Martin A. Nelson

In State v. Hoskins, the defendant was convicted after a jury trial of one count of second-degree murder and four counts of third-degree murder for killing his wife and children, then attempting to stage the scene as an attack by intruders by setting the house on fire and shooting himself. He appealed his convictions and the denial of a new trial, arguing primarily that the evidence, including expert testimony, established his insanity at the time of the offenses and that the jury should have been directed to acquit on that ground. The Minnesota Supreme Court affirmed the judgment, holding that the question of sanity was properly submitted to the jury, which was entitled to weigh the expert testimony along with other evidence and was not required to accept the defense experts' opinions as conclusive. The court found sufficient evidence in the record to support the verdicts returned.

criminal law

The case involved defendants charged under Minnesota Statute 617.241 with possessing obscene films with intent to sell at their Duluth bookstore, after police seized 54 reels pursuant to a warrant. A jury convicted them on 29 of 33 counts, resulting in per-count fines, and they appealed on issues of evidence sufficiency, exclusion of defense exhibits on community standards, First Amendment protections, and the statute's constitutionality for omitting an "utterly without redeeming social value" element. The Minnesota Supreme Court affirmed the convictions, holding that the jury could assess obscenity under the statutory definition without expert testimony and rejecting the constitutional claims, but modified the judgments to impose only a single fine because the counts stemmed from a single incident.

criminal lawfree speech

This case arose from a two-car collision at a rural intersection, where the plaintiff sued both drivers and their fathers as owners after settling with one pair of defendants for $10,500; the remaining issue was the cross-claims between the defendant groups over liability and contribution. The trial court found both drivers negligent as a matter of law and instructed the jury on proximate cause and superseding causation, resulting in a verdict that the Junkermeier driver's negligence was not a proximate cause of the accident. The court affirmed the denial of post-trial motions, holding that proximate cause is a jury question unless the evidence leaves no room for reasonable disagreement, and that the record supported the jury's conclusion either because the collision would have occurred anyway or because the other driver's actions were unforeseeable and superseding. The court also upheld the superseding-cause instruction as appropriate given the factual dispute.

torts & liability

This case involves a state prisoner's appeal from the denial of postconviction relief, in which he challenged the validity of his warrantless arrest and search, the voluntariness of his confessions and guilty plea to uttering a forged drug prescription, and the constitutionality of his indeterminate sentence of up to 20 years as cruel and unusual punishment under the Eighth and Fourteenth Amendments. The court affirmed the denial of relief. It held that a voluntary guilty plea waives challenges to prior defects in arrest, search, and confession under McMann v. Richardson, that the conviction for forgery does not violate constitutional prohibitions on punishing status as a drug addict under Robinson v. California and Powell v. Texas, and that the sentence within the statutory maximum was not cruel and unusual given legislative authority over penalties and the trial court's discretion.

criminal lawprocedurecivil rights

This case involved a nurse’s aide who developed back and leg pain during her employment at St. Barnabas Hospital and later sought workers’ compensation benefits. The employee did not inform her employer that the condition was work-related until more than a year after it began, and contemporaneous medical and insurance forms stated that any connection to employment was unknown or nonexistent. The Workmen’s Compensation Commission found that the employer had actual knowledge of the injury within the 90-day statutory period under Minn. St. 176.141, but the court reversed, concluding that knowledge of the disability alone did not constitute actual knowledge because it did not put the employer on inquiry notice that the injury arose out of employment. The court held that the commission’s finding lacked substantial evidentiary support in the record.

labor & employmentprocedure

In this case, the municipal court suppressed oral admissions made by the defendant to a police officer in a traffic violation prosecution because the prosecuting attorney served the Rasmussen notice on the defendant rather than his attorney. The state appealed the suppression order. The appellate court reversed with instructions to hold a Rasmussen hearing, determining that the state had acted in good faith by following local court rules when serving the defendant and that the error was harmless. It reasoned that remanding for a pretrial hearing on admissibility, with the defendant present and represented by counsel, would not unduly prejudice the defendant and would allow a proper determination of whether the evidence violated constitutional rights.

criminal lawprocedure

This case involved plaintiffs filing a declaratory judgment action against the University of Minnesota and its Board of Regents, seeking court oversight and control over university administration based on allegations of mismanagement and criminal activities occurring on campus. The district court granted judgment on the pleadings for defendants, finding no justiciable controversy, and the Minnesota Supreme Court affirmed. The court held that the university operates as an autonomous constitutional corporation with broad governing authority vested in the Board of Regents, which courts may not broadly invade or supplant. It further noted that alleged crimes should be reported to prosecutors for enforcement, that the requested relief could conflict with due process, equal protection, and First Amendment protections, and that declaratory relief was discretionary and inappropriate where no decree could resolve the underlying disputes.

procedurecivil rightscriminal law

This case involved a garnishee (employer) that released funds it had withheld from an employee's wages pursuant to prejudgment garnishment summonses served under Minnesota's then-existing garnishment statute. After the U.S. Supreme Court ruled in Sniadach v. Family Finance that prejudgment wage garnishment without a hearing violated due process, and Minnesota amended its law accordingly, the garnishee released the funds. The plaintiff obtained a default judgment against the defendants and then sought judgment against the garnishee for the released amounts totaling $89.37. The court held that the garnishee remained obligated to hold the funds because the statute was not retroactively invalid in this context where the defendant had defaulted and thus had an opportunity to be heard, and the plaintiff's rights had vested under the prior law. Therefore, the judgment against the garnishee was affirmed.

procedurecivil rights

The case involved defendant Luther William Fulford's appeal from his conviction for second-degree murder after he stabbed Richard Younghans at a St. Paul apartment hotel in 1969. The Minnesota Supreme Court affirmed the conviction, holding that evidence of a prior knife threat was properly admitted for impeachment after the defendant opened the door on direct examination, that the knife seized from his coat was admissible as seized incident to a valid arrest, and that the jury instructions were adequate given the defendant's strategic waiver of a heat-of-passion manslaughter instruction. The court further ruled that the evidence, including eyewitness testimony and blood tests linking the knife to the victim, was sufficient to support the verdict of intentional but unpremeditated murder. Issues regarding pretrial notice of collateral crimes and admissibility of room photographs were deemed moot or without merit.

criminal lawprocedure

The case involved petitioner Donald Olness, who had pleaded guilty to aggravated robbery in Ramsey County District Court after being charged with two robberies. He sought postconviction relief on grounds that his plea was involuntary due to alleged promises of leniency (probation or one year in the workhouse) by his attorney and because he had participated in lineups without counsel. The trial court denied relief after a hearing, finding that no promises had been made, that Olness understood the consequences of his plea, and that the lineups had no effect since no identifications resulted. The Minnesota Supreme Court affirmed, concluding that the record supported the voluntariness of the plea and that any lineup issues were irrelevant to the plea decision.

criminal lawprocedurecivil rights

The case involved a defendant charged with possession of LSD, classified as a gross misdemeanor under Minnesota statutes at the time, after being arrested without a warrant based on a tip from a reliable informant describing the vehicle and its occupants. The defendant challenged the arrest's validity and the court's jurisdiction, arguing that the offense was not committed in the officers' presence as required for warrantless arrests of non-felonies. The Minnesota Supreme Court addressed a certified question on whether such an arrest was valid under Minn. St. 629.34 and the state constitution, holding that it was not because gross misdemeanors are treated separately from felonies, and the statute does not authorize warrantless arrests for them unless the offense occurs in the officer's presence. The court reasoned that probable cause alone was insufficient without statutory authorization or the offense being visible to officers, and remanded the case after answering the certified question in the negative.

criminal lawprocedure

This case involves an extradition proceeding where the Minnesota governor issued a warrant to return the petitioner to Nebraska to face robbery charges stemming from a bank holdup in Omaha on October 20, 1970. The trial court denied the petitioner's habeas corpus challenge to the warrant, and the Minnesota Supreme Court affirmed that decision on appeal. The court relied on testimony from an Omaha police sergeant who positively identified the petitioner as one of the robbers, finding that the petitioner's alibi witnesses—a brother and a convicted felon friend—did not sufficiently rebut the identification or the presumption created by the valid rendition warrant.

criminal lawprocedure

The case involved a defendant convicted of burglary for entering a Minneapolis furniture store without consent in the early morning hours, with the sole issue on appeal being whether the evidence sufficiently proved his intent to commit a crime inside. The defendant argued that his intoxication at the time negated the required intent, as he claimed to have been in a drunken stupor and unable to recall events. The court affirmed the conviction after a bench trial, concluding that the circumstances—including the manner of entry through a high window, removal of shoes, location inside the building, and post-arrest conduct—permitted a reasonable inference of intent to steal despite the intoxication claim. The decision emphasized deference to the trial court's assessment of witness credibility and the limited scope of appellate review on factual issues like subjective intent.

criminal law

The case concerned a defendant charged in municipal court with both failing to stop and provide identifying information after a car accident and driving under the influence of alcohol. After acquittal on the first charge, the defendant moved to dismiss the second on grounds that the two offenses arose from a single behavioral incident under Minn. St. 609.035, which bars serialized prosecutions. The Minnesota Supreme Court applied its test from State v. Johnson, finding that the violations occurred at substantially the same time and place as part of a continuous course of conduct involving coincident errors of judgment linked by alcohol impairment. The court therefore ruled that the acquittal barred further prosecution on the DUI charge, made the writ of prohibition absolute, and noted that the defendant had sought a joint trial that the lower court had denied.

criminal lawprocedure

The case involved a dispute over the distribution of assets between the estates of Fred O. Perkins, who died in 1932, and his wife Lillian C. Perkins, who died in 1967. Fred's will granted Lillian a life estate in the residue of his property, including the right to use principal for her support and pleasure, with the remainder to pass to specified nieces and nephews. Lillian managed the assets during her life, sold some shares, received dividends, and benefited from stock splits on holdings like International Harvester stock. The Minnesota Supreme Court affirmed the district court's ruling that the remaining stock and increases from splits belonged to the remaindermen under Fred's will, while cash, dividends, and income assets went to beneficiaries under Lillian's will, applying the Massachusetts rule on principal-income allocation as codified in Minnesota statute.

property

This case involved a dispute over whether a school district could make payments to striking Minneapolis public school teachers pursuant to negotiated agreements for back pay during the strike and increased wages and benefits afterward. The teachers had struck in April 1970 after negotiations under the state's meet-and-confer law failed to produce an agreement, leading to temporary restraining orders and automatic termination of employment for strikers under state law. The trial court permanently enjoined the payments, and the Minnesota Supreme Court affirmed that order. The core reasoning was that Minn. St. §§ 179.51, 179.54, and 179.55 render public-employee strikes illegal, automatically terminate the strikers' employment without any action by the employer, prohibit any compensation during the strike period, and bar increased compensation of any kind for one year after rehiring; the agreements violated these statutes on their face.

labor & employment

The case concerned a petition to consolidate the Township of Glendale with the Village of Savage in Scott County, Minnesota. The Minnesota Municipal Commission approved the consolidation but excluded two sections of the township; the district court reviewed the order and directed that those sections be included. The commission appealed that decision to the Minnesota Supreme Court. While the appeal was pending, the commission adopted a resolution and issued an amended order incorporating the district court's directive. The Supreme Court dismissed the appeal as moot, holding that the commission's amendment of its own order made it impossible to grant any effective relief to the appellant.

procedure

This case involved consolidated actions for wrongful death and personal injuries arising from a car accident in which defendants Richard Crandall and Jeane Hutchinson's vehicle struck Kenneth Granley and Christopher Wakefield. Crandall's negligence was conceded, leaving the sole issue whether he drove with Hutchinson's implied consent under Minnesota's vicarious liability statute, Minn. St. 170.54, when Hutchinson's daughter allowed him to operate the car in violation of standing instructions. The trial court ruled consent existed as a matter of law, and the jury awarded damages to the plaintiffs. The Supreme Court affirmed, reasoning that a parent permitting a child to use the car is deemed to consent to its operation by third persons with the child's permission when the child is a passenger, based on the policy of the statute and common youthful conduct such as joyriding.

torts & liability

This case concerned the proper standard for a district court's review of a Public Service Commission order granting a limited irregular-route common carrier permit for household goods transportation. The Commission had found insufficient existing carriers to meet area needs and issued the permit to St. Paul Terminal Warehouse Company; competitor Minneapolis Van & Warehouse appealed, arguing the evidence was inadequate. The district court affirmed using a lenient "any evidence" test drawn from prior case law interpreting Minn. Stat. §§ 216.24-.25. The Minnesota Supreme Court reversed and remanded, holding that the 1963 Administrative Procedure Act's substantial-evidence standard under § 15.0425(e) controls review of the Commission's factual findings to ensure uniformity across agencies. The court reasoned that the legislature's enactment of the APA superseded earlier interpretations allowing review based on a mere scintilla of evidence.

procedurebusiness & regulatory

This case concerned the annexation of certain land to the City of Glencoe pursuant to a Minnesota statute permitting annexation by ordinance when the land is 75 percent bordered on three sides by the city. Following objections by the township and hearings before the Minnesota Municipal Commission, which ordered the annexation, affected landowners appealed to the district court and then to the Supreme Court, challenging the commission's jurisdiction and the lack of an election. The court decided that no election was required because the proceedings were initiated by ordinance rather than petition, that the prior ordinance creating the third border could not be collaterally attacked, and that the annexation order was supported by evidence, thus affirming the lower court's decision.

procedureproperty