Edward C. Stringer

In State v. Larsen, a Minnesota conservation officer entered respondent's fish house without a warrant or consent during a routine license check, observed marijuana and three fishing lines (one more than permitted), and charged him with a controlled substance offense and unlawful angling. The district court granted the motion to suppress the evidence and dismissed the charges, ruling that the occupant had a reasonable expectation of privacy in the fish house; the court of appeals affirmed, and the Minnesota Supreme Court affirmed as well. The court reasoned that recreational fishing is a private activity, fish houses are not akin to closely regulated commercial businesses eligible for warrantless administrative inspections, and the statute authorizing entry and inspection at reasonable times must be interpreted to require compliance with constitutional limits under the Fourth Amendment and Minnesota Constitution.

criminal lawprocedureenvironment

In State v. Carney, the defendant was convicted of premeditated first-degree murder after killing a man who was having an affair with his wife. The defendant appealed, arguing that the trial court erred by denying his request for a jury instruction on the lesser-included offense of heat-of-passion manslaughter and by making certain evidentiary rulings regarding photographs and videotape evidence. The Minnesota Supreme Court affirmed the conviction, holding that the evidence did not support giving the manslaughter instruction because the killing involved premeditation, and that the evidentiary decisions were within the trial court's discretion as the excluded evidence was cumulative or violated the best evidence rule while the admitted photo was not prejudicial.

criminal lawprocedure

In State v. Thao, the defendant was convicted after a jury trial of second-degree murder while committing a drive-by shooting for the benefit of a gang, arising from a fatal shooting of a basketball player in a public park from a vehicle occupied by gang members. The district court imposed an upward durational departure from the presumptive sentence based on the number of shots fired, the number of people nearby, and the location of the offense. The Minnesota Supreme Court affirmed the conviction, finding sufficient evidence to support the verdict, but reversed the sentence departure and remanded, holding that the circumstances did not make the offense significantly more serious than a typical drive-by shooting under the relevant statutes. The court reasoned that the elements of the drive-by shooting and second-degree murder statutes already accounted for the recklessness involved in firing from a vehicle, without additional aggravating factors justifying an enhanced sentence.

criminal lawguns

The case involved Jeffrey Hilligoss, a former Cargill employee terminated in 1997, who sued to recover the unpaid portion of his 1996 deferred bonus that Cargill had withheld on the grounds of termination for cause. A jury determined that Cargill lacked cause for the termination, leading to a judgment awarding Hilligoss $506,956.22, which the trial court upheld after denying Cargill's motion for judgment notwithstanding the verdict. The court of appeals affirmed the verdict on most issues but remanded for clarification on damages, and the Minnesota Supreme Court affirmed in full. The core reasoning centered on evidence that Hilligoss received generally positive performance feedback, was not warned of impending termination as per company policy, and that the cited reasons for termination—such as investment losses and travel—did not establish cause under the bonus plan terms. The court also rejected Cargill's arguments regarding jury instructions and evidentiary rulings related to the noncompete provisions in the bonus plan.

labor & employmentbusiness & regulatory

In this case, two individuals injured in snowmobile accidents on trails maintained by the nonprofit Star Trails Association sued the association for negligence. The association sought summary judgment, asserting recreational use immunity under Minn. Stat. §§ 604A.20-.27 and municipal immunity extended by Minn. Stat. § 84.83, subd. 4(a), but the district court denied the motion, ruling that the association did not qualify as an owner entitled to protection. The court of appeals dismissed the association's appeal as not immediately appealable. The Minnesota Supreme Court reversed, holding that orders denying immunity claims are immediately appealable under the collateral order doctrine because they involve rights that would be lost if review were deferred until final judgment, and remanded for further proceedings.

proceduretorts & liability

The case involved a medical malpractice claim brought by the trustee for the heirs of a 14-year-old leukemia patient who died after receiving morphine following a bone marrow transplant. The plaintiff alleged that the University of Minnesota Hospital and the Pediatric Research and Education Foundation negligently failed to recognize and properly treat signs of morphine toxicity. The district court dismissed the case because the plaintiff's expert affidavits did not sufficiently establish the standard of care or causation as required by Minnesota Statute § 145.682. The court of appeals reversed, but the Minnesota Supreme Court reinstated the dismissal, holding that the affidavits lacked the necessary detail on how the defendants' actions caused the patient's death.

torts & liabilityhealthcareprocedure