John J. Todd

Telephone Associates, Inc. submitted a bid to St. Louis County for installation of phone service but lost to Norstan Communications Systems, Inc. despite submitting a lower bid. The trial court denied injunctions, but the court of appeals reversed, and the Minnesota Supreme Court affirmed the reversal while remanding for appropriate relief. The court found that the county improperly inserted a maintenance cost figure into Norstan's bid during evaluation, violating bidding rules. Since the system was already installed, the court awarded the low bidder its bid preparation costs and expenses under promissory estoppel rather than requiring removal or lost profits.

business & regulatoryprocedure

The case involved Mary Ann Jackson, who was convicted after a bench trial of uttering a forged instrument, aggravated forgery, and theft by check based on her use of a forged check and identification to purchase a watch. The trial court imposed three concurrent stayed sentences, which the court of appeals affirmed as to the sufficiency of the evidence and the convictions but modified by vacating two sentences under Minn. Stat. § 609.035. The Minnesota Supreme Court affirmed that the eyewitness identifications and other evidence supported the convictions and that two sentences must be vacated for a single behavioral incident, but reversed on the multiple-conviction issue. It held that Minn. Stat. § 609.04 bars formal adjudications of conviction for both aggravated forgery and uttering a forged instrument under different subdivisions of the same statute when they arise from one incident, and therefore vacated the uttering conviction.

criminal lawprocedure

The case involved a declaratory judgment action by Federated Mutual Insurance Co. against its insured, Concrete Units, Inc., to determine whether the insurer had a duty to defend or indemnify Concrete Units for claims by a construction company and its client arising from defective concrete supplied for a grain elevator project. The trial court ruled in favor of coverage, but the Minnesota Supreme Court affirmed in part and reversed in part. The court held that certain claims for loss of use of the elevator qualified as covered "property damage" caused by an "occurrence" under the comprehensive general liability policy, while other claims for repair costs, interest, and lost profits did not trigger the duty to defend or indemnify. Core reasoning focused on the policy's definitions of property damage and occurrence, along with the scope of exclusions for damage to the insured's own product or work, which did not bar coverage for third-party property losses.

business & regulatorypropertytorts & liability

In State v. Stark, the defendant was charged with driving while under the influence of alcohol and driving with a blood alcohol concentration of .10 or more after being stopped for erratic driving and submitting to a breath test showing over .15. The jury convicted him on the first charge but acquitted on the second. The district court appeal panel vacated the conviction, finding errors in the trial court's jury instructions on the elements of driving under the influence and in its responses to jury questions during deliberations. The reviewing court reversed the appeal panel, holding that the instructions were not erroneous when read as a whole, the responses to the jurors did not coerce a verdict or fail to address confusion, and the trial court properly submitted both charges. As a result, the conviction was reinstated.

criminal lawprocedure

The case involved defendant Ortlepp, a former police chief, who was convicted by a jury of aggravated criminal damage to property and unjustifiably killing an animal after he and an accomplice allegedly shot at a house and dogs in retaliation during a high-speed chase over a stolen lawnmower. The trial court stayed sentencing on the felony and imposed probation and jail time. On appeal, the Minnesota Supreme Court affirmed the convictions, holding that the accomplice's prior statement to police was admissible as substantive evidence of guilt, that the evidence was sufficient to support the verdicts even without that statement, and that there was no error in the aiding-and-abetting jury instruction or in the effectiveness of defense counsel.

criminal lawprocedure

The case Williams v. State concerns whether amendments to Minnesota's sentencing guidelines in 1983 require automatic reductions in previously imposed sentences for inmates like Williams, and whether a trial court's failure to file a departure report invalidates a sentencing departure. The Minnesota Supreme Court affirmed the Court of Appeals' ruling that sentence reductions are not automatic under Minn.Stat. § 244.09, subd. 11, as the statute allows for justified durational departures from new presumptive sentences. However, it reversed on the departure report issue, holding that the trial court's reasons sufficed despite the missing report, and prospectively adopted strict rules requiring stated reasons for departures to ensure compliance with guidelines.

criminal lawprocedure

In this workers' compensation case, employee Lulabell Cavanaugh sought permanent total disability benefits after sustaining back injuries in 1974 while performing heavy manual labor at a pool table manufacturing plant, following the end of her temporary total disability payments. The Minnesota Supreme Court reversed the Workers' Compensation Court of Appeals' affirmance of the compensation judge's determination that she had not proved permanent total disability by a preponderance of the evidence. The court held that the employee established her claim, finding that her physical condition from the work-related injuries, combined with her age, education, intelligence, personality factors, and limited work options, rendered her unable to secure anything more than sporadic employment. This conclusion rested on undisputed medical evidence from an orthopedic surgeon and psychiatrist causally linking her ongoing symptoms and unemployability to the injuries, which rendered the contrary findings manifestly contrary to the record.

labor & employment

In State v. Vaughn, the defendant was convicted by a jury on three counts of knowingly transferring stolen property valued at $150 or more after selling items to undercover police officers posing as fences. He appealed, arguing insufficient evidence to prove the property was stolen or met the value threshold, failure to disprove entrapment, multiple trial court errors regarding hearings, continuances, evidence admissibility, and witness preclusion, as well as sentencing miscalculations under the Hernandez method and lack of credit for prior jail time. The Minnesota Supreme Court affirmed the convictions and sentences, finding sufficient independent corroboration of the defendant's statements to establish the corpus delicti, no government inducement for entrapment, proper exercise of discretion in trial rulings, and correct application of sentencing rules. The court reasoned that the evidence supported the jury's findings on all elements and that procedural sanctions and computations complied with precedent and statutes.

criminal lawprocedure

This case concerned an employee's appeal challenging a Workers’ Compensation Court of Appeals order that remanded an employer's challenge to a rehabilitation specialist’s decision awarding rehabilitation services. The court reversed the remand, ruling that the Rehabilitation Review Panel lacked jurisdiction over the employer’s appeal. The reasoning centered on Minn. Stat. § 176.102, subd. 6, which requires any appeal from a rehabilitation specialist’s decision (treated as the commissioner’s) to be filed with the Rehabilitation Review Panel within 30 days, a deadline the court held to be jurisdictional based on analogous precedent. Because the employer skipped this step, the WCCA could not confer jurisdiction through remand.

labor & employmentprocedure

In State v. Christianson, the defendant was convicted of first-degree murder after shooting and killing his wife's lover with a shotgun at her workplace, following discovery of their affair. On appeal, Christianson challenged the sufficiency of evidence for premeditation, the trial court's refusal to instruct the jury on first-degree manslaughter, certain evidentiary admissions, and alleged prosecutorial misconduct. The court affirmed the conviction, holding that multiple facts—including the purchase and modification of the gun, prior threats, and the manner of the shooting—supported a finding of premeditation under Minnesota law. It also ruled there was no evidentiary basis for a manslaughter instruction based on heat of passion and provocation, that any evidentiary issues caused no prejudice, and that prosecutorial conduct did not deny a fair trial.

criminal lawprocedure

In State v. Gist, the defendant was convicted by a jury of attempted aggravated robbery after he and an accomplice approached the victim outside his home, displayed a gun, and demanded money before fleeing when the victim's sister opened the door. The trial court imposed a durational departure from the presumptive 54-month sentence, sentencing the defendant to 108 months to run consecutively to a prior sentence. On appeal, the defendant challenged the sufficiency of the evidence, the admission of the sawed-off shotgun found in the accomplice's home, the use of prior convictions for impeachment, and the sentencing departure. The court affirmed the conviction, holding that the evidence was sufficient and that the trial court did not err in its evidentiary rulings, but reduced the sentence duration to 36 months on the ground that no aggravating circumstances existed to justify the double durational departure.

criminal lawprocedure

This case involved a conservatorship proceeding for Rudolfo Torres, a 57-year-old man who had been comatose and dependent on a respirator since July 1983 due to severe, irreversible brain damage from an accident and subsequent cardiopulmonary arrest. The Hennepin County Probate Court authorized the conservator to order removal of the respirator after a hearing with medical evidence and input from counsel for the patient, the conservator, and the medical center. The Minnesota Supreme Court affirmed that decision, holding that the conservator could discontinue treatment when it was in the conservatee's best interests based on clear medical findings of no reasonable chance of recovery, a permanent vegetative state, and lack of any cortical function. The court emphasized the need for judicial oversight in such end-of-life decisions while noting that the patient's court-appointed counsel and conservator had properly represented his interests throughout the process.

healthcarefamily lawprocedure

The case involved defendant Patricelli's conviction for aiding and abetting aggravated robbery by driving the getaway car during an armed robbery of a bakery. He appealed seeking reversal on grounds of insufficient evidence, a new trial due to admission of his inculpatory statement to police, and modification of his sentence with additional jail credit. The court affirmed the conviction, holding that the accomplice testimony was properly corroborated by the defendant's statement and other evidence, and that the statement was voluntary and admissible. It also affirmed the sentence duration but modified it to grant credit for pretrial jail time served in another county on a separate charge because the sentences were concurrent.

criminal law

The case involved a defendant who, after waiving a jury trial, was convicted of marijuana possession in excess of 1.5 ounces based on evidence seized during a search of his person and apartment. He appealed, claiming the affidavit for the search warrant did not establish probable cause because it relied on unreliable hearsay from a confidential informant, the information was stale, and the premises were inadequately described. The court affirmed the conviction, reasoning that police observation of a controlled purchase, the defendant's prior drug convictions, and the direct connection to the apartment supported probable cause; the information was timely given the circumstances; and the warrant adequately identified the location for execution.

criminal lawprocedure

The case involved a lawsuit by Mona Glassman and her son against Beltrami County for injuries from a car accident allegedly caused in part by the county's negligent road maintenance. The plaintiffs had not provided the required notice of claim to the county under Minnesota statute, leading the trial court to dismiss the county as a defendant. The Minnesota Supreme Court reversed the dismissal, holding that the statutory provision barring suits without notice violated equal protection by irrationally distinguishing between victims of municipal and state torts. The court struck the language requiring notice as a prerequisite to maintaining an action against municipalities.

civil rightsproceduretorts & liability

This case involved a contract dispute in which construction company Zobel & Dahl sued homeowner David Crotty for the unpaid balance on building a residence near Duluth, after Crotty withheld payment citing defects including a sagging roof truss. A jury found that Crotty breached the contract by refusing to allow repairs and calculated his damages at $9,350 while awarding Zobel & Dahl $10,872.13, leading the trial court to enter judgment for the builders without offsetting the defects. The Minnesota Supreme Court affirmed the liability determination based on common-law principles allowing builders the opportunity to cure defects upon substantial completion, but reversed the damages ruling and remanded for further proceedings on Crotty's direct claims against subcontractor Builders Supply for negligence and product liability, as the trial record lacked explanation for dismissing those claims. The court also upheld the admission of evidence about Crotty's prior real estate broker license revocation.

propertyproceduretorts & liability

This case involved an employee who was denied temporary total disability benefits under workers' compensation after a compensation judge found her disability resulted substantially from non-work-related agoraphobia, with her 1974 work-related arm injury not contributing substantially. The Workers’ Compensation Court of Appeals affirmed in a 3-2 decision. The Minnesota Supreme Court affirmed the denial as to the psychiatric condition, finding substantial evidence supported the lack of causal connection to employment, but reversed as to the arm injury. The court held that the record showed the repetitive arm motions required by her meat-wrapping job caused ongoing tendonitis and related symptoms that substantially contributed to her total disability, as confirmed by orthopedic experts and a vocational consultant who found her unemployable due to the physical limitations alone.

labor & employment

This case involved judicial disciplinary proceedings against Minnesota Judge Robert F. Johnson. The Board on Judicial Standards filed a stipulation addressing prior misconduct by the judge, recommending public censure and a $1,000 fine, and later pursued additional charges concerning inexcusable delay in deciding one case and improper handling of 36 probate matters from before the judge's full-time appointment. A referee conducted a hearing, found the additional conduct prejudicial to the administration of justice, and recommended sanctions treating the matters as isolated. The court accepted the Board's recommendations, imposed censure for the conduct in both the stipulation and the referee's findings, and ordered the $1,000 fine, reasoning that further discipline for overlapping conduct would add nothing of substance and that the new issues involved mitigating factors such as completed estates and no complaints from parties.

procedure

In State v. Kumpula, the defendant was convicted by a jury of aggravated robbery and assault with a dangerous weapon stemming from an armed robbery of a drug store in Hilltop, Minnesota, during which he stole narcotics and assaulted a witness during his getaway. The defendant appealed, arguing that the evidence was insufficient to support the convictions and that the trial court erred by denying his motion to suppress evidence, admitting Spreigl evidence of prior bad acts, and allowing certain photographs into evidence. The Minnesota Supreme Court affirmed the convictions, holding that the evidence of guilt was legally sufficient and that the trial court did not err in its evidentiary rulings, including that the relevance of the photographs and other evidence outweighed any potential unfair prejudice.

criminal lawprocedure

Jon Schulte was discharged from his trucking job, initially awarded unemployment benefits by the claims deputy, and collected them for several months before returning to work. His employer appealed the award, but Schulte did not participate in the hearings because he was re-employed; the appeal tribunal reversed the award in his absence, and he was later notified of an overpayment requiring repayment of over $3,000 when he sought new benefits. The court considered whether the notices of the employer's appeal and the tribunal's reversal satisfied due process by adequately informing him that reversal would create liability for repaying benefits already received, which could be offset against future claims. It held that the notices were constitutionally deficient because they omitted this critical consequence, and therefore reversed the commissioner's refusal to reopen the proceedings and remanded for a de novo hearing on eligibility.

labor & employmentprocedure