Helen M. Meyer

This case concerned a Minnesota school district's refusal to discuss in a disabled student's IEP meetings the supplementary aids and services needed for participation in extracurricular activities such as volleyball, clubs, and a graduation party. The Minnesota Department of Education found the district violated the federal IDEA by declining to consider those services, and the school district appealed. The Minnesota Supreme Court held that IDEA regulations (34 C.F.R. §§ 300.107, 300.117) require IEP teams to consider supplementary aids and services for a broad range of extracurricular and nonacademic activities without limiting them to only those required for the student's education. The court reasoned that the regulation's plain language enumerates numerous activities without such a restriction, the statute contains no such limit, and the regulation is within the Secretary of Education's authority and not ultra vires.

civil rightsfederal power

In State v. Cao, the defendant was convicted of third- and fourth-degree criminal sexual conduct after evidence showed he had intercourse with a complainant who was physically helpless from intoxication at a party. The prosecutor stated in closing argument that Minnesota law does not require corroboration of the complainant's testimony. The court of appeals held this constituted plain error and prosecutorial misconduct, but the Minnesota Supreme Court reversed and remanded, concluding the statement did not violate case law or rules so was not plain error, and that even assuming error it did not affect substantial rights because the evidence was strong, the comment was isolated, and the defense had rebuttal opportunities.

criminal lawprocedure

The case involved Stafon Edward Thompson, who was convicted by a jury of two counts of first-degree premeditated murder and two counts of first-degree murder while committing aggravated robbery for the deaths of Katricia Daniels and her son. Thompson appealed his convictions and consecutive life sentences, arguing that the district court erred in admitting certain statements he made to police and computer-generated crime scene images, that his trial counsel was ineffective, and that his sentences constituted cruel and unusual punishment given his age of 17. The Minnesota Supreme Court affirmed the convictions, holding that any errors in the admission of evidence were harmless and that the sentences did not violate constitutional protections.

criminal lawprocedure

The case concerned a 14-year-old who pleaded guilty in juvenile court to first-degree murder and attempted first-degree murder and was convicted and sentenced as an adult without a certification hearing or the findings required to transfer the case to adult court. The Minnesota Supreme Court held that the juvenile court's convictions and sentences were void for lack of subject-matter jurisdiction because the court made no findings on public safety or the statutory certification factors under Minn. Stat. § 260B.125. The court reversed the denial of postconviction relief and remanded for further proceedings, emphasizing that the juvenile court could not simply accept the guilty plea and impose adult sentences without satisfying the prerequisites for adult certification.

criminal lawprocedure

Gary Roby was convicted in 1989 of first-degree premeditated murder for the shooting death of Marlizza McIntyre and received a mandatory life sentence; his direct appeal and two earlier postconviction petitions were denied. In 2009 he filed a third petition alleging newly discovered evidence, including a letter and affidavits suggesting a co-conspirator was the actual shooter, and invoking the newly-discovered-evidence and interests-of-justice exceptions to the two-year filing deadline under Minn. Stat. § 590.01, subd. 4(b). The postconviction court dismissed the petition as untimely without examining whether any exception applied. The Minnesota Supreme Court reversed, holding that Roby had sufficiently invoked two statutory exceptions, and remanded for the postconviction court to determine whether the claims satisfied the time limits in subdivision 4(c) and, if so, whether they warranted relief.

criminal lawprocedure

Brett Arnold Laine was convicted of first-degree domestic abuse murder for killing his girlfriend, Nancy Jagunich, after evidence showed her injuries were inconsistent with his claim that she fell down stairs. Following affirmation of his conviction on direct appeal, Laine filed a second petition for postconviction relief alleging newly discovered evidence, ineffective assistance of counsel, and a Sixth Amendment Confrontation Clause violation based on out-of-court statements. The district court denied the petition without a hearing, and the Minnesota Supreme Court affirmed, holding that most claims were Knaffla-barred because they were known but not raised on direct appeal, the new evidence did not satisfy the criteria for granting relief, and Giles v. California did not render the statements testimonial or inadmissible.

criminal lawprocedure

This case involved a dispute over the location of a cartway that Pepin Township was required to establish under Minnesota law to provide access to John Kennedy's landlocked 26.6-acre property. The township board selected a route accessing only the unusable sloped portion of the land from Highway 61, while Kennedy sought a more expensive route to the buildable 5 acres atop the bluff. The district court affirmed the board's decision, but the court of appeals reversed, and the Minnesota Supreme Court affirmed in part, reversed in part, and remanded. The court held that providing access only to an unusable portion does not satisfy the statutory requirement for access to the tract, relying on prior precedent, and directed the board to properly evaluate alternative routes in the public interest.

property

The case involved Halla Nursery and its owners, who sought to keep using an illuminated electronic sign at their property after obtaining a 2005 sign permit, despite a 1997 stipulation and judgment with the City of Chanhassen that limited signs to non-illuminated directional ones of specific size and prohibited illumination. The district court ruled for Halla, finding substantial compliance with the 1997 agreement and vested rights based on substantial completion of the $124,000 sign project. The court of appeals reversed, and the Minnesota Supreme Court affirmed, holding that the sign violated the 1997 judgment's terms on illumination, size, and type, and that the permit was erroneously issued without authority to amend the judgment. The core reasoning was that vested rights cannot arise from an illegal or mistaken permit issued in violation of a prior court judgment and city ordinances, as Halla knew or should have known of the restrictions.

propertybusiness & regulatory

This case concerned whether the Minnesota DNR could enforce a state administrative rule under the Lower St. Croix Wild and Scenic River Act that barred development on a substandard lot recorded before 1974 and later held in common ownership, even though the DNR had previously approved the City of St. Mary's Point's local Bluffland/Shoreland Management Ordinance as being in substantial compliance with state standards and that ordinance permitted the development. The administrative law judge and DNR denied certification of the city's variance for the lot, and the court of appeals affirmed. The Minnesota Supreme Court reversed, holding that the DNR-approved local ordinance controlled because it was deemed in substantial compliance with the Act's protective standards, and the agency could not enforce the stricter state rule against a variance granted under the local ordinance it had reviewed and accepted.

environmentproperty

In State v. Raleigh, the defendant was indicted on first-degree murder charges for the beating death of a probation officer during a robbery attempt and later pleaded guilty to first-degree premeditated murder in exchange for dismissal of other charges. Before sentencing, he moved to withdraw the plea, arguing it was not knowing or voluntary due to stress, mental health issues, and lack of understanding of the consequences. The district court denied the motion under both the manifest injustice and fair and just standards of Minn. R. Crim. P. 15.05, finding the plea valid and no credible reasons or evidence to support withdrawal. The Minnesota Supreme Court affirmed, holding that the defendant had failed to substantiate any basis for withdrawal and that the district court did not abuse its discretion even after discounting overstated prejudice to the state.

criminal lawprocedure

This case involved a dispute over whether contractors who performed surveying, engineering, utilities, and earthwork on single-family lots in a failed Minnesota residential development could enforce mechanic's liens without providing statutory pre-lien notice to the property owners. The district court dismissed one contractor's lien claim for lack of notice, but the court of appeals held that the exception for improvements to property consisting of more than four family units applied to single-family lots within a development. The Minnesota Supreme Court reversed, holding that Minn. Stat. § 514.011, subd. 4b applies only to multi-unit buildings such as apartments, condominiums, and townhouses. The court reasoned that mechanic's lien statutes are strictly construed as to whether a lien attaches, that the statutory language and purpose of protecting owners supported a narrow reading of the exception, and that the exception therefore did not exempt the contractor from the notice requirement. The case was remanded for consideration of an alternative argument regarding engineering and surveying services.

propertyprocedure

Andrew Tyler Jones, an indigent defendant, spent 286 days in county jail before pleading guilty to aggravated robbery charges and being sentenced. Olmsted County billed him $7,150 under Minn. Stat. § 641.12, subd. 3(a) for the costs of his preconviction confinement. The district court and court of appeals upheld the billing, but the Minnesota Supreme Court reversed. The Court held that the statute permits counties to charge only an "offender's" confinement expenses, and because conviction is required to attain offender status, the statute does not authorize recovery of preconviction costs.

criminal lawprocedure

In State v. Pearson, the defendant was convicted of first-degree premeditated murder and unlawful firearm possession after shooting and killing Corodarl Merriman during an altercation stemming from a potential drug sale, though he claimed self-defense and presented conflicting testimony from the surviving witness. The Minnesota Supreme Court affirmed the convictions following consolidated direct and postconviction appeals. The court held that a videotaped statement by the defendant was properly admitted as rebuttal evidence, that the prosecution did not engage in misconduct, and that the defendant was not denied effective assistance of counsel, with no plain error found in the handling of references to an attorney in the tape.

criminal lawprocedure

This case involved a dispute over the validity of four mechanics' liens recorded by Consolidated Lumber against property owned by Bahr Construction, which Premier Bank challenged due to errors in the property descriptions on the lien statements. After a bench trial, the district court upheld the liens as identifying the property with reasonable certainty, determined their value, and entered partial judgment while reserving attorney fees for later determination. The Minnesota Supreme Court affirmed the court of appeals' dismissal of Premier Bank's appeal on the liens' validity as untimely, because the partial judgment was properly certified for immediate appeal under Minn. R. Civ. P. 54.02 and the appeal was filed more than 60 days later, but reversed the dismissal of the appeal from the separate attorney fees order and remanded for further proceedings. The core reasoning centered on the rules governing finality and timeliness of appeals from partial judgments that resolve some but not all claims.

propertyprocedure

In Holt v. State, Clarence Holt was convicted by a jury of first-degree premeditated murder and related charges for the 1997 shooting death of Frederick Pitts during a drug-related dispute and was sentenced to life in prison. Nine years later, Holt filed a petition for postconviction relief raising multiple claims, including that the trial court erred by failing to remove a juror exposed to potential outside influence, excluding him from an in-chambers Schwartz hearing in violation of his rights to self-representation and presence, admitting evidence of witness tampering without a proper limiting instruction, admitting an alleged accomplice's statements, and refusing an accomplice liability instruction. The Minnesota Supreme Court affirmed the conviction, holding that Holt's claims either lacked merit, were harmless, or did not require reversal under applicable standards for constitutional and evidentiary errors. The decision addressed procedural and substantive issues arising from the original trial without reaching the state's timeliness argument due to the affirmance.

criminal lawprocedure

In State v. Cruz-Ramirez, a Hennepin County jury convicted the defendant of multiple counts of first-degree and second-degree murder, as well as attempted murder, stemming from a 2007 shooting incident in Minneapolis that killed one man and injured three others after the shooter approached a group of men near parked cars and opened fire following a gang-related question. The district court imposed a life sentence plus consecutive terms for the attempted murders. On direct appeal, Cruz challenged the admission of expert gang testimony, certain jury instructions, the sufficiency of the evidence for first-degree murder, and sought vacation of unsentenced convictions, with additional pro se claims. The Minnesota Supreme Court affirmed the convictions and sentences but modified the judgment by vacating the unsentenced convictions, finding no error in the evidentiary ruling or instructions when read as a whole and that the evidence supported the verdicts.

criminal lawprocedure

The case involved Geronimo and Kathleen Sanchez, who claimed to have changed their domicile from Minnesota to South Dakota in 2004 after selling their Minnesota home, obtaining South Dakota documents such as driver's licenses and voter registration, and filing Minnesota income tax returns as part-year residents. The Commissioner of Revenue audited the returns, treating the couple as full-year Minnesota residents based on the presumption that domicile continued absent proof of a new domicile, and the tax court granted summary judgment to the Commissioner. The Minnesota Supreme Court affirmed, holding that the Sanchezes had not established domicile in South Dakota under the applicable rules because they lacked sufficient bodily presence there and had not fixed their habitation with intent to make it their home, having spent limited time in the state before traveling elsewhere. The court reviewed the tax court's application of law de novo and factual findings for sufficient evidence, concluding the couple remained Minnesota domiciliaries for the full tax year.

taxes

In Chambers v. State, Timothy Patrick Chambers petitioned for postconviction relief after his 1998 convictions for first-degree murder of a peace officer, second-degree felony murder, fleeing a peace officer resulting in death, and motor vehicle theft, stemming from the killing of Rice County Deputy John Liebenstein. The Minnesota Supreme Court affirmed the postconviction court's denial of relief, holding that Chambers' claims of ineffective assistance of trial counsel were procedurally barred under the Knaffla rule because they were evident from the trial record and should have been raised on direct appeal. The court also rejected his renewed challenge to the trial court's refusal to instruct the jury on lesser-included offenses, finding that the issue had been decided against him on direct appeal and that, even under the Dahlin test viewed in the light most favorable to him, there was no rational basis for acquitting him of second-degree felony murder. The decision rested on procedural bars codified in Minn. Stat. § 590.01 and standards for ineffective assistance under Strickland v. Washington, along with the lack of factual support warranting an evidentiary hearing.

criminal lawprocedure

The case involved the City of West St. Paul seeking a permanent injunction to bar homeowner Alice Krengel from occupying her residence for one year, based on prior public nuisance incidents at the property and violations of a 2005 abatement plan that prohibited alcohol use and other activities. Although no further statutory nuisance activity occurred after the plan was implemented, the district court granted the injunction citing the earlier incidents and plan breaches under Minn. Stat. §§ 617.80-87. The Minnesota Supreme Court affirmed the court of appeals' reversal, holding that once nuisance conduct has been abated, a prosecuting attorney lacks authority to initiate a nuisance action. The core reasoning was that the statute requires proof of two or more qualifying nuisance incidents within the relevant period, abatement plan violations do not constitute statutory public nuisances, and the law does not permit actions based solely on past abated conduct.

criminal lawpropertyprocedure

In State v. Vance, the defendant was convicted of first-degree criminal sexual conduct and related offenses after a violent assault on the mother of his children, and the district court imposed a double upward durational departure from the presumptive sentence based on aggravating factors. Following a Blakely trial, a jury found three aggravating factors, including that the offense occurred in the presence of children, but Vance challenged the jury instruction on that factor, which stated the state need not prove the children actually observed or heard the offense so long as they could have. The Minnesota Supreme Court concluded the instruction was erroneous because it was overly broad and misstated the law on the presence-of-children factor. Nevertheless, the court affirmed the sentence, reasoning that the remaining valid factors of multiple forms of penetration and particular cruelty independently supported the departure.

criminal lawprocedure