James C. Otis

The case involved a workers' compensation claim by truck driver George Rogde, who suffered a work-related back injury resulting in a 10% permanent partial disability and sought continued temporary total disability benefits after his employer's insurer discontinued payments in November 1979. The Minnesota Supreme Court reversed the compensation judge and Workers' Compensation Court of Appeals, denying benefits after that date. The court held that Rogde had not met his burden of proving total incapacity from gainful employment under Minn. Stat. § 176.101, subd. 2, because undisputed evidence showed he was capable of light work (lifting up to 25 pounds), made no diligent efforts to seek employment or regain his revoked driver's license, refused alcoholism treatment, and had already received compensation for his partial disability.

labor & employment

The case involved a defendant convicted by a jury of first-degree criminal sexual conduct and aggravated robbery for raping and robbing a university student. The defendant appealed, arguing that identification testimony from the victim and two Spreigl witnesses was improperly admitted, references to mug shots prejudiced the jury by suggesting a prior criminal record, and the prosecutor engaged in misconduct during cross-examination and closing argument. The Minnesota Supreme Court affirmed the convictions, holding that the defendant had forfeited some claims by failing to object in a timely manner, that the identification procedures were confirmatory rather than unduly suggestive, and that any evidentiary issues or unobjected-to conduct did not constitute prejudicial error warranting reversal.

criminal lawprocedure

In State v. Johnson, the defendant was convicted by a jury of first-degree criminal sexual conduct under Minn. Stat. § 609.342(a) (1980) for sexually penetrating a 12-year-old girl after approaching her and other children in a park, luring her away, and using a knife to force the assault. The trial court excluded expert testimony that the defendant was a chronic alcoholic whose intoxication was involuntary, and it imposed an upward departure sentence of 240 months rather than the presumptive 132 months. The Minnesota Supreme Court affirmed the conviction and sentence, holding that self-induced intoxication by a chronic alcoholic constitutes voluntary intoxication that does not provide a defense to a general-intent crime, and that aggravating factors such as particular cruelty justified the sentencing departure.

criminal law

This case involved a criminal defendant's appeal of his conviction for cocaine possession, which stemmed from a pretrial ruling denying his motion to suppress evidence obtained during a police encounter at the State Fair. The Minnesota Supreme Court affirmed the conviction, holding that the officer's investigation did not violate the Fourth Amendment. The court reasoned step by step that the officer was justified in approaching the illegally parked vehicle, shining a flashlight inside, investigating an apparent open-bottle violation based on visible plastic cups, reaching into the defendant's pocket after observing furtive movements and a possible weapon, and opening the discovered package, as each action was supported by reasonable suspicion or probable cause under the circumstances.

criminal law

The case involved a defendant charged with attempted first-degree murder, first-degree assault, and two counts of first-degree criminal sexual conduct for beating and sexually assaulting a woman he knew in St. Paul. A jury acquitted him of attempted murder and one sex offense but convicted him of assault and the remaining sex offense, after which the trial court imposed an upward departure sentence of 90 months instead of the presumptive 54 months. On appeal, the defendant sought reversal based on insufficient evidence of identification or a new trial due to allegedly prejudicial admission of Spreigl evidence regarding a similar prior incident. The Minnesota Supreme Court affirmed, holding that the victim's positive identification was credible with no apparent motive to lie and that the Spreigl evidence was properly admitted to corroborate her testimony under controlling precedent.

criminal lawprocedure

The case involved a City of Minneapolis employee injured in a work-related auto accident who received workers' compensation benefits and sought additional no-fault economic loss benefits from the city as a self-insurer under Minnesota's reparation security statutes. The trial court ruled that the employee could stack the benefits without limit under pre-amendment law, but the Minnesota Supreme Court reversed in part. The court held that municipalities must provide no-fault coverage despite workers' compensation immunity exceptions, but a 1980 statutory amendment preventing stacking of no-fault and workers' compensation benefits above $200 weekly applied to the employee's future losses. The core reasoning was that basic economic loss benefits accrue as losses are incurred over time rather than at the date of injury, so the amendment governed post-April 1980 payments, consistent with the statute's prospective language and legislative clarification of prior intent.

torts & liabilitylabor & employment