Rosalie E. Wahl

The case involved an inmate's 42 U.S.C. § 1983 claim against Minnesota prison officials, including Corrections Commissioner Orville Pung, Warden Robert Erickson, and Medical Director Dr. James Allan, alleging that a delayed tuberculosis diagnosis violated his Eighth Amendment rights to adequate medical care. The Minnesota Supreme Court addressed whether the defendants were collaterally estopped by findings in a related federal class action and whether qualified immunity barred the claims. The court held that the officials were not collaterally estopped and that qualified immunity protected Allan because the record lacked evidence he was aware of and disregarded an excessive risk to the inmate, as opposed to mere ignorance or negligence. It affirmed summary judgment for Pung and Erickson, reversed the denial of summary judgment for Allan on the constitutional claim, and remanded the separate medical malpractice claim for trial.

civil rightscriminal lawhealthcareprocedure

The case concerned whether a single father's inability to obtain child care for a temporary shift change at his job as a maintenance mechanic constituted misconduct that would disqualify him from unemployment compensation benefits after he was terminated for missing shifts. The Minnesota Supreme Court held that it did not, affirming the court of appeals reversal of the agency denial. The court reasoned that the employee had made reasonable efforts to secure care over several days, faced criminal and support obligations if he left his child unsupervised, and could not be deemed to have engaged in willful misconduct under the unemployment statute, which must be narrowly construed; prior cases treating child care unavailability as rendering a worker unavailable for work were overruled as outdated.

labor & employment

This case involved a wrongful death lawsuit after seven-year-old Brandon Johnson drowned during a school district extended-day program field trip to an artificially created swimming pond at Lake Elmo Park Reserve. A jury found both the South Washington County School District and Washington County negligent, apportioning 40% liability to the district and 60% to the county and awarding over $1 million in damages. The court of appeals reversed the verdict against the county, and the Minnesota Supreme Court affirmed, holding the county immune from liability because the park qualified as part of an outdoor recreation system under the Minnesota Tort Claims Act. The court also affirmed the trial court's denial of the district's motions for a new trial based on attorney misconduct, evidentiary rulings, and claims of excessive damages.

torts & liability

The case involved Michael Jerome Scales' conviction for two counts of first-degree murder and one count of second-degree intentional murder in the stabbing death of Otha Brown. On appeal, Scales challenged the admission of his statements to police, arguing that he had a due process right under the Minnesota Constitution to have his entire custodial interrogation recorded or that the court should mandate such recording through its supervisory powers. The Minnesota Supreme Court declined to recognize a constitutional due process right to recording but exercised its supervisory powers to require electronic recording of all future custodial interrogations by law enforcement. The court affirmed the conviction, finding that the lack of recording in this case did not require suppression of the statements or reversal of the jury's verdict.

criminal lawprocedure

The case involved a federal tax lien against Lawrence P. O'Shaughnessy for unpaid income taxes, with the IRS serving a levy on trustees of two discretionary trusts established for him by his grandparents. The trusts gave trustees sole discretion to distribute principal or income to the beneficiary or withhold it entirely, with no mandatory payments required. The U.S. District Court certified a question to the Minnesota Supreme Court on whether, under state law, the beneficiary held "property" or "rights to property" in undistributed trust assets that could be subject to the federal lien. The court answered no, reasoning that a discretionary trust creates only a mere expectancy for the beneficiary until trustees choose to distribute, so neither the beneficiary nor creditors standing in his shoes can compel any payment. It distinguished this from vested interests like certain pensions and rejected arguments that the beneficiary's limited power of appointment altered the outcome.

taxespropertyprocedure

This case involved a workers' compensation claim by Laurie Steffen against Target Stores for a lumbar disc herniation allegedly caused by her repetitive work duties as a zoner and ticketer. The compensation judge and Workers’ Compensation Court of Appeals denied benefits, finding the medical evidence insufficient to establish that her work activities caused the disability. The Minnesota Supreme Court reversed and remanded, holding that injuries from the usual exertions of employment, including gradual or Gillette-type injuries, are compensable if the employment is a proximate contributing cause, and that the lower courts had applied an overly strict standard for proving causation based on the medical opinion provided.

labor & employment