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

The case concerned the City of Rochester's plan to acquire and operate a sanitary landfill in Oronoco township after its existing waste site posed pollution risks, which the town and nearby landowners sought to block through injunctions and denial of a special exception permit under county and township zoning ordinances. The district court denied the injunction and ordered issuance of the permit, and the Minnesota Supreme Court affirmed. The court held that while governmental bodies are generally exempt from zoning when acting in a governmental capacity, it adopted a balancing-of-public-interests test instead of a blanket rule; here, the urgent public need for a new landfill, combined with oversight by the Minnesota Pollution Control Agency, outweighed the local zoning restrictions. The decision turned on the city's statutory eminent domain authority and the absence of environmental hazards under the permit conditions.

environmentpropertybusiness & regulatory

This case involved an appeal from a first-degree murder conviction under Minn. St. 609.185(1), where the defendant challenged the admission of testimony from his alleged wife on marital privilege grounds, the introduction of his prior criminal record, the sufficiency of the evidence, hearsay admissions, jury instructions, and the state's failure to disclose certain evidence before trial. The facts centered on the 1968 death of Nancy Meyer, found suffocated in her apartment while pregnant, with evidence including the defendant's admissions to five witnesses that he planned to and did kill her to prevent her from reporting his robberies, his possession of her wallet and paychecks shortly after the crime, and medical findings consistent with suffocation despite inconclusive toxicology. The court affirmed the conviction, holding that no valid marriage existed under state law so the privilege did not apply, that the evidence was sufficient to prove guilt beyond a reasonable doubt, that no favorable evidence was improperly suppressed, and that other claimed errors lacked merit.

criminal lawprocedure

This case concerned a workers' compensation claim by employee Elmer Miller, a physically handicapped worker with epilepsy who suffered two hip fractures from falls at his light-duty job site. The first fall occurred on steps while returning from lunch when his leg locked, and the second happened months later while he was still recovering and walking with a cane. The employer and insurer argued that the injuries did not arise out of or in the course of employment due to the employee's pre-existing condition, but the Workmen’s Compensation Commission awarded temporary total disability benefits. The court affirmed the award, holding that the initial injury was compensable under established precedents even if the handicap was a contributing factor, and that the second injury was a consequential result of the first.

labor & employment

In State v. Bellcourt, the defendant appealed his aggravated robbery conviction, arguing insufficient evidence and that a delay of over a year between the April 1969 offense and his arrest violated his due process and speedy trial rights. The court affirmed the conviction, noting that the evidence supported the jury's verdict and that the speedy trial protection generally applies from the time of custody rather than the offense date. The opinion found no indication that police knew the defendant's identity earlier or acted with prejudicial intent, and the defendant failed to demonstrate actual prejudice from the delay in his ability to present a defense.

criminal lawprocedure

The case involved a defendant's conviction for participating in an attempted aggravated robbery of a filling station during which a companion shot the attendant. On appeal, the defendant challenged the sufficiency of the evidence to show his knowledge of the armed robbery plan, the admission of a .45-caliber bullet seized from him (despite the crime involving a .22-caliber pistol), and the admission of his in-custody statements on grounds including Miranda compliance and a multi-day delay before appearing before a magistrate. The court affirmed the conviction, holding that the evidence supported the verdict, any error in admitting the bullet was harmless beyond a reasonable doubt in light of other evidence, the statements were properly admitted because Miranda rights were given and waiver was shown, and the delay was not manifestly unreasonable so as to require suppression. The opinion addressed related procedural issues under state precedent but did not alter the judgment.

criminal lawprocedure

The case involved a 22-year-old defendant who, with two companions, entered a St. Paul service station late on January 10, 1970; one companion shot the attendant three times after he refused to open the cash register. The defendant was indicted for attempted aggravated robbery and aggravated assault, but pursuant to a plea agreement the assault charge was dismissed and he pleaded guilty to attempted aggravated robbery. On appeal the defendant claimed his plea was invalid because he was innocent and entered it only out of fear of conviction at trial. The Minnesota Supreme Court affirmed the conviction, holding that the plea examination established an adequate factual basis and that a guilty plea entered to avoid the risks of trial remains valid even if the defendant maintains innocence, citing North Carolina v. Alford.

criminal law

The case involved a defendant indicted for first-degree murder in the 1965 shooting death of his estranged wife's boyfriend who later pled guilty to second-degree murder, was sentenced, had his term commuted, and was paroled before seeking to withdraw his plea via postconviction motion. The defendant argued his plea was invalid due to erroneous advice from counsel about his wife's potential testimony, statements made during a psychiatric exam that undermined intent, and the availability of self-defense or provocation defenses. The court affirmed the denial of the motion, holding that withdrawal of a guilty plea is discretionary and requires proof of manifest injustice, which was absent here. The record showed the plea was a calculated choice to avoid the high risk of a first-degree murder conviction at trial, based on available evidence and counsel's assessment that self-defense was unlikely to succeed. No errors in the plea process or factual basis were found sufficient to justify relief.

criminal lawprocedure

Tyler Lumber Company, a lumber cooperative, sued the Minnesota commissioner of taxation to recover sales taxes paid under a deficiency assessment after deducting patronage refunds from its gross receipts when calculating the tax. The court affirmed summary judgment for the commissioner, holding that patronage refunds cannot be excluded from the taxable "sales price" under Minn. St. 297A. The core reasoning was that the refunds are determined and distributed after sales are consummated based on the cooperative's annual net income, making them post-sale events that do not reduce the predetermined consideration paid by customers at the time of purchase, as confirmed by the statutory definitions of sales price and gross receipts and by the commissioner's regulations on post-consummation discounts.

taxesbusiness & regulatory

The case concerned whether plaintiffs had acquired an implied easement over defendants' adjacent lots for a septic tank drain field serving plaintiffs' house. The district court found that the drain field was located on defendants' land, that plaintiffs could not install one on their own property, and that an implied easement existed; it granted declaratory and injunctive relief. The Minnesota Supreme Court affirmed, holding that the evidence supported the location and necessity findings, that the common ownership by defendants from 1957 to 1966 followed by severance in 1966 satisfied the unity-of-title requirement, and that the use was sufficiently apparent because plans on file with the health department and expert testimony indicated its location. The court also upheld denial of a new trial, finding the proffered affidavits failed to meet the diligence and non-cumulative standards for newly discovered evidence.

property

This case involved a painter employed by a subcontractor who suffered severe burns while spray-painting inside a confined mooring tank due to flammable vapors igniting from an unprotected light bulb and lack of ventilation. The employee and his workers' compensation insurer sued the general contractor for negligence, alleging breach of nondelegable safety duties under its contract with the Corps of Engineers; the general contractor then sought indemnity from the subcontractor. The trial court, using a special verdict on comparative negligence, awarded damages and granted the general contractor indemnity against the subcontractor. The Minnesota Supreme Court affirmed, holding that the subcontract incorporated the general contract's safety requirements and included express indemnity provisions obligating the subcontractor to protect against losses from its failure to comply with those duties.

torts & liabilitylabor & employmentbusiness & regulatory

The case concerned whether Milwaukee Motor Transportation Company, a trucking subsidiary of a railroad, owed Minnesota corporate income tax under Minn. Stat. 290.02 on revenues from cartage services performed for its parent, when the railroad had already paid gross earnings taxes on those same revenues. The trial court granted summary judgment to the company for a tax refund, reasoning that the dual taxes amounted to impermissible double taxation. On appeal, the Minnesota Supreme Court analyzed whether the subsidiary and parent should be treated as a single taxable entity under precedents such as The Pullman Co. v. Commissioner of Taxation and State v. St. Paul Union Depot Co., or whether their separate corporate forms meant each owed its own tax. The court noted that the gross earnings tax is in lieu of other taxes on railroad property and franchises, while the corporate tax is measured by net income, and considered whether the subsidiary's services qualified as railroad operations exempt from the income tax.

taxesbusiness & regulatory

In Kost v. Peterson, plaintiff Arthur Kost sued defendant Gordon Peterson, an agent for the disclosed principal Federal Auto Systems, alleging that Peterson fraudulently induced him to pay $487.50 for a car-leasing franchise by misrepresenting details of the program and then improperly cashing his check instead of certifying it, preventing a stop-payment. The jury awarded Kost the amount paid, but the trial court denied the agent's motion for judgment notwithstanding the verdict. On appeal, the Minnesota Supreme Court reversed, holding that an agent acting for a disclosed principal incurs no personal liability on the contract or for the principal's nonperformance, and that the evidence failed to establish the elements of actionable fraud because the method of transmitting the funds was collateral and not a material misrepresentation of past or present fact. The court reasoned that the agent had turned the proceeds over to the principal without retaining any benefit and had not misrepresented his authority.

torts & liabilitybusiness & regulatory

This case involved consolidated negligence actions arising from a 1968 automobile collision at an uncontrolled T-intersection in Rice County, Minnesota, where Mary Ella Martin was driving south and Rita Bussert was driving west. The jury apportioned causal negligence as 80% to Mary Ella Martin and 20% to Rita Bussert. The Minnesota Supreme Court affirmed the trial court's denial of the Martins' motions for judgment notwithstanding the verdict or a new trial. The court reasoned that any error in failing to instruct the jury that Bussert was negligent as a matter of law was harmless because the jury found her negligent anyway, and the negligence apportionment was supported by evidence and not manifestly against its weight.

torts & liability

The case involved an appeal by the state from a municipal court order dismissing a complaint charging the defendant with violating drug possession statutes after a preliminary hearing. The state argued that the magistrate had improperly acted as a fact-finder on guilt rather than assessing only whether probable cause existed. The court held that the dismissal order was not appealable under the statute allowing state appeals from orders dismissing complaints. The reasoning was that the provision applies only when a dismissal effectively defeats or terminates the prosecution, but here the state could still pursue the matter before another magistrate or a grand jury, making routine appellate review of probable cause determinations at this stage inappropriate.

criminal lawprocedure