Esther Tomljanovich

The case involved a patient's dental malpractice claim against a dentist and clinic for allegedly failing to recommend timely surgery for temporomandibular joint dysfunction (TMJD), resulting in permanent injury. The patient sued in December 1995, nearly three years after her last office visit but just under two years after the dentist authorized a prescription refill. The district court granted summary judgment to the defendants, finding the claim time-barred under Minnesota's two-year statute of limitations for medical malpractice, which generally runs from the end of treatment for the condition. The court of appeals reversed, but the Minnesota Supreme Court held that the refill authorization did not extend the course of treatment or toll the limitations period on these facts, as it was not part of an ongoing physician-patient relationship involving active care. The core reasoning focused on the single-act exception to the continuing-treatment rule and the absence of any direct interaction or scheduled follow-up after the last visit.

proceduretorts & liabilityhealthcare

The case involved Jason Gilhousen, who was injured by an unidentified driver and received medical and disability benefits from his employer's ERISA-governed plan; after winning a damages award against his uninsured motorist insurer, the insurer sought to reduce the award under Minnesota's collateral source statute, which allows offsets for benefits received except where subrogation rights have been asserted. The district court applied the statute after finding the plan administrator abused discretion in interpreting the plan's subrogation clause to cover first-party insurance, but the court of appeals held ERISA preempted the statute. The Minnesota Supreme Court reversed, holding that ERISA does not preempt the collateral source statute because the law does not "relate to" ERISA plans under 29 U.S.C. § 1144(a), as it affects the calculation of damages in tort litigation rather than regulating the structure or administration of benefit plans themselves. The court reasoned that the statute imposes no additional burdens on plans beyond those they voluntarily assume through subrogation provisions and leaves employers free to enforce subrogation interests against third parties or insurers. The matter was remanded for further proceedings on the plan interpretation issue.

federal powerhealthcarelabor & employmenttorts & liability

In McKenzie v. State, the appellant, convicted of first-degree murder of a police officer and serving a life sentence, sought postconviction relief claiming that Hennepin County judges improperly met in advance to decide on using an anonymous jury in his trial without his input, violating due process, confrontation rights, and judicial conduct canons. The postconviction court denied the petition and hearing request, finding the record showed no entitlement to relief. On appeal, the Minnesota Supreme Court affirmed, holding there was no abuse of discretion because the files conclusively demonstrated the trial judge had not prejudged the issue, conducted a hearing before ruling, and the anonymous jury decision had already been upheld on direct appeal; the confrontation clause was not implicated as no witness testimony occurred at the judges' meeting.

criminal lawprocedurecivil rights

In State v. Varnado, police stopped Beverly Ann Varnado for driving with a cracked windshield in a high-crime area known for drug activity, asked her to sit in the squad car after she lacked identification, and frisked her before she entered, discovering crack cocaine in her pocket. The district court suppressed the evidence and dismissed the complaint, finding no valid basis for the frisk, but the court of appeals reversed. The Minnesota Supreme Court reversed the appeals court and reinstated the suppression, holding that the frisk violated the Fourth Amendment because no exception applied: there was no individualized suspicion that Varnado was armed to justify a protective frisk for weapons, and it was not a valid search incident to arrest since the officer lacked probable cause at the time. The court reasoned that while officers could reasonably request Varnado sit in the squad car for safety during the license check given the circumstances, this did not automatically permit the frisk without additional justification tied to weapons or arrest. The ruling focused on the specific facts showing Varnado was cooperative with no suspicious behavior indicating danger.

criminal lawprocedure

In Gleason v. Metropolitan Council Transit Operations, a physically disabled plaintiff confined to a motorized wheelchair sued the transit authority, bus driver, and supervisor for disability discrimination under the Minnesota Human Rights Act as well as tort claims including false imprisonment and intentional infliction of emotional distress, based on an incident where the driver refused to secure her wheelchair, summoned a supervisor instead, and delayed her travel. The district court denied the defendants' motion for summary judgment on immunity grounds, and the court of appeals held that official immunity did not bar the tort claims while statutory immunity was not a defense to the discrimination claims. The Minnesota Supreme Court affirmed in part, holding that the discrimination, false imprisonment, and emotional distress claims were not barred by official immunity and remanding for trial. The core reasoning was that the employees' operational conduct did not involve discretionary policy decisions protected by official immunity, and statutory immunity under Minn. Stat. § 466.03 does not apply to MHRA claims.

civil rightstorts & liabilityprocedure

The case involved Daniel Martinson, who was charged with multiple drug possession and trafficking offenses after narcotics officers at the Minneapolis-St. Paul Airport detained him for a drug-sniffing dog examination based on observations of his travel from a source city, nervous behavior, cash one-way tickets on different airlines, lack of photo ID, and refusal to consent to a luggage search. Martinson moved to suppress the resulting evidence, claiming the detention violated the Fourth Amendment, but the trial court denied the motion; he was convicted on stipulated facts and sentenced to 54 months. The court of appeals reversed the conviction, but the Minnesota Supreme Court reinstated it, concluding that the officers had reasonable suspicion under the totality of the circumstances to justify the brief Terry stop even though the individual facts were consistent with innocent conduct. The court emphasized that the officers' training and experience, combined with the specific articulated facts, supported the detention until the dog arrived.

criminal lawprocedure