Eric J. Magnuson

In State v. Chavarria-Cruz, the defendant was convicted of second-degree intentional murder for the benefit of a gang after the district court admitted his confession from a custodial interrogation, despite his claim that he had invoked his right to counsel. The Minnesota Supreme Court reversed the conviction, concluding that the district court's factual finding that Chavarria-Cruz did not request an attorney was clearly erroneous because the interrogation recording plainly captured the invocation. The court held that police were required to cease questioning upon the invocation and that the confession should have been suppressed, leading to reversal of the conviction obtained with the improperly admitted evidence.

criminal lawcivil rights

The case involved a sister suing her brother for alleged sexual abuse and battery that occurred when both were children between 1974 and 1977. After the federal district court dismissed the suit, the Eighth Circuit certified questions to the Minnesota Supreme Court regarding whether Minnesota recognizes a sibling cause of action for childhood sexual abuse, whether intrafamilial immunity bars such claims between emancipated adults, and whether the delayed-discovery statute of limitations applies retroactively. The court answered the first two questions in the negative, holding that no such cause of action exists between unemancipated siblings and that intrafamilial immunity applies, while answering the third question affirmatively based on the statute's text and prior applications. The reasoning relied on the lack of statutory or common-law recognition for sibling sexual-abuse torts, the policy foundations of familial immunity, and the legislature's intent in enacting the delayed-discovery provision.

criminal lawfamily lawproceduretorts & liability

This case involved three child protection (CHIPS) petitions filed by Crow Wing County in district court against indigent parents between 2007 and 2008. After the State Board of Public Defense discontinued representation in such cases, the district court appointed private counsel for the parents; when the County refused to pay the resulting attorney invoices and argued that only public defenders could be appointed, the court held county officials in civil contempt. The Minnesota Supreme Court affirmed, concluding that the cost of court-appointed counsel for indigent parents in juvenile protection proceedings is a charge upon the county. The core reasoning rested on statutory provisions that assign financial responsibility for such counsel to the county when public defender resources are unavailable, along with the county's capacity to raise revenue to meet this obligation.

family lawcivil rightsprocedure

This case concerned whether a county must pay for private counsel appointed to represent an indigent parent in a juvenile protection proceeding under the Indian Child Welfare Act, rather than providing a public defender at state expense. The Minnesota Supreme Court affirmed the lower courts' decisions that private counsel was properly appointed at the county's expense. The court reasoned that state statutes limit public defender appointments to criminal cases, not juvenile matters, and that counties are responsible for such costs under child protection statutes. Additionally, the county could not avoid payment due to lack of budget approval, as judicial orders for such fees must be paid in the following fiscal year.

family lawprocedure

The case involved challenges by recipients of Minnesota's Supplemental Aid-Special Diet Program to executive branch reductions in allotted funds for the 2010-2011 biennium, made under Minn. Stat. § 16A.152 to address a projected budget deficit after the Governor vetoed revenue bills and the Legislature adjourned without overriding them. The district court ruled that the unallotment violated separation of powers principles, and the Minnesota Supreme Court affirmed the invalidity of the reductions although on different grounds. The court reasoned that the unallotment statute authorizes the executive to reduce allotments only when specific statutory triggers are met regarding revenue shortfalls and reserve funds, but does not permit the executive to effectively override legislative appropriations through this mechanism when a deficit remains due to vetoes of revenue measures.

taxeshealthcarefederal power

The case involved Pamela Krueger, the owner of Diamond Dust Contracting, LLC, who sued Zeman Construction Company under the Minnesota Human Rights Act, Minn. Stat. § 363A.17(3), alleging sex discrimination and harassment while performing subcontract work on a construction project through her company. The district court dismissed Krueger's individual claim for lack of standing, and the court of appeals affirmed. The Minnesota Supreme Court affirmed, holding that the statute requires a direct contractual relationship between the plaintiff and defendant for a business discrimination claim because the law prohibits discrimination that affects the performance of a contract by an aggrieved party. The court reasoned from the plain statutory language, comparisons to analogous federal law, and policy considerations that only the party to the contract has standing, so Krueger could not bring a personal action.

civil rightslabor & employment