Oscar R. Knutson

This case involved a dispute over compensation for land taken by the City of Bloomington to build a street. Brooks Investment Company purchased property from the Berglunds in 1969 after the city had already constructed the street across part of the lots without formally acquiring title or an easement. The city later initiated condemnation proceedings but named only the Berglunds as owners, paid them the award, and provided no notice to Brooks despite the recorded deed. Brooks sued the city to recover the compensation, and the court held that Brooks, as the record owner at the time of the condemnation proceeding and award, was entitled to the proceeds because the prior owners had not reserved any rights to them in the sale. The decision rested on the principle that entitlement to condemnation awards follows ownership at the time of the formal proceeding rather than the date of physical appropriation.

property

The case concerned a dispute between an insured individual (Knowlton), his former attorney (Paulos), and the disability insurer (Continental Casualty) over entitlement to future monthly benefits following a lump-sum settlement of a policy claim arising from an auto accident. After Knowlton settled his claim against Continental for past benefits and the action was dismissed, the attorney asserted a 40% contingent fee on all future payments and requested that checks be issued jointly. The trial court ruled in favor of the attorney, and the Minnesota Supreme Court affirmed, holding that the contingent fee contract covered ongoing benefits, that the fee was reasonable based on the services provided and results obtained, and that the statutory exemption for accident and disability insurance proceeds did not bar enforcement of the attorney's lien.

business & regulatoryprocedure

This case arose from a nighttime automobile collision in Minneapolis between a vehicle driven by defendant Lorraine Bush (making a left turn) and one driven by Byron Deegan carrying passengers John Wadena and David Deegan, leading to consolidated actions for damages and contribution among the parties. A jury apportioned 55% of the negligence to Bush and 45% to Deegan and awarded damages accordingly, resulting in judgments that Bush appealed. The main issue on appeal concerned the trial court's pretrial rulings excluding from hospital emergency room records certain notations describing the Deegan parties as "drunk," "intoxicated," or involved in "disorderly conduct," as well as a blood-alcohol test result. The court held that these entries were properly excluded because they constituted prejudicial hearsay not related to medical treatment and fell outside the scope of the Uniform Business Records as Evidence Act, while also addressing right-of-way and speed rules applicable to the drivers.

torts & liabilityprocedure

This case involved a dispute between owners of adjoining rural land in Winona County over the construction of a boundary fence. Appellant built the fence, entered respondent's property to cut trees, and sought to recover half the fence costs through statutory fence viewers, while respondent counterclaimed for trespass and tree damage. The jury found that neither party's land was previously improved or used, that appellant had trespassed by cutting trees worth $250, and that respondent was not entitled to treble damages; the trial court entered judgment accordingly. On appeal, the Minnesota Supreme Court affirmed, holding that Minn. St. 344.03, subd. 1 applied because the lands were not enclosed before the fence, so appellant had no right to apportion costs or privilege to enter the property, and the evidence supported the verdict on lack of prior use and the trespass claim.

propertyproceduretorts & liability

This case involved consolidated actions to determine entitlement to contract proceeds and resolve mechanics liens arising from a subcontract for prefabricated housing units in a low-cost housing project. CWS Development contracted with Modular Structures, which defaulted after receiving payments and assigning its rights to Park Plaza State Bank; CWS then completed the work and sought to offset its costs against amounts claimed under the liens assigned to the bank and another material supplier. The trial court awarded limited recovery to the bank and the supplier after applying an offset to CWS for completion expenses and directed return of remaining deposited funds to CWS. On appeal, the Minnesota Supreme Court affirmed, holding that the record evidence supported the trial court's factual findings on the offset amount and other issues, while declining to address a new argument about setoff not raised below.

propertyprocedure

The case concerned whether United States Steel Corporation owed Minnesota sales or use taxes on various operating supplies, refractory materials, and leased equipment used in its iron ore mining, steel manufacturing, and cement production operations between 1967 and 1968. The Minnesota Supreme Court affirmed the Tax Court's decision that the company was liable for the taxes on these items. The court reasoned that the statutory exemption under Minn. St. 1971 § 297A.25, subd. 1(h) for materials consumed in industrial production did not apply because the items were either machinery, equipment, tools, or supplies used for maintenance and repair rather than direct production inputs, and the exemption expressly excluded such categories even when used in manufacturing processes intended for retail sale. The court also upheld taxation of post-enactment rental payments on pre-existing leases.

taxesbusiness & regulatory

The case concerned a Minnesota mechanical contracting corporation that sought refunds of taxes paid under Minn. St. 1971, § 290.02 for tax years 1968-1970, claiming that interest income from U.S. Treasury notes and other federal obligations should not have been included in its taxable net income. The corporation contended that 31 U.S.C.A. § 742 barred states from considering such interest in computing any tax other than a nondiscriminatory franchise tax. The Tax Court denied the refund claims, and the Minnesota Supreme Court affirmed, ruling that § 290.02 imposes a franchise tax on the privilege of corporate existence that is measured by net income and is therefore permitted by the federal statute to include federal interest income as a measuring stick.

taxesbusiness & regulatoryfederal power

This case involved a breach of a real estate purchase agreement where the defendants backed out of buying the plaintiffs' home after paying a $2,000 down payment. The trial court found the down payment constituted liquidated damages and awarded plaintiffs some mitigation costs like abstracting fees and advertising. On appeal, the Minnesota Supreme Court reversed, holding that the contract did not clearly establish the down payment as liquidated damages in lieu of performance, and remanded for a retrial to determine additional damages including expenses like taxes, utilities, and insurance incurred while attempting to resell the property to mitigate losses.

property

The case involved an appeal by a 17-year-old juvenile charged with aggravated robbery who had been referred by the Hennepin County Juvenile Court for prosecution as an adult under Minn. St. 260.125, based on his history of offenses and expert testimony that no suitable juvenile treatment programs existed for hard-core delinquents like him. The Minnesota Supreme Court vacated the referral order and remanded the matter to the juvenile court. The court reasoned that the reference statute requires specific findings on whether the juvenile is suitable for treatment or whether public safety is served by juvenile court jurisdiction, and that the existing hearing record was inadequate to support such findings or to allow meaningful appellate review, necessitating a fuller hearing with appropriate determinations by the experienced juvenile court judge.

criminal lawfamily law

This case concerned a dispute over the application of federal Brooke Amendments to the U.S. Housing Act of 1937, which capped rents in public housing at 25% of a tenant's income and prohibited state welfare agencies from reducing shelter assistance payments to public housing residents as a result. The Blue Earth County Welfare Department had reduced benefits for tenants in a new Mankato public housing project, contrary to the federal rules, leading the state welfare commissioner to order compliance; the district court reversed that order, holding the Second Brooke Amendment violated equal protection by giving public housing tenants an advantage over those in private housing. The Minnesota Supreme Court reversed the district court and reinstated the commissioner's decision. It reasoned that the amendments were intended to coordinate federal housing subsidies with state welfare programs based on actual housing costs, and that the county had not shown the resulting distinction among tenants to be an equal protection violation.

civil rightsfederal power

This case involved a dispute over the validity of Edyth Bush's attempted renunciation of her late husband Archibald G. Bush's will, which left the bulk of his estate to The Bush Foundation, after she had signed a consent to the will and later entered a 1966 compromise settlement agreement with the estate's executors. The probate court ruled her renunciation ineffective, and the district court granted summary judgment dismissing an appeal from that ruling. The Minnesota Supreme Court affirmed, holding that a prior judgment in related Godfrey litigation was res judicata and barred relitigation of the same issues in this de novo appeal, making summary judgment appropriate despite the statutory right to a full trial on appeal from probate court. The court also noted the claims had become moot following Mrs. Bush's death and distribution of the estate.

family lawpropertyprocedure

The case involved an employee who suffered multiple work-related back injuries over more than a decade while employed by Erie Mining Company, resulting in total permanent disability after the final 1969 injury. The employer, which had registered the employee's preexisting impairments from earlier injuries, sought full reimbursement from the special compensation fund under Minn.St.1969, § 176.131, subd. 1, for benefits paid beyond the statutory deductibles. The Workmen's Compensation Commission modified the compensation judge's order to apportion liability 50 percent to the employer and 50 percent to the fund based on its finding that all injuries equally contributed to the disability. The Minnesota Supreme Court reversed, holding that the statute requires full reimbursement to the employer when a subsequent injury aggravates a registered preexisting impairment to cause substantially greater total disability, without authorizing apportionment of liability between the employer and the fund.

labor & employment

The case concerned West St. Paul State Bank's application to relocate its branch within the same city, which the commissioner of banks approved after finding no threat to solvency, but which the Commerce Commission reversed on review. The Commission held that it had authority over intra-municipal moves, that the applicant bank bore the burden of proving no solvency risk to competitors, and that the bank must also demonstrate reasonable public demand for the new location. The Minnesota Supreme Court interpreted Minn. St. 45.03 and 47.10, reviewing their historical development from earlier banking statutes, and addressed the scope of administrative powers and burden allocation in such proceedings.

business & regulatoryprocedure

The case concerns Dunham Associates' attempt to foreclose a mechanics lien on land in Burnsville, Minnesota, after it prepared structural, mechanical, and electrical plans for an apartment building under a contract with Group Investments; the building was never constructed and the plans were not used. The trial court awarded Dunham a personal judgment against Group for the value of its services but denied the lien against the property owned by the Lannons. On appeal, the Minnesota Supreme Court affirmed, interpreting Minn. St. 1971 § 514.01 to require that services contribute to an actual improvement of the real estate for a lien to attach. The court reasoned that no lien arises from unused plans alone, and even if one did, the plaintiff failed to identify the specific one-acre portion of the 20-acre tract to which any lien could attach given the lack of visible improvements or location details.

property

The case involved a plaintiff who contracted brucellosis while working on power lines near slaughtering plants and a rendering business operated by the defendants. He sued the companies for negligence, alleging that accumulated offal, carcasses, and debris caused his illness, after already receiving workers' compensation from his employer. The jury apportioned negligence under comparative fault rules, assigning 80% to one defendant, 10% to another, 10% to the plaintiff, and none to the third. The trial court denied the plaintiff's motion for judgment notwithstanding the verdict or a new trial, and the appellate court affirmed, finding sufficient evidence on causation from the medical expert and no reversible error in rulings on settlements, jury instructions, or recovery of medical expenses.

torts & liabilityprocedure

This case involved Alside, Inc. seeking to enforce a restrictive covenant in an employment contract against former employee Gene A. Larson, who joined a competitor after working for Alside in sales of siding products in Minnesota and surrounding states. The district court granted Alside an injunction limiting Larson from competing in certain metropolitan counties for two years, and the Minnesota Supreme Court affirmed that order. The court reasoned that Larson had access to confidential customer information and trade secrets during his employment, that the covenant was reasonable in duration, geographic scope (as narrowed by the plaintiff), and purpose in protecting Alside's goodwill without unduly restricting Larson or harming the public, and that Minnesota and Ohio law both apply a reasonableness standard to such agreements. The evidence showed Larson attempted to transfer Alside-built goodwill to his new employer.

labor & employmentbusiness & regulatory

This case involved a negligence lawsuit arising from a highway accident in which an 8-year-old boy was struck by a car while crossing southbound lanes to retrieve a flag that had fallen from his father's boat trailer. The father had parked on the right shoulder and allowed the boy to cross after instructing him to use a nearby crossover; the driver of the striking vehicle was found 60 percent negligent and the father 40 percent negligent for failing to park in a manner that better protected the child during the crossing. The jury awarded damages to the boy and the father, and the trial court denied the father's post-verdict motions to change the answers or grant a new trial. On appeal, the Minnesota Supreme Court affirmed, holding that the evidence permitted the jury to infer the father was negligent in his use of the vehicle and that the verdict could not be set aside as a matter of law.

torts & liability

In State v. McDonald, the defendant appealed his burglary conviction, claiming a violation of double jeopardy protections under the U.S. and Minnesota constitutions after a mistrial was declared in his first trial and he was retried. The first trial began with jury impanelment and opening statements, but the judge granted the prosecution's mistrial motion the next day due to a newspaper article detailing the defendant's rejected guilty plea and protestations of innocence, which could have biased the jury. The Minnesota Supreme Court affirmed the conviction, ruling that the mistrial did not bar retrial because it was supported by manifest necessity to preserve an impartial jury, and the trial court did not abuse its discretion in declaring it without first polling the jurors, given their existing exposure to the plea colloquy. The court noted that double jeopardy generally attaches when a jury is sworn but permits retrial in such circumstances to serve the public interest in fair trials. The court also rejected the defendant's separate claim of improper cross-examination regarding his prior criminal record.

criminal lawprocedure

In State v. Berry, the State of Minnesota appealed the trial court's dismissal of an indictment against Allen Berry for theft and gambling law violations, stemming from a grand jury investigation into a bingo game. Berry had been subpoenaed and testified before the grand jury without signing a written waiver of immunity, though there were disputes about whether he was properly informed of his rights against self-incrimination. The Minnesota Supreme Court affirmed the dismissal, holding that under the circumstances, it could not be determined if Berry knowingly waived his privilege, and that an indictment based on such testimony must be quashed to protect the constitutional right against self-incrimination.

criminal lawprocedure

This case involved several Minnesota district court judges seeking declaratory judgments that 1967 and 1969 amendments to the retirement compensation statute were unconstitutional as applied to them. The amendments changed the formula for retirement pay from one-half the compensation allotted to the office to one-half the compensation at the time of retirement, preventing the judges from receiving increases tied to later salary raises for sitting judges. The judges argued that the changes impaired their contractual rights under the retirement statutes in violation of state and federal contract clauses. The trial court ruled that most of the judges had enforceable contractual rights based on the law at the time of their retirement and that the amendments unconstitutionally diminished those benefits, but found no such impairment for the judge who retired after the amendments took effect. The Supreme Court affirmed as to the judges with pre-amendment retirements and modified the ruling for the one who retired later.

labor & employment