively to validate the transaction. The court reasoned that usury laws are penal in nature, so any forfeiture right does not vest until reduced to final judgment, consistent with its prior decision in United Realty Trust v. Property Development & Research Co., and the Guildners had not obtained such a judgment before the statute took effect.

business & regulatoryproperty

The case involved the City of Shakopee petitioning to condemn a strip of land for a street easement across parcels in which the Metropolitan Waste Control Commission (MWCC) held an interest for a planned sludge disposal site. The MWCC had exercised purchase options on the land before the condemnation petition was filed but was not initially named in the proceeding. The trial court authorized the condemnation after finding the MWCC lacked a sufficiently certain future public use, but the Minnesota Supreme Court reversed. The court determined that the parcels qualified as public property at the time of filing due to the MWCC's equitable interest from exercised options and held that the city's general eminent domain powers did not include an implied authority to condemn such land under these circumstances, given the MWCC's present need and proposal for public use.

propertyenvironment

The cases involved individuals held under emergency orders pursuant to Minn. St. 253A.07, subd. 3, pending hearings on petitions to commit them as mentally ill, who challenged the constitutionality of the statute, sought class certification for their claims, and raised related procedural issues including the authority of probate referees to issue hold orders. The district court denied class certification and dismissed the actions of Mary Doe and Jane Doe; it also denied Douglas Vinge's habeas petition, but the supreme court reversed on the constitutional question while affirming the dismissals. The court reasoned that the statute's procedures for pre-hearing confinement violated due process because they permitted extended detention without a prompt probable cause determination, though the statute could operate constitutionally if a full hearing or equivalent probable cause hearing occurred within 72 hours, and it exercised supervisory authority to require such interim hearings; it also upheld the referees' authority to issue hold orders and found the individual claims moot after the underlying commitment petitions were dismissed.

civil rightshealthcareprocedure