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

In State v. Gianakos, the defendant was convicted of first-degree murder, conspiracy, and aiding murder after his wife testified against him regarding the killing of a key witness in their prior robbery case. The couple had married shortly before the robbery charges, at least partly to invoke Minnesota's marital privilege statute (Minn. Stat. § 595.02, subd. 1(a)) against adverse spousal testimony, and the wife had pleaded guilty pursuant to a plea agreement. The Minnesota Supreme Court reversed the conviction and remanded, holding that the privilege barred the wife's testimony despite the timing and partial motivation of the marriage, as the statute contains no exception for joint criminal participants or marriages entered with an eye toward litigation. The core reasoning centered on the legislature's policy choice to protect marital relationships by vesting the privilege in the defendant-spouse, with any exceptions to be created only by statute rather than judicially.

criminal lawprocedurefamily law

The case involved a workers' compensation dispute between Judd and Doege Precision Machining, Inc. The Workers’ Compensation Court of Appeals had issued a decision on January 4, 2002. The Minnesota Supreme Court reviewed the files, records, and proceedings and affirmed the lower court's decision without a separate opinion. The affirmation was issued under Minn. R. Civ. App. P. 136.01, subd. 1(b).

labor & employment

The case involved a dispute over whether American National General Insurance Co. was required to provide liability coverage to Paul Solum for a 1997 accident he caused while driving an uninsured pickup truck. American argued that coverage was barred by the policy's owned-vehicle exclusion because title to the truck was held by Paul's wife, Helen Solum; the Solums countered that their son Daniel was the true owner despite the title transfer, which had been made to avoid potential impoundment related to Daniel's prior DUI offenses. The trial court ruled for the Solums after a jury found Daniel to be the owner based on multiple factors including use, maintenance, and payment. The Minnesota Supreme Court affirmed the court of appeals' reversal, holding that substantial compliance with the motor vehicle title-transfer statute (Minn. Stat. § 168A.10) made Helen the incontrovertible owner, precluding extrinsic evidence to the contrary in this insurance-coverage context.

propertytorts & liabilitybusiness & regulatory

In Kaiser v. State, the appellant pleaded guilty to a gross misdemeanor charge of possession of pictorial representations of minors without being advised that he would be required to register as a predatory offender under Minnesota law. He sought to withdraw his plea via postconviction relief, arguing that the lack of advice rendered the plea unintelligent and that the registration requirement was a direct consequence. The district court and court of appeals denied relief, concluding the requirement was collateral. The Minnesota Supreme Court affirmed, holding that because an intervening act of prosecutorial discretion is needed to enforce the registration duty and because the requirement is primarily regulatory rather than punitive, it does not qualify as a direct consequence that must be disclosed for a valid guilty plea. The court emphasized the policy favoring finality of pleas that are accurate, voluntary, and intelligent.

criminal lawprocedure

In State v. Hugger, the defendant was charged with DWI and other offenses after a traffic stop; the district court dismissed the charges for lack of reasonable suspicion to justify the stop. The state filed a notice of appeal 12 days after the district court administrator mailed notice of the dismissal order, but the court of appeals dismissed the appeal as untimely under its calculation of the 5-day appeal period plus 3 days for mail service. The Minnesota Supreme Court reversed, holding that the 5-day period under Minn. R. Crim. P. 28.04 must first exclude weekends and holidays before adding the 3 mailing days under Rule 34.04, making the state's July 9 filing timely. The court based its decision on the plain language and structure of Rules 28.04, 34.01, and 34.04, along with their alignment to analogous federal and civil rules.

criminal lawprocedure

Charles Theo McIntosh was convicted of four controlled substance offenses for selling crack cocaine, including second-degree sale of three grams or more. The district court imposed an upward departure from the presumptive 98-month sentence to 122 months on the ground that the offense qualified as a major controlled substance offense under the sentencing guidelines because it involved multiple transactions, quantities substantially larger than for personal use, and the defendant's high position in the drug distribution hierarchy; the court of appeals affirmed. The Minnesota Supreme Court reversed, holding that the record did not support application of the major controlled substance offense factors, particularly the absence of evidence that the defendant occupied a high position in the hierarchy or that the quantities sold exceeded personal-use amounts in the relevant statutory context, and remanded for imposition of the presumptive guidelines sentence.

criminal law

The case involved a negligence lawsuit filed by W.G.O. on behalf of his then-twelve-year-old son, A.W.O., who was injured when his bicycle was struck by a car driven by Mary Crandall at an intersection in 1993. A jury found Crandall 80% at fault and awarded damages, but Crandall appealed, arguing that the trial court should have instructed the jury on the emergency rule and that certain expert testimony lacked proper foundation. The Minnesota Supreme Court reversed the court of appeals' affirmance and remanded for a new trial on liability only, holding that the evidence permitted a finding that any emergency was not created by the driver's own negligence and thus the emergency rule instruction should have been given to the jury.

torts & liabilityprocedure

The case involved Great Lakes Gas Transmission, which operates a natural gas pipeline through Minnesota and sought a refund of use taxes paid on natural gas consumed as fuel for its compressor engines. The Minnesota Supreme Court affirmed the tax court's ruling that while the consumption of the gas constituted a taxable event under the use tax statute, Minn. Stat. § 297A.14, the gas was exempt from taxation under Minn. Stat. § 297A.25, subd. 9, because it was consumed in the industrial production of personal property intended to be sold ultimately at retail. The court reasoned that Great Lakes exercised control over the gas by consuming it as fuel, satisfying the purchase and use requirements for taxation, but the industrial production exemption applied to the pipeline operations. The court did not address constitutional issues raised regarding interstate commerce.

taxesbusiness & regulatory

The case involved Arturo Alcozer's claim for workers' compensation benefits after he was allegedly injured while participating in a Polk County Community Work Experience Program (CWEP) assignment at North Country Food Bank, a requirement tied to his family's receipt of AFDC benefits. Alcozer's claim against North Country and the county was dismissed by the Department of Labor and Industry and affirmed by the Workers' Compensation Court of Appeals on the grounds that he was not an "employee" under Minn. Stat. § 176.011 and that the state's Injury Protection Program (IPP) under Minn. Stat. § 256.737 provided the exclusive remedy for such injuries. The Minnesota Supreme Court affirmed the dismissal, holding that the IPP statute expressly makes its procedures exclusive of all other remedies, including workers' compensation, for participants in county-administered community work experience programs. The court reasoned that the IPP was designed as an alternative to workers' compensation coverage for these welfare-to-work placements, as permitted by federal regulations, and that the legislature intended to limit remedies to those specified in the IPP.

labor & employmenthealthcare

The case involved a former receptionist who sued her employer, an orthodontist and sole shareholder of the practice, for assault, battery, intentional infliction of emotional distress, and negligence based on multiple incidents where he struck her on the head while reprimanding her for work errors. The district court granted summary judgment dismissing the claims, and the court of appeals affirmed, holding that the employer was immune under the Minnesota Workers' Compensation Act. The Minnesota Supreme Court affirmed, ruling that the defendant qualified as an employer entitled to immunity under the Act and that the plaintiff failed to raise a genuine issue of material fact showing the intentional injury exception applied, as the evidence did not establish a conscious and deliberate intent to inflict injury.

labor & employmenttorts & liability

In this case, Northwest Airlines challenged the assessed property tax values of the Main Base Building it leased at the Minneapolis/St. Paul International Airport for tax years 1997-1999 by filing petitions under Minnesota Statutes chapter 278. The county moved to dismiss the petitions related to the Main Base Building because Northwest failed to provide required income and expense information within the 60-day deadline under Minn. Stat. § 278.05, subd. 6(a). The tax court ruled that the building was income-producing property due to the arm's-length lease requiring monthly rent payments and dismissed the petitions for noncompliance. On review, the Minnesota Supreme Court affirmed, holding that the statutory deadline applied because income was generated from the use of the property and the failure to submit the information was not excused by unavailability of evidence. The decision turned on the interpretation of 'income-producing' to include leased property generating rental payments, even though the building itself is tax-exempt as MAC-owned.

taxespropertyprocedure

The case involved Christopher David Nelson, convicted by a jury of aiding and abetting first- and second-degree murder in the 1996 death of Gregory Johnson, whose dismembered body was found months later; Nelson and co-defendant Scott Carter were the last to see Johnson alive, and Carter testified against Nelson after pleading guilty. Nelson appealed, arguing insufficient evidence and improper admission of Spreigl evidence from two prior armed robberies. The Minnesota Supreme Court affirmed the conviction, concluding that the circumstantial evidence formed a complete chain excluding any reasonable inference other than guilt beyond a reasonable doubt, and that the other-crimes evidence was properly admitted with limiting instructions solely to help the jury assess whether Nelson committed the charged acts.

criminal lawprocedure

This case involved the validity of a no-knock search warrant executed at the Garza residence in connection with a controlled drug buy and related investigation into marijuana trafficking by Xavier Garza Jr. The trial court denied suppression of evidence seized during the unannounced search, leading to convictions on stipulated facts for fourth-degree controlled substance crimes, but the court of appeals reversed. The Minnesota Supreme Court held that the warrant affidavit provided only general statements about drug traffickers destroying evidence or using violence, without the particularized facts required under the Minnesota Constitution to justify an unannounced entry into a home. As a result, evidence from the dwelling was suppressed, while the ruling on evidence from an outdoor shed was reversed and remanded for a determination of whether the shed was within the curtilage. The court further concluded that police good faith reliance on the magistrate's authorization could not cure the lack of particularized justification for the no-knock provision.

criminal lawprocedure

In Witso v. Overby, a man claiming to be the biological father of a child born to a married woman petitioned under the Minnesota Parentage Act for an order compelling the mother and child to submit to genetic testing to establish his paternity and standing as a presumed father, despite the child already having a presumed father by marriage. The district court granted the petition, and on a certified question the court of appeals affirmed, holding that the putative father could proceed based on an affidavit alleging sexual contact during the conception period. The Minnesota Supreme Court affirmed, ruling that under Minn. Stat. § 257.57, subd. 2(1) and § 257.62 a putative father need not already possess genetic test results to initiate the action or compel testing, as the statute permits standing upon a sufficient showing of sexual contact that could lead to conception. The core reasoning was that the MPA creates standing for such claims through statutory presumptions and procedures without requiring prior proof of a genetic presumption, leaving ultimate custody or visitation issues for later determination.

family lawprocedure