William P. Murphy

This case concerns whether insurance companies can use T. Eugene Thompson's 1963 first-degree murder conviction for killing his wife to bar his claim to life insurance proceeds on her life under Minnesota's slayer statute. The companies moved for summary judgment in a declaratory action, arguing the conviction conclusively established the facts needed to prevent Thompson from benefiting as beneficiary. The district court denied the motion and certified the question of whether the criminal judgment has preclusive effect in the civil proceeding. The court reasoned that principles of collateral estoppel can apply to treat the conviction as conclusive on the issue of felonious killing, despite lack of mutuality between the parties in the two actions, given the identical facts, full litigation in the criminal case, and strong public policy against allowing a murderer to profit from the victim's death via insurance.

criminal lawpropertyprocedure

The case involved a defendant convicted under a St. Paul city ordinance prohibiting visiting a disorderly house, an offense punishable by up to 90 days in jail. At trial the court applied civil procedures, instructing the jury on proof by a preponderance of the evidence and stating there was no presumption of innocence. The Minnesota Supreme Court reversed, ruling that because incarceration was possible the proceeding must be treated as criminal and therefore required proof beyond a reasonable doubt together with the presumption of innocence under Minn. St. 611.02. The court also directed that a five-sixths verdict instruction not be given on retrial, although the unanimous verdict here prevented reversal on that issue, and it found no error in the admission of search-warrant testimony or in the ordinance's validity.

criminal lawprocedure

The case involved two appeals by defendant Fenton VanWert from jury convictions for uttering a forged instrument and possession of a forged instrument under Minn. St. 609.625, along with denial of a new trial motion. The defendant challenged the search warrant authorizing seizure of check-forging equipment and identification documents, arguing it improperly allowed a nighttime search, lacked particularity, permitted seizure of unlisted items, and was executed too late, as well as the admission of his bail hearing statements and denial of a second Rasmussen hearing. The court affirmed both convictions and the order, holding that the affidavit justified the nighttime search to prevent evidence destruction, the warrant description was adequate for the forgery investigation, seized items fell within the warrant's scope or related closely to it, execution delay was reasonable for coordinated action, bail statements were admissible without Miranda warnings since made in open court, and no additional hearing was needed after the initial admissibility ruling.

criminal lawprocedure

The case involved a cross-claim by AAMCO franchisee Kugler against franchiser AAMCO, alleging that AAMCO's deceptive national advertising and sales methods caused state enforcement action under Minn. St. 325.905, adverse publicity, and destruction of Kugler's business; AAMCO counterclaimed for breach of the franchise agreement. The jury found both parties had engaged in false and misleading advertising and practices, with Kugler knowingly and willingly participating and exceeding franchise requirements. The trial court dismissed both claims with prejudice, concluding the parties were in pari delicto. On appeal, the Minnesota Supreme Court affirmed, holding that Kugler's willing participation barred recovery and that the consumer-protection statute, unlike antitrust laws, did not support damages to a seller who knowingly defrauded consumers.

business & regulatorytorts & liability

This case involves a workers' compensation dispute under Minnesota's second-injury statute, where an employer and insurer sought reimbursement from the special fund for benefits paid to an employee who suffered a second back injury after a prior compensable back injury. The Workmen’s Compensation Commission granted reimbursement only under subdivision 1 rather than subdivision 2 of the statute, and the court reviewed that decision on certiorari. The court affirmed the commission's decision, holding that the employer-insurer failed to meet its burden of proving that the second injury resulted from the preexisting condition, as the medical experts' testimonies conflicted and one doctor could not opine with certainty on the causal link. The court distinguished the case from prior precedent where unopposed expert testimony was disregarded, noting here that the commission reasonably interpreted the evidence in light of both sides' medical opinions.

labor & employmentprocedure

This case concerned whether a 1967 amendment to Minnesota's veterans' preference statute, limiting the 5-point credit to one promotion, was unlawfully applied retroactively to deny the appellant a second preference credit on a police lieutenant promotional exam. The court upheld the Civil Service Bureau's denial of the credit, ruling that the amendment was not retroactively applied because key events like grading the 1967 sergeant exam occurred after the amendment's effective date. The decision reasoned that veterans' preference rights are gratuities rather than vested rights and that the promotion list preparation was properly governed by the law in effect at the time of completion.

labor & employmentprocedure