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

In State v. Tomassoni, Gary Tomassoni was convicted of first-degree premeditated murder after he admitted shooting and killing his wife of 24 years but claimed the killing was not premeditated. The Minnesota Supreme Court affirmed the conviction and life sentence without release, rejecting claims that the prosecutor misused impeachment-only evidence during closing argument to prove premeditation and that various trial errors occurred. The court held that the evidence supported the jury's finding of premeditation, the challenged jury instruction correctly stated the law, and the defendant's remaining pro se arguments regarding gender composition of the courtroom, jury selection, and other issues lacked merit or legal support.

criminal law

In State v. Lopez, two brothers were convicted of aiding and abetting a first-degree controlled-substance crime for selling methamphetamine but had related kidnapping charges dismissed after they allegedly held an informant hostage over a drug debt. The district court ordered the brothers to register as predatory offenders under Minn. Stat. § 243.166 on the ground that the kidnapping charges arose out of the same set of circumstances as the drug convictions, and the court of appeals affirmed. The Minnesota Supreme Court reversed, holding that the statute requires registration only when the conviction offense and the charged predatory offense share the same general facts as to time, location, persons involved, and basic events. The court reasoned that the drug sales were completed on April 6, while the alleged kidnapping occurred ten days later in a different location with a slightly different group of people and was not mentioned in the stipulated facts supporting the convictions. The brothers were therefore not required to register as predatory offenders.

criminal law

The case involved Ronald Schober challenging assessments by the Commissioner of Revenue for sales taxes he collected from customers in his home repair business but failed to remit, as well as use tax on a vehicle purchase. The Minnesota Tax Court upheld the sales tax assessment and found no constitutional violations, and Schober had withdrawn his objection to the use tax. The Minnesota Supreme Court affirmed, reasoning that state law requires remittance of any taxes collected from purchasers even if erroneously collected, holding them in trust for the state, and that Schober had waived the use tax issue by stipulation at trial.

taxesbusiness & regulatorycriminal lawprocedure

The case involved appellant Jonard Brandon McDaniel, who was indicted and convicted by a jury in Hennepin County District Court of aiding and abetting first-degree premeditated murder and committing a crime for the benefit of a gang in the May 2006 shooting death of Christopher Lynch amid a gang rivalry between the Tre Tre Crips and the One-Nines. McDaniel was sentenced to life in prison without the possibility of release. On appeal, the Minnesota Supreme Court affirmed the conviction and sentence, holding that the life sentence without release did not violate the Minnesota Constitution's prohibition on cruel or unusual punishments when imposed on an aider and abettor who provided a weapon and drove the car to facilitate the killing. The court reasoned that prior precedents upheld similar sentences for aiders and abettors and that evidence supported McDaniel's intent to participate in the murder.

criminal law

In State v. Stein, appellant Jeffrey Stein was charged with three counts of first-degree burglary after a series of early-morning home invasions in Mound, Minnesota, in which a young white man entered residences and choked female victims in their beds. The jury convicted Stein on one count based solely on circumstantial evidence, including witness descriptions of his clothing at a nearby party, ATM surveillance footage, the timing and locations of the crimes, a discarded shirt matching the description, and DNA on the shirt consistent with Stein. The Minnesota Supreme Court affirmed the conviction, holding that the reasonable inferences from the proved circumstances were consistent with guilt and inconsistent with any rational hypothesis of innocence. The court applied its traditional standard for reviewing convictions resting on circumstantial evidence to determine that the evidence excluded any reasonable inference other than guilt on the one count.

criminal law

This case concerns the modification of spousal maintenance obligations after a 1993 divorce, focusing on how pension benefits factor into calculations of the parties' incomes and ability to pay. The Minnesota Supreme Court interpreted state statutes to determine that pension payments earned before marriage but received after dissolution qualify as income available for maintenance, while pension benefits earned during marriage and previously divided as marital property are not reconsidered as income for the paying spouse. The court affirmed in part and reversed in part the lower courts' rulings on the adjusted maintenance amount, effective date, and related issues, remanding for further proceedings consistent with the statutory distinctions between income and property.

family lawproperty

In State v. Johnson, Ryan Adam Johnson was convicted after a bench trial of first-degree murder while committing child abuse, first-degree murder while committing domestic abuse, and second-degree intentional murder for the death of his six-week-old son Jonah. The court held that sufficient evidence supported the convictions, including Johnson's admissions to multiple incidents of squeezing the infant and sitting on him, which established a past pattern of abuse within the baby's short life. The court affirmed the first-degree child abuse murder conviction and life sentence but reversed and vacated the other two convictions, reasoning that the state could not convict on both first-degree murder counts for the same conduct or on a greater offense and its lesser-included offense. The opinion reviewed the evidence in the light most favorable to the verdict and applied precedents on sufficiency and multiple convictions under Minn. Stat. § 609.04.

criminal lawfamily law

The case involved a Pennsylvania resident who sued non-Minnesota drug manufacturers in federal court in Minnesota over personal injuries from hormone therapy medications taken in Pennsylvania, seeking to apply Minnesota's longer statute of limitations after Pennsylvania's two-year limit had expired. The MDL court certified a question to the Minnesota Supreme Court asking whether Minnesota's statute of limitations governs such claims by a non-resident against non-residents for pre-2004 events occurring outside the state. The court answered yes, holding that Minnesota's six-year limit applied. It reasoned that the 1977 repeal of Minnesota's borrowing statute, combined with longstanding precedent treating statutes of limitations as primarily procedural and thus governed by the law of the forum, meant forum law controls absent a compelling reason to adopt a new retroactive rule.

proceduretorts & liability

This case involved the second conviction of Myon Burrell for first-degree murder and attempted first-degree murder after an 11-year-old girl was killed by a stray bullet during a gang-related shooting in Minneapolis in 2002. Burrell challenged the admission at his retrial of prior bad acts evidence, gang expert testimony, and the grand jury testimony of a deceased witness, as well as the imposition of a longer sentence than he received after his first trial. The Minnesota Supreme Court affirmed the convictions, concluding that the evidentiary rulings were proper and did not prejudice Burrell. However, the court reversed the sentence under the rule from State v. Holmes that prohibits imposing a more onerous sentence after a defendant secures a new trial, and remanded for resentencing.

criminal lawprocedure

In State v. Fort, appellant Eugene Erick Fort was convicted of first-degree premeditated murder and first-degree murder while committing burglary for the 1990 stabbing death of 11-year-old Marcus Potts in his Minneapolis home. The Minnesota Supreme Court affirmed the premeditated murder conviction, holding that the evidence—including 44 stab wounds, statements made by the perpetrator during the attack, footprints leading from the scene to Fort's residence, and inconsistencies in his statements—established premeditation and intent to kill. The court reversed the felony murder conviction without addressing related claims. It also rejected arguments concerning lack of probable cause for search warrants based on the footprints, unclear jury instructions on felony murder, and the need for lesser-included offense instructions, finding no rational basis to acquit on the first-degree charge.

criminal law

This case involved The Work Connection, Inc. seeking further review by the Minnesota Supreme Court of an April 8, 2008, decision by the Court of Appeals. The Supreme Court had previously granted the petition for review on June 18, 2008. Upon later determining that the grant of review had been improvidently issued, the court vacated its earlier order granting review and dismissed the appeal.

procedure

This case involves Otha Eric Townsend's appeal from the denial of his petition for postconviction relief after his first-degree murder conviction. Townsend argued that the 2005 amendment to the Postconviction Relief Act violated the Single Subject and Title Clause of the Minnesota Constitution, that the court had erred in adopting the Knaffla procedural bar, and that evidence of another crime had been improperly admitted at trial. The Minnesota Supreme Court affirmed the denial of relief. It held that the amendment was constitutional because its provisions on postconviction petitions fell under the general subject of public safety and criminal penalties expressed in the law's title, that the Knaffla rule had been validly codified by statute, and that the evidentiary claim was barred because it could have been raised on direct appeal.

criminal lawprocedure

This case was a declaratory judgment action by Minnesota Voters Alliance and six Minneapolis voters challenging the constitutionality of the city's instant runoff voting (IRV) system for municipal elections, adopted via referendum, on grounds that it violated rights to vote, associate for political purposes, and equal protection under the U.S. and Minnesota Constitutions. The district court granted summary judgment to the city on cross-motions, upholding IRV, and the Minnesota Supreme Court affirmed. The court reasoned that IRV uses uniform, nondiscriminatory rules to count every ballot equally in a single election that simulates runoffs by redistributing preferences until a threshold is met, without burdening the fundamental right to vote or creating invidious classifications, and that the method was validly chosen by voters as an alternative to the prior primary-general format.

electionscivil rights

The case concerned a labor union's requests under the Minnesota Government Data Practices Act for payroll records that a private electrical subcontractor had submitted to the City of St. Cloud to demonstrate compliance with state prevailing-wage requirements on a public project. The Minnesota Supreme Court held that the names and wages of the contractor's employees are public data that must be disclosed and that home addresses must also be released. The court reasoned that the specific statutory provision making certain personnel data private applies only to public employees or individuals who contract directly with a state agency, not to employees of a private subcontractor; therefore the Act's general presumption that government data is public governs.

labor & employmentbusiness & regulatory