Lawrence R. Yetka

This case involves a subrogation action by an employer and its workers' compensation insurer against a third-party manufacturer for negligence that caused an employee's injury during loading operations. The trial court had ruled that the employer could recover the full amount of benefits paid and barred submission of the employer's comparative fault to the jury. The Minnesota Supreme Court affirmed the court of appeals' reversal of those rulings but remanded for a new trial on damages. The court reasoned that the employer stands in the shoes of the employee in a common-law negligence action, so recovery depends on proving reasonable wage losses and medical expenses caused by the injury rather than the amount of workers' compensation benefits paid, and the third party may challenge those elements with relevant evidence.

labor & employmenttorts & liability

In State v. Clausen, the defendant was convicted in district court of third-degree possession of 10 or more grams of cocaine under Minn. Stat. § 152.023, subd. 2(2) (1990) and third-degree possession with intent to sell under subd. 2(3). The trial court dismissed the first conviction, holding the statute unconstitutional on due process grounds because it allegedly created an irrebuttable presumption of intent to sell based on weight alone, relying on dicta from State v. Russell. On a certified question, the Minnesota Supreme Court held that the statute contains no such presumption, as it defines a standalone possession offense with penalties graduated by quantity rather than inferring an element of intent to sell, and therefore does not violate state or federal due process. The court distinguished the case from Russell, reinstated the conviction on Count I, and remanded for sentencing.

criminal law

The case involved a candidate for Associate Justice of the Minnesota Supreme Court who petitioned the court to declare unconstitutional certain statutes governing the form of judicial election ballots, including designations identifying the incumbent and the specific seat. The court denied the petition. Although the court found the challenge untimely given the long-standing nature of the statutes and prior similar rulings, it addressed the merits and upheld the ballot format. The core reasoning was that the provisions, in place for over 40 years, are designed to maintain an independent judiciary distinct from other elections and do not violate equal protection guarantees under the U.S. or Minnesota Constitutions.

electionscivil rights

This case concerned a delinquency petition filed against D.A.G. after police recovered an illegal sawed-off shotgun during a warrantless search of a shared residence, leading to charges under Minnesota statutes for possession of a short-barreled shotgun. The trial court suppressed the evidence as the product of an unreasonable search, and both the court of appeals and the Minnesota Supreme Court affirmed that ruling. The court held that consent from one cotenant (Howard) did not authorize the search because D.A.G. was present and not asked for permission, no exigent circumstances existed, and the officers had time to obtain a warrant based on the information provided. The decision emphasized that warrantless searches of a dwelling are per se unreasonable under the Fourth Amendment and the Minnesota Constitution absent a recognized exception.

criminal lawgunsprocedure

The case involved John K.D. Scruggs's appeal from a Hennepin County District Court order denying postconviction relief after his conviction for first-degree murder in the 1985 killing of Christine Kreitz, a gang member, which he was found to have ordered as leader of local Disciples factions. The Minnesota Supreme Court affirmed the district court's denial of relief. The court held that the postconviction petition's claims, including the lack of formal findings by the district court and ineffective assistance of trial counsel for not introducing certain evidence, calling witnesses, or timely appealing a pretrial motion, were either waived, previously decided on direct appeal, or failed to show prejudice or deficient performance under applicable standards. The opinion noted that the underlying evidence of Scruggs's role in ordering the murder was overwhelming and had already been reviewed and upheld.

criminal lawprocedure

The case concerned the constitutionality of Minneapolis Code of Ordinances § 244.690, which requires every occupant of a dwelling to keep the occupied portion in a clean and sanitary condition. Theora Reha was convicted after a jury trial for failing to comply with a specific city inspection order to remove clutter, eliminate vermin harborage, and address related sanitary issues in her home, following repeated inspections that documented blocked egress, pest infestation, and unsanitary conditions. The trial court imposed a stayed sentence of 35 days or a $700 fine. The Minnesota Supreme Court reversed the court of appeals' ruling that the ordinance was unconstitutionally vague as applied, reinstating the conviction on the grounds that the detailed cleaning order, read together with related code provisions on egress and pest control, provided sufficient notice of the prohibited conduct. The court held that the ordinance was not impermissibly vague in this context because the enforcement action was based on specific, observable violations rather than arbitrary discretion.

criminal lawproperty