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construed; prior cases treating child care unavailability as rendering a worker unavailable for work were overruled as outdated.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

The case concerned a workers' compensation insurer's subrogation rights after an employee injured on the job settled a third-party tort lawsuit for $1 million. The trial court allocated all settlement proceeds to the employee as nonrecoverable damages for pain and suffering, and the court of appeals affirmed. The Minnesota Supreme Court reversed, ruling that a trial court lacks authority to allocate an entire settlement covering all claims to nonrecoverable damages when the settlement necessarily includes amounts recoverable under the Workers' Compensation Act. The court reasoned that precedents such as Henning v. Wineman permit allocation between recoverable and nonrecoverable damages but do not allow an allocation that is unreasonable or patently arbitrary by excluding the insurer's subrogation interest entirely.

labor & employmenttorts & liability

This case involves two consolidated tort actions by Ronald Kubiszewski seeking damages for injuries from a work-related accident and a subsequent non-work-related accident. The City of Prior Lake, which had paid workers' compensation benefits, intervened claiming indemnity rights under the Workers' Compensation Act against the third-party tortfeasors in both incidents. The Minnesota Supreme Court affirmed the lower courts in the work-related accident case but reversed in the non-work-related accident case, holding that the Act's indemnity provisions do not apply to benefits mistakenly paid for non-compensable, non-work-related injuries. The core reasoning was that only benefits paid pursuant to the Act for work-related injuries trigger the employer's subrogation and indemnity rights against third parties.

labor & employmenttorts & liability

The case arose from a 1988 car accident in which lone Drake was injured by a vehicle driven by James Ryan; the Drakes sued the Ryans for negligence, and Dairyland (primary insurer with $30,000 limits) later entered a partial settlement agreement that paid $20,000, released the Ryans from personal liability beyond that amount, and preserved the Drakes' right to seek any additional damages up to the limits of the State Farm excess policy. After Dairyland withdrew, State Farm assumed the defense, but James Ryan moved for summary judgment on the ground that the agreement fully released him. The district court denied the motion and certified the validity of the release as important and doubtful; the court of appeals upheld the release, and the Minnesota Supreme Court affirmed. The court reasoned that such modified Loy-type releases are enforceable under Minnesota law because they do not prejudice the excess insurer (which had a contractual duty to defend), eliminate the defendant's personal exposure, reduce the number of parties, and align with public policy favoring partial settlements without affecting the underlying negligence issues at trial.

torts & liabilityprocedure

The case concerned whether a prosecutor could certify a misdemeanor speeding charge as a petty misdemeanor without the defendant's consent, thereby eliminating his right to a jury trial. The defendant had been charged with a misdemeanor due to prior violations and objected to the certification under Minnesota Rule of Criminal Procedure 23.04, which requires consent, while the state relied on Minnesota Statutes § 609.131, which does not. The trial court and court of appeals ruled that the statute controlled as a matter of substantive law. The Minnesota Supreme Court reversed, holding that the certification process is procedural and thus governed by the court rule, which prevails over the conflicting statute.

criminal lawprocedure

In Felton v. Anton Chevrolet, a used car reconditioner filed a workers' compensation claim for a low back injury consisting of a lumbar disc herniation that developed after his work activities on August 15, 1991, which involved heavy physical tasks such as repairing brakes and installing parts. The compensation judge awarded wage loss, medical, and other benefits after finding a compensable work injury that aggravated an underlying condition, but the Workers’ Compensation Court of Appeals reversed that determination. The Minnesota Supreme Court reversed the WCCA and remanded, concluding that the compensation judge’s findings were supported by substantial evidence including the employee’s testimony, chiropractic records, subsequent medical treatment, and the treating neurologist’s opinion linking the injury to the August 15 work, and that conflicts in medical expert opinions are resolved by the trier of fact.

labor & employment

In State v. Hawkins, Tommy Hawkins was convicted by a jury of attempted first-degree murder and aggravated robbery after he and an accomplice assaulted undercover BCA agent Michael Wold in an apartment stairwell during a staged drug purchase, beating him and attempting to take his cash and gun. The Minnesota Supreme Court affirmed the attempted murder conviction, rejecting arguments that incriminating statements made to a fellow inmate in a holding cell violated the right to counsel, that exclusion of portions of a defense witness's testimony denied the right to present a defense, and that prosecutorial misconduct occurred. However, the court vacated the separate sentence for aggravated robbery under Minn. Stat. § 609.035, concluding that the offenses were part of a single behavioral incident because the attempted murder was committed to facilitate the robbery and escape apprehension rather than as a distinct act.

criminal lawprocedure

The case involved defendant William E. Lehman, Jr., who was convicted of assault with a dangerous weapon after stabbing an acquaintance. The court of appeals had granted a new trial because the trial court required Lehman to wear a concealed leg brace during trial without making required findings on the need for the restraint under Minn.R.Crim.P. 26.03. The Minnesota Supreme Court reversed that decision and reinstated the conviction, reasoning that the record on appeal demonstrated the restraint was objectively justified by Lehman's history of violent recidivism and escape, his self-representation which allowed greater movement, and the minimal nature of the device, which was unlikely to prejudice the jury or lead it to infer security concerns beyond properly admitted evidence of his prior offenses.

criminal lawprocedure

The case involved Nelson's Office Supply Stores challenging the Commissioner of Revenue's inclusion of payments for real estate taxes, common area expenses, and utilities—required under its retail leases—in the calculation of 'capitalized rent' for Minnesota's corporate alternative minimum tax base under Minn. Stat. § 290.092 (1990), which incorporates the property valuation rules from the apportionment statute. The Tax Court had ruled that these payments were not part of 'rentals' under Minn. Stat. § 290.191, subd. 10(e), but the Minnesota Supreme Court reversed that decision. The court held that 'rentals' means all payments required for the use of property, including the disputed charges, based on the ordinary meaning of the term, related statutory definitions distinguishing gross rent from specific exclusions, legislative history, and the weight given to administrative interpretations. It further concluded that this construction did not violate the Uniformity Clause of the Minnesota Constitution, as the tax formula had been upheld in prior cases.

taxesbusiness & regulatory

This case involved divorced parents with joint legal and physical custody of two children under a 1990 amended decree, where the mother sought court permission to relocate the children permanently to Illinois with her new spouse and to modify the custody arrangement. The trial court denied the relocation request after an evidentiary hearing and found that the children's best interests would be served by maintaining primary residence with the father in Minnesota. The court of appeals reversed, but the Minnesota Supreme Court reinstated the trial court's order, holding that the best-interests standard under Minn. Stat. § 518.18(e) applied rather than the endangerment standard, because the proposed move would effectively modify the joint physical custody provisions. The court concluded that the trial court's detailed findings on the statutory best-interests factors were supported by the record, including the children's ties to Minnesota and the parents' existing custody schedule.

family law

This case concerns a pre-trial appeal by the state in a prosecution for aggravated robbery, challenging the dismissal of charges against defendant Kevin Blacksten on grounds that his detention by police was illegal. The court affirmed the trial court's rulings that the seizure exceeded the permissible scope of an investigative stop, lacked probable cause at the time it occurred, and that the defendant's consent to search his vehicle was not voluntary, leading to suppression of the resulting evidence including a snowmobile cover. It reversed the court of appeals only on the need for further findings regarding consent, instead crediting the trial court's determination based on witness credibility, and reinstated the judgment of dismissal for lack of probable cause to proceed.

criminal lawprocedure

The case involved a dispute between Medica, a Minnesota HMO, and Central States, a health and welfare fund, over a 1990-92 agreement that included a retrospective premium adjustment based on Central States' costs for non-HMO members. Medica argued the adjustment violated Minn. Stat. § 62D.04, subd. 1(f), which requires HMOs to assume full financial risk on a prospective basis for enrollees' services, and sought a declaration that the provision was unenforceable. The federal district court certified the question to the Minnesota Supreme Court. The court held that the statute does not prohibit all risk-sharing arrangements except those meeting the narrow exception in subd. 1(f)(2), because the agreement did not shift Medica's full financial risk for providing services to its enrollees. The opinion focused on statutory interpretation of the HMO Act's risk assumption requirement without addressing the second certified question.

healthcarebusiness & regulatory

The case concerned whether the Hennepin County District Court could order a closed settlement conference between the County and City of Minneapolis in an ongoing lawsuit over the proposed demolition of the National Guard Armory for a new public safety facility, without complying with Minnesota's Open Meeting Law. The Star Tribune petitioned for a writ of prohibition after the trial court excepted the meeting from the statute's requirements, and the court of appeals granted the writ. The Minnesota Supreme Court affirmed, holding that while courts possess inherent judicial power to order closed settlement conferences in litigation involving public bodies, the specific conference here did not qualify because it occurred after trial while the case was on appeal, had an overly broad scope beyond the underlying litigation, and was not narrowly tailored to settlement needs. The court reasoned that the Open Meeting Law therefore applied to the meeting of a quorum of the county board, and the trial court's orders were vacated.

procedure

In State v. Zacher, the defendant was convicted under Minn.Stat. § 609.615 of defeating a security interest in real property after removing fixtures from a foreclosed building during the statutory redemption period. The court of appeals reversed the conviction on the ground that the mortgage had been extinguished by the foreclosure sale, but the Minnesota Supreme Court reversed that decision and reinstated the conviction. The court held that the property remained subject to the mortgage for purposes of the criminal statute until the redemption period expired, based on the statute's text, its legislative history from prior versions, and the principle that foreclosure is not complete until redemption rights end.

criminal lawproperty

The case involved James Russell's appeal from convictions for first degree felony murder and second degree intentional murder in connection with the death of Cornell Booker, a drug dealer robbed by Russell and accomplices to cover back rent. The Minnesota Supreme Court affirmed both convictions after a jury trial. The court held that the evidence was sufficient to show the homicide and predicate aggravated robbery formed a single continuous transaction, that Russell intended Booker's death as a foreseeable consequence and did not effectively withdraw from the crime, and that his confession was admissible because proper Miranda warnings had been given before any incriminating statements.

criminal lawprocedure