John E. Simonett

This case involved the civil commitment of Peter Rickmyer as a psychopathic personality under Minnesota statutes following his guilty plea to second-degree criminal sexual conduct for spanking an 8-year-old boy. The trial court found Rickmyer met the criteria based on his history of sexual contact with children, lack of impulse control, and likelihood of reoffending, leading to his commitment to the Minnesota Security Hospital. The Minnesota Supreme Court reversed the commitment, concluding that the evidence failed to show Rickmyer was likely to inflict serious physical or mental harm. The court reasoned that the psychopathic personality statute, as interpreted in Pearson, requires a showing of habitual misconduct, uncontrollable impulses, and potential for injury of the type that meets the statutory threshold, which nonviolent touching and spanking incidents did not satisfy.

criminal lawprocedure

This case concerns a dispute over farmland subject to Minnesota's family farm foreclosure statute, Minn. Stat. § 500.24, and a former owner's statutory right of first refusal. Metropolitan Life Insurance sold the property to plaintiff Noel Kjesbo under a contract that was subject to defendant Valerie Ricks' right of first refusal; Ricks exercised that right with financing from defendant Douglas Daniels, then conveyed portions of the land to her son and to Daniels in a series of transactions. The trial court granted summary judgment to Kjesbo on his claims for tortious interference with contract and violation of the statute, but the court of appeals reversed, finding factual issues about the parties' intent. The Minnesota Supreme Court reversed the court of appeals, holding that the manner in which the right of first refusal was exercised did not constitute unjustified interference with Kjesbo's contract and remanded the case. The core reasoning focused on whether the defendants' actions satisfied the elements of tortious interference, particularly the lack of justification, and on the statute's family exception to its anti-flipping provisions.

propertytorts & liabilityfamily law

In State v. Trong Kim Huynh, the defendant was convicted of racketeering under Minnesota's RICO statute after he and associates repeatedly threatened to kill a Vietnamese restaurant owner and his family unless the owner paid $1,000-$1,500 monthly, with payments made via checks and money orders routed through Texas entities in a manner consistent with money laundering. The Minnesota Supreme Court affirmed the conviction and the trial court's assignment of severity level VIII for sentencing. The court held that an "enterprise" under Minn. Stat. § 609.903 requires an ascertainable structure distinct from the predicate acts of coercion, and the evidence here established such an organized pattern of activity involving multiple participants, coordinated threats, and systematic collection and transfer of payments. The opinion clarified that sporadic crimes alone do not suffice and that the enterprise element must remain separate from the pattern of criminal activity requirement.

criminal law

The case involved a bar owner who challenged two city ordinances banning nudity in establishments with liquor licenses, claiming they violated free expression rights under the Minnesota Constitution. The ordinances were enacted after complaints about nude dancing at the bar, and the city denied license renewal based on violations of them. Lower courts ruled the ordinances unconstitutional, finding they targeted protected speech without legitimate governmental interests. The Minnesota Supreme Court reversed, holding that the Twenty-first Amendment grants states broad authority to regulate liquor sales and prohibit nudity in bars, which does not infringe on the state constitution's free speech protections even for non-obscene expressive conduct.

free speechbusiness & regulatoryfederal power

In State v. Kelly, the defendant was convicted of multiple prostitution-related offenses, including soliciting, promoting, and receiving profits from the prostitution of juveniles, as well as one count of racketeering under Minnesota's RICO statute. The Supreme Court of Minnesota reversed only the racketeering conviction. The court held that the evidence failed to establish the defendant's association with an "enterprise" as defined by the statute, because the prostitution activities involved a loose group of individuals primarily supporting the defendant's personal heroin habit rather than constituting organized crime with the required structure and continuity. The court distinguished this from the type of racketeering the RICO law was intended to address and noted that the other convictions and sentences remained in place.

criminal law

This case involves an employee, Albert, who obtained a verdict against a third-party tortfeasor, Paper Calmenson & Co. (PaCal), for workplace injuries, while also receiving workers' compensation benefits from his employer, MAK Oil. The Minnesota Supreme Court granted limited further review to address allocation of the verdict proceeds under the Lambertson contribution framework. The court directed that PaCal pay Albert the full verdict amount of $1,962,108; MAK Oil then contribute to PaCal its proportionate share of negligence (capped at the $654,036 in benefits paid or payable); and Albert reimburse MAK Oil $362,121 under Minn. Stat. § 176.061, subd. 6(c), leaving MAK Oil a $334,216 credit against future benefits. The allocation follows precedents such as Johnson v. Raske Building Systems and Kempa v. E.W. Coons Co. All other aspects of the petitions for review were denied.

labor & employmenttorts & liability

The case involved the University of Minnesota seeking insurance coverage for asbestos removal costs from buildings after settling claims against an asbestos product manufacturer and assigning the claims to the Regents. The insurers denied coverage under pollution exclusion clauses in both primary and excess comprehensive general liability policies. The Minnesota Supreme Court held that the standard pollution exclusion in the primary policies did not apply because the release of asbestos fibers inside buildings was not a discharge of pollutants into land, the atmosphere, or water as the clause contemplated. However, the court found that the broader exclusion language in the excess policies did bar coverage for the claims.

environmentpropertybusiness & regulatory

The case involved Alice Beaudry, who was injured in a car accident caused by an underinsured driver and later died of unrelated cancer while pursuing underinsured motorist (UIM) benefits from her insurer, State Farm. After settling with the tortfeasor, Beaudry and her husband sued State Farm for UIM coverage, but the trial court ruled that her claim abated upon her death under Minnesota's survival statute, which provides that causes of action arising out of personal injury die with the person except for special damages. The court of appeals reversed, treating the UIM claim as a surviving contract action, but the Minnesota Supreme Court reversed that decision and reinstated summary judgment for State Farm. The court reasoned that UIM benefits are measured by tort damages the claimant could have recovered from the underinsured driver, making the claim primarily one for personal injury rather than a pure contract action, so it abates upon the claimant's unrelated death. The ruling noted that any special damages component could survive under the statute, and the husband's separate claim was unaffected.

torts & liabilityprocedure

The case involved defendant Willie Earl Robinson's convictions for first-degree sale of a controlled substance (10 grams or more of a cocaine mixture) and second-degree possession after police seized 13 packets of a white substance from a car. The Minnesota Supreme Court reversed the first-degree sale conviction because the state tested at most 7 packets totaling under 9 grams, and the evidence was insufficient to prove beyond a reasonable doubt that the total mixture met the 10-gram threshold, despite circumstantial indications of drug dealing. The court remanded for resentencing on the lesser second-degree offense and affirmed the trial court's constructive possession jury instruction as adequate without needing additional language on exclusive control.

criminal law

In State v. Dezso, a state trooper stopped the defendant for speeding, requested he sit in the squad car, and after returning his license began questioning him about the contents of his wallet, eventually obtaining and searching it to discover LSD. The Minnesota Supreme Court reversed the conviction for fifth-degree possession of a controlled substance, ruling that the wallet search was invalid and the evidence must be suppressed. The court reasoned that under the totality of the circumstances the state failed to prove voluntary consent, as the officer's persistent official questioning, physical leaning, and the defendant's equivocal responses indicated submission rather than free agreement, and discovery of the drugs was not inevitable following an ordinary traffic stop.

criminal lawprocedure

This case involved a dispute over whether a crossclaim for contribution and indemnity by one defendant (consulting engineers) against another (manufacturer) could proceed after the plaintiff's original claims against the manufacturer were barred by the UCC's 4-year statute of limitations for breach of warranty on goods. The Minnesota Supreme Court held that the crossclaim survives and reversed the court of appeals. The court reasoned that contribution and indemnity are independent equitable causes of action under common law, requiring only common liability to the plaintiff (even if based on different theories like negligence versus breach of warranty) and payment of more than a fair share, rather than being directly governed by the underlying contract claim subject to the UCC limitations period. The 2-year statute for defective improvements to real property was deemed applicable instead, allowing the claim to proceed after settlement.

proceduretorts & liability

In Bauer v. State, a state employee at a treatment center sued her supervisors personally for defamation after they documented complaints about client treatment and her subsequent suspensions and termination, following her whistleblower allegations. The trial court denied summary judgment on the defamation claim, and the court of appeals affirmed, treating malice as a factual issue. The Minnesota Supreme Court reversed on the immunity question, holding that official immunity does not apply to common-law defamation actions because the truth or falsity of a statement is not a discretionary judgment protected by the doctrine. Instead, the court ruled that qualified privilege governs such workplace statements about job performance, with the case remanded for further proceedings applying the correct malice standard under that privilege.

labor & employmenttorts & liability

The case involved Edward Potter Dolbeare's conviction for first-degree felony murder after he entered Russell Miller's apartment, struggled with Miller, and left him to asphyxiate while stealing credit cards and other items. Dolbeare appealed on grounds that the trial court erroneously admitted certain testimony about prior acts, gave an improper self-defense jury instruction, and allowed prosecutorial misconduct in closing arguments. The Minnesota Supreme Court affirmed the conviction, holding that any improper evidence was harmless in light of the strong proof of guilt, that the instruction did not prejudice the defendant, and that no misconduct occurred. The court also observed that the evidence may not have warranted a self-defense instruction at all.

criminal lawprocedure

The case involved the first-degree murder conviction of Rene Julian McKenzie for the 1991 killing of Perry Pajunen, where McKenzie was accused of either shooting the victim or aiding and abetting his associate Ian James in the crime after a dispute over a stolen rental car. On appeal, McKenzie challenged the sufficiency of the evidence, the admission of certain testimony, and alleged prosecutorial misconduct during closing arguments. The Minnesota Supreme Court affirmed the conviction, holding that the jury could reasonably have found McKenzie guilty based on witness testimony describing his confession and planning discussions, and that any evidentiary or argument errors were harmless.

criminal lawprocedure

This case concerned whether Marie Stiernagle, who sold her farm under a contract for deed but continued to reside there and pay the real estate taxes, qualified for a homestead tax classification. The Minnesota Supreme Court reversed the Tax Court's ruling in her favor, holding that she was not entitled to the classification. The court reasoned that a contract for deed effects an equitable conversion, vesting equitable ownership in the vendee while the vendor retains only bare legal title as security, and that the statute requires the land to be occupied and used as a homestead by its owner. Possession alone does not suffice for homestead status, as one can occupy land without owning it.

propertytaxes

This case concerned the indefinite civil commitment of Dwight Walton as a psychopathic personality under Minn. Stat. §§ 526.09-.10, following his convictions for multiple sexual offenses and a determination that he posed a risk of recidivism. Walton appealed the trial court's commitment order, which was affirmed by the court of appeals, claiming the statutes were unconstitutional under the Due Process and Equal Protection Clauses based on the U.S. Supreme Court's ruling in Foucha v. Louisiana. The Minnesota Supreme Court affirmed the commitment, concluding that its prior decision in In re Blodgett directly controlled and upheld the statutes as constitutional. The court reasoned that the statutory criteria and commitment procedures satisfied constitutional requirements without needing further analysis beyond the Blodgett precedent.

criminal lawcivil rightsprocedure

The case involved Phillip Jay Blodgett's challenge to his civil commitment as a psychopathic personality under Minn.Stat. § 526.09-.10, based on his history of sexual assaults, violence, and refusal of treatment programs. The trial court found by clear and convincing evidence that Blodgett met the statutory criteria for commitment due to his antisocial personality disorder and dangerousness, and rejected his constitutional challenge. On appeal, the Minnesota Supreme Court affirmed, holding the Act constitutional because it requires proof of a mental disorder and dangerousness, consistent with precedents like Foucha v. Louisiana, and provides adequate procedural protections. The court rejected arguments that the statute was vague, overbroad, or violated due process or equal protection, noting that the commitment served public safety purposes even if treatment options were limited.

criminal lawcivil rightsprocedure

The case involved a wrongful death lawsuit by a child's grandfather against Ramsey County and its social worker, alleging negligence in failing to prevent the child's death from ongoing abuse by his mother, despite a prior child protection report and a formulated case plan requiring monitoring and contacts. The Minnesota Supreme Court held that discretionary function immunity and official immunity shielded the defendants from claims related to the creation and design of the child protection case plan, but not from claims about its implementation. On the implementation claim, the court found as a matter of law that the social worker had no duty to make in-person visits to the child under the plan's terms, which used vague language allowing other forms of contact and assigned primary monitoring to other providers, and thus there was no negligence or proximate cause. The court affirmed in part and reversed in part the lower courts' denial of summary judgment.

torts & liabilityprocedurefamily law

This case concerned whether Minnesota could apply its general transaction-based sales and use tax to railroad rolling stock and repair parts after repealing an earlier exemption tied to the gross earnings tax. The Minnesota Supreme Court held that the tax, as applied to railroads, violated federal law under Section 306 of the 4-R Act, which prohibits states from imposing taxes that discriminate against rail carriers. The court reasoned that the tax was facially discriminatory because comparable property used by barge lines and commercial airlines was exempt and motor carriers faced an alternative tax regime, without any need to prove actual competitive harm or overall tax fairness. It therefore reversed the Tax Court’s decision to recompute the tax on a transaction basis and ordered a refund of taxes paid by Burlington Northern.

taxesbusiness & regulatoryfederal power

In this workers' compensation dispute, employee James Franke suffered a severe hip injury in a 1978 work-related accident while employed by Fabcon, Inc., leading to ongoing issues with his hip and back; the parties settled all claims in 1986 for a lump sum, with the compensation judge issuing an award on stipulation. After Franke's condition substantially worsened, requiring hip replacement surgery and causing permanent disability, he petitioned in 1993 to vacate the 1986 award based on a change in medical condition. The Workers' Compensation Court of Appeals denied the petition, applying the 1992 statutory amendments and finding the worsening could reasonably have been anticipated. The Minnesota Supreme Court reversed, holding that the amendments preserved prior case law allowing vacation of awards for substantial unanticipated changes in condition and remanded for a hearing on the petition.

labor & employmentprocedure