Justia Civil Rights Opinion Summaries

Articles Posted in Minnesota Supreme Court
by
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the district court's grant of summary judgment in favor of Defendant after concluding that Plaintiff failed to allege conduct sufficiently severe or pervasive to support a claim for sexual harassment, holding that the conduct alleged by Plaintiff was sufficiently severe or pervasive for a reasonable person to find the work environment to be hostile or abusive. In granting summary judgment to Defendant, the district court determined that the conduct alleged did not meet the severe-or-pervasive standard for actionable sexual harassment based on a hostile work environment. The court of appeals affirmed. The Supreme Court reversed in part, holding (1) Plaintiff has not presented the Court with a compelling reason to abandon the severe-or-pervasive standard for analyzing the objective component of a claim for sexual harassment under the Minnesota Human Rights Act, Minn. Stat. 363A.01-.44; and (2) considering the totality of the circumstances, Plaintiff presented sufficient evidence for a reasonable jury to decide that the complained of behavior was sufficiently severe or pervasive to substantially interfere with Plaintiff's employment or to create an intimidating, hostile, or offensive employment environment. View "Kenneh v. Homeward Bound, Inc." on Justia Law

by
The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of check forgery, holding that a government inspection of a guest registry is a search under the Minnesota Constitution and that the district court committed reversible error by admitting evidence illegally seized from Defendant's hotel room. Based on evidence that law enforcement officers discovered in Defendant's hotel room, Defendant was charged with check forgery. Defendant filed a motion to suppress, arguing that the officers violated Minn. Const. art. I, 10 when they inspected the hotel guest registry, which led them to his room, without having any individualized suspicion of criminalized activity. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) law enforcement officers must have at least a reasonable, articulable suspicion to search a guest registry; (2) the hotel guest registry statutes, Minn. Stat. 327.10-.13 are constitutional because they do not authorize suspicionless searches; and (3) because the evidence admitted in this case was the fruit of the illegal, suspicionless search of the guest registry the district court erred by denying Defendant's motion to suppress. View "State v. Leonard" on Justia Law

by
The Supreme Court affirmed Defendant's convictions for first-degree murder and second-degree murder but reversed the sentence in part, holding that the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder but any other error in the proceedings below was harmless. Specifically, the Supreme Court held (1) any error the district court may have made by declining to hold an evidentiary hearing regarding the admissibility of DNA evidence was harmless, and the district court did not abuse its discretion by denying Defendant's motion to exclude the DNA evidence; (2) Defendant was not prejudiced by alleged prosecutorial misconduct; and (3) the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder in its sentencing order, and therefore, the cause must be remanded to the district court to correct the error. View "State v. Garland" on Justia Law

by
The Supreme Court affirmed Defendant's conviction for first-degree murder, holding that there was no error in the proceedings below. Specifically, the Supreme Court held (1) Appellant's right to a fair trial before an impartial tribunal was not violated when the district court stated that it might reconsider its prior Spreigl ruling if the defense presented certain witnesses; (2) the jury instructions on accomplice liability were plainly erroneous, but Appellant failed to establish that there was a reasonable likelihood that the error had a significant effect on the verdict; (3) the prosecutor did not commit misconduct in his closing arguments regarding the law of accomplice liability; (4) the district court did not abuse its discretion by granting the State’s motion to admit evidence of appellant’s past convictions for impeachment purposes, including by allowing the specific convictions to be disclosed to the jury; and (5) Appellant’s pro se arguments were without merit. View "State v. Reek" on Justia Law

by
The Supreme Court affirmed the decisions of the district court denying Appellant's ineffective assistance of trial counsel claim raised in his first petition for post conviction relief and the claims raised in his second petition for postconviction relief, holding that the district court did not abuse its discretion by denying Appellant's claims. After a jury trial, Appellant was found guilty of first-degree felony murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed. In his first petition for postconviction relief, Appellant raised some of the same issues addressed in his direct appeal but also claimed that he received ineffective assistance of trial counsel. The district court ordered an evidentiary hearing only on the ineffective assistance of counsel claim and, after a hearing, denied the claim. Appellant then filed a second petition for postconviction relief, which the district court summarily denied. The Supreme Court affirmed both of the district court's orders, holding (1) Appellant did not satisfy the first prong of Strickland on his ineffective assistance of counsel claim; and (2) all of Appellant's claims in his second petition were time barred. View "Griffin v. State" on Justia Law

by
The Supreme Court denied Petitioners' petition filed under Minn. Stat. 204B.44(a) asking that the Supreme Court direct the Minnesota Secretary of State to include Roque De La Fuente's name as a candidate for The Republican Party of Minnesota's nomination for United States President on the ballot for the Minnesota presidential nomination primary election on March 3, 2020, holding that Petitioners' claims failed. Petitioners argued that the procedure established by Minn. Stat. 207A.13, which allows a major political party to determine which candidates' names will be on the ballot for a statewide presidential nomination primary, was unconstitutional. The Supreme Court disagreed, holding that section 207A.13 does not violate (1) the prohibition against special privileges because the Legislature had a rational basis for classifying political parties based on a party's participation in a national convention to nominate the party's presidential candidate; (2) the Presidential Eligibility Clause because requiring a political party to identify the candidates for the ballot to be used in a presidential nomination primary is not a condition of eligibility to serve as President of the United States; and (3) Petitioners' rights of free association because any burden imposed on those rights by the ballot preparation procedures is outweighed by the associational rights of political parties and the State's regulatory interests. View "De La Fuente v. Simon" on Justia Law

by
In this challenge to a zoning ordinance prohibiting industrial mineral operations within Winona County the Supreme Court affirmed the decision of the court of appeals affirming the order of the district granting summary judgment to the County on all of Minnesota Sands, LLC's claims, holding that the ordinance was constitutional. Minnesota Sands, a mining company, sought to mine and process silica sand in the County. Minnesota Sands sued the County requesting declaratory, injunctive, and monetary relief. The district court granted summary judgment to the County. The court of appeals affirmed, concluding that the ordinance did not violate the dormant Commerce Clause or work an unconstitutional taking of Minnesota Sands' property interests. The Supreme Court affirmed, holding (1) Minnesota Sands had standing to bring this case; (2) the County's ordinance did not violate the dormant Commerce Clause on its face, in purpose or in effect; and (3) Minnesota Sands' takings claims failed because the property interests it claimed were taken by the County had not yet accrued. View "Minnesota Sands, LLC v. County of Winona, Minnesota" on Justia Law

by
The Supreme Court affirmed the judgment of the district court summarily denying Appellant's petition for postconviction relief, holding that the alleged facts, even when viewed in a light most favorable to Appellant, conclusively showed that he was entitled to no relief. Appellant was convicted of murder and attempted murder. Appellant later filed his postconviction petition alleging that several reversible errors were committed by the judge, prosecutor, and his counsel during his jury trial. The district court denied the petition without holding an evidentiary hearing and without addressing the ineffective assistance of appellate counsel claim. The Supreme Court affirmed, holding (1) Appellant's claims were procedurally barred by State v. Knaffla, 243 N.W.2d 737 (Minn. 1976); and (2) the failure to address the ineffective assistance of appellate counsel claim did not require a remand because the facts alleged conclusively showed that Appellant was not entitled to relief on his claim. View "Zumberge v. State" on Justia Law

by
The Supreme Court affirmed the decision of the tax court reducing Hennepin County's valuation of a Lowe's store in Plymouth, Minnesota for the 2015 tax year, holding that the tax court did not inflate the property's fair market value and did not violate Lowe's due process rights. Lowe's petitioned the tax court asserting that Hennepin County's assessment for the 2015 tax year overstated the fair market value of the property. The tax court agreed and reduced the County's valuation. The Supreme Court affirmed, holding (1) the tax court did not violate Lowe's due process rights by failing to rely on evidence in the record in reaching its conclusions; and (2) because the record supported the tax court's decision to place greater weight on the cost approach rather than on the sales approach and its adjustments under both approaches, the tax court did not violate Lowe's due process rights. View "Lowe's Home Centers, LLC (Plymouth) v. County of Hennepin" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for first-degree driving while impaired, holding that Officer Patrick Bendel of the Red Lake Police Department was acting within his proper authority when he detained Defendant and transported him to Beltrami County law enforcement. On appeal, Defendant challenged the denial of his motion to suppress, arguing that all evidence obtained as a result of his arrest should be suppressed because Officer Bendel was not a "peace officer" as defined in Minn. Stat. 169A.03, subd. 18 and therefore could not legally arrest Defendant for driving while impaired. The Supreme Court affirmed, holding (1) Officer Bendel detained and investigated Defendant and ejected him from the Red Lake Reservation pursuant to the tribal authority to detain and remove recognized by federal courts; and (2) therefore, Defendant's detention was lawful. View "State v. Thompson" on Justia Law