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

This case was a declaratory judgment action brought by State Farm to determine its obligations under a mobile homeowner’s insurance policy issued to Gary Seefeld. The underlying incident involved injuries to Kimberly Smith while riding in a utility trailer negligently designed and constructed by Seefeld and towed by an ATV driven by his daughter; the trailer hitch failed during a joyride on a public road. The trial court found coverage because the trailer’s negligent design was an independent, non-vehicle-related cause, but the court of appeals reversed. The Minnesota Supreme Court affirmed the reversal, holding that the policy’s exclusion for bodily injury arising out of the ownership, maintenance, or use of a motor vehicle applied and barred coverage. The court reasoned that, unlike prior precedent involving concurrent independent causes, the design defect could only have caused injury through the use of a motor vehicle and therefore was not an independent non-vehicle-related cause.

torts & liability

This case concerned Minnesota banks' challenge to the state's pre-1983 bank excise tax, which included interest from federal obligations in the net income calculation while exempting interest from certain state obligations, allegedly violating 31 U.S.C. § 3124(a). After the U.S. Supreme Court remanded following its decision in James B. Beam Distilling Co. v. Georgia, the Minnesota Supreme Court addressed whether the rule from Memphis Bank & Trust Co. v. Garner must apply retroactively and what remedies or procedural bars remain available. The court concluded that Beam requires retroactive application of the Garner rule but does not prevent states from raising procedural defenses or selecting appropriate remedies for the violation. It held that severing the discriminatory provisions cured the tax and that equitable factors, including the banks' prior acceptance of benefits and failure to challenge the tax earlier, justified denying refunds.

taxesfederal power

This case involved a dispute over no-fault automobile insurance benefits after Michael Meister suffered severe injuries in an accident while riding in his employer's pickup truck. MSI, the employer's insurer, tendered $20,000 in basic economic loss benefits, but Meister sought additional benefits from Western National under his father's personal policy, which had elected stacked coverage increasing limits to $40,000 each for medical and non-medical expenses. The trial court ruled for Western National based on the priority statute in Minn. Stat. § 65B.47, subd. 1, and the anti-stacking amendment, but the court of appeals reversed. The Minnesota Supreme Court affirmed, holding that the priority statute governs only basic coverage and does not bar recovery of the optional additional stacked benefits purchased under the personal policy. The core reasoning centered on interpreting the No-Fault Act to allow access to the elected higher limits despite the business vehicle priority rule directing initial payment to the employer's insurer.

business & regulatorytorts & liability

The case involved the Minnesota Commissioner of Revenue assessing a controlled substance tax and penalty against both a husband and wife after police found cocaine in their shared bedroom during a search targeting the husband. The husband admitted sole possession and had judgment entered against him, while the wife, who was never charged with a crime, invoked her privilege against self-incrimination in response to discovery requests. The tax court granted summary judgment to the wife, finding no evidence that she possessed the drugs, and the Minnesota Supreme Court affirmed. The court reasoned that the husband's statements and lack of contrary proof meant the commissioner could not establish the wife's liability, and her invocation of the privilege did not create an adverse inference sufficient for judgment against her.

taxescriminal lawprocedure

The case involved Tony L. Borchardt's conviction for first-degree murder after he shot and killed Alan Meece, a superior in the Army Reserves who had allegedly coerced Borchardt into sexual acts through threats of military consequences. Borchardt appealed on the grounds that the trial court denied his constitutional right to present a defense by excluding expert testimony on "male sexual victimization" syndrome, which he argued would demonstrate sufficient provocation to reduce the offense to manslaughter. The Minnesota Supreme Court affirmed the conviction, concluding that the proffered expert testimony was properly excluded because the underlying theory lacked adequate scientific acceptance and its minimal probative value was substantially outweighed by the danger of misleading the jury. The court further reasoned that extensive evidence of premeditation, including Borchardt's planning and post-shooting statements about wanting to act as a hit man, made it unlikely that the testimony would have affected the verdict.

criminal lawprocedure

This case involved a buyer, Edward Corazalla, who sued the sellers, Albert and Gretchen Quie, and their real estate agents for fraud and negligent disclosure after purchasing rural property advertised as having a private 7-acre lake. The buyer claimed he discovered post-closing that the lake was shared with a neighboring property. The trial court granted summary judgment to the sellers, which the court of appeals reversed, but the Minnesota Supreme Court reversed the appeals court and reinstated the summary judgment. The court reasoned that public records, maps, and legal descriptions clearly showed the lake's boundaries and the neighbor's access rights, which the buyer could have verified during his inspections or review of documents, so no genuine issues of material fact existed.

propertytorts & liability

The case concerned whether Minnesota Statute § 550.37, subdivision 22, which exempts rights of action for personal injuries from attachment, garnishment, or sale, violates article I, section 12 of the Minnesota Constitution requiring a reasonable amount of exempt property. The Minnesota Supreme Court answered in the negative, upholding the statute's constitutionality as applied to general and future special damages from bodily injury. The court reasoned that the exemption serves the purpose of protecting debtors' human capital and providing a fresh start after injury, distinguishing it from unlimited financial exemptions struck down in prior cases, and presuming statutes constitutional unless proven otherwise beyond a reasonable doubt.

propertytorts & liability

The case concerned Audie Fox's petition for post-conviction relief from his 1982 first-degree murder conviction, in which he claimed that the antipsychotic drug Thorazine, administered before and during trial to treat anxiety and hallucinations, impaired his ability to participate in his defense; he also raised related claims of ineffective assistance of counsel and denial of the right to testify. The Minnesota Supreme Court affirmed the district court's denial of relief. The court reasoned that Fox failed to present expert testimony showing the medication's effects prevented meaningful participation, that the four-year delay in seeking relief after the medication ended weighed against the claim, and that counsel's performance was not shown to be deficient under the Strickland standard or to have caused prejudice.

criminal lawprocedure

The case involved Joy Marie Friedman, whose driver's license was revoked for one year after police deemed her refusal to take an implied consent breath test following a DWI arrest. The Minnesota Supreme Court reversed the lower courts' decisions sustaining the revocation. The court held that the right to counsel under the Minnesota Constitution attaches before a driver must decide whether to submit to chemical testing in a DWI proceeding. It reasoned that the state constitution provides greater protection than the federal Constitution in this context, requiring an opportunity to consult an attorney prior to the test.

criminal lawprocedurecivil rights

The case involved a declaratory judgment action by an insurer to determine coverage under a homeowners' policy for personal liability after a father, subject to a separation order, killed his two children during a visit at the marital home where they resided with their mother. The trial court and court of appeals granted summary judgment to the insurer based on the policy's household exclusion for bodily injury to any insured, but the Minnesota Supreme Court reversed and remanded for trial. The court held that the severability clause required the exclusion to be applied separately to each insured, that the children were not residents of the father's household, and that the policy language was ambiguous and thus construed against the insurer.

family lawtorts & liability

This case involved apportioning a federal social security disability insurance (SSDI) offset against workers’ compensation benefits between two employers and their insurers for an employee who suffered separate work-related back injuries in 1972 and 1977, resulting in permanent total disability. The Minnesota Supreme Court affirmed the Workers’ Compensation Court of Appeals’ ruling that SSDI benefits should first be deducted from the total workers’ compensation obligation (including adjustments), with the remaining balance then apportioned according to the established Kaisershot formula based on each employer’s percentage of responsibility for the disability, subject to annual recalculation. The court reasoned that this approach aligns with longstanding WCCA precedent applying the Kaisershot formula, accounts for differing statutory rules on benefit rates and adjustments for pre- and post-1975 injuries, and produces an equitable distribution without requiring judicial creation of a new allocation method.

labor & employmentfederal power

This case was about determining the priority of uninsured motorist coverage among three insurance policies (from Athena, Northland, and Omaha) after an accident in which the insured struck an uninsured motorist. The Minnesota Supreme Court reversed the court of appeals in part and reinstated a modified version of the trial court's decision, establishing Athena as primary, Northland as secondary, and Omaha as tertiary while denying the insureds' claim for attorney fees. The core reasoning involved de novo interpretation of the policies' 'other insurance' clauses to establish the order of coverage and a determination that attorney fees are unavailable in this declaratory judgment action absent a contractual duty to defend or statutory authority.

business & regulatoryproceduretorts & liability

The case involved the conviction of David Kraushaar for second-degree criminal sexual conduct based on allegations made by his young daughter during a custody dispute with her mother. The jury convicted Kraushaar after hearing testimony from social workers, a pediatrician, foster parents, and a videotaped interview with the child, along with expert analysis of the child's drawings. The court of appeals reversed the conviction on grounds of insufficient evidence, improper admission of expert testimony regarding the drawings, and errors in permitting the jury to replay the videotape while denying access to transcripts. The Minnesota Supreme Court reversed the court of appeals and reinstated the conviction, concluding that the evidence was legally sufficient when viewed in the light most favorable to the verdict, the expert testimony met admissibility standards, and any procedural issues did not constitute prejudicial error.

criminal lawprocedurefamily law

This case involved a defamation lawsuit brought by David Britton, a county probation officer, against Mary Koep, a county commissioner, after she reported at a joint corrections board meeting that an informant alleged a probation officer had coerced female probationers for sexual favors. The trial court granted summary judgment to the defendants on all claims, including defamation, but the court of appeals reversed on the defamation claim, finding Britton was not a public official. The Minnesota Supreme Court reversed the court of appeals and reinstated the summary judgment, ruling that Britton qualified as a public official under the New York Times v. Sullivan standard, requiring proof of actual malice, which was not shown because Koep's statements were made in good faith based on informant reports during an official meeting discussing county business.

torts & liabilityfree speechcivil rights