Justia Civil Rights Opinion Summaries

Appellants were landowners who elected to require a utility to condemn their property in fee after Respondents sought to acquire easements through their property by eminent domain in order to construct a high-voltage electric transmission line. After making this election, Appellants requested that Respondents provide them with minimum compensation and relocation assistance. Respondents moved the district court for an order clarifying whether such benefits are available to property owners making an election under Minn. Stat. 216E.12. The district court concluded that such benefits were available to Appellants, but the court of appeals reversed. The Supreme Court reversed, holding that Appellants satisfied the statutory criteria for receiving minimum compensation and relocation assistance and were therefore entitled to such benefits. Remanded. View "N. States Power Co. v. Aleckson" on Justia Law

After a jury trial, Appellant was convicted of fleeing a peace officer by means other than a motor vehicle pursuant to Minn. Stat. 609.487(6) after she ran from a police officer who was responding to a stabbing at a bar. Appellant argued in a pretrial motion that she was entitled to a voluntary intoxication jury instruction because section 609.487(6) contains a specific-intent requirement. The district court denied the motion, ruling that the offense is a general-intent crime. The court of appeals affirmed. The Supreme Court affirmed but on different grounds, holding (1) section 609.487(6) contains a specific-intent requirement, and the district court erred in failing to instruct the jury on voluntary intoxication in this case; but (2) the error was harmless beyond a reasonable doubt because the omission of the voluntary intoxication jury instruction did not significantly affect the verdict. View "State v. Wilson" on Justia Law

Employees filed a complaint against two employers (Employers), alleging that Employers violated the Minnesota Human Rights Act (MHRA) based on sexual harassment perpetrated by the sole owner of both entities (Owner). Employees also alleged that Owner was individually liable under MHRA's aiding and abetting provision. The district court dismissed Employees' claims. The court of appeals reversed, holding (1) the district court's determination that the harassment was not actionable was clearly erroneous, (2) Employees were entitled to judgment on their claims as a matter of law, and (3) Owner could not be individually liable for aiding and abetting Employers' MHRA violations. The Supreme Court reversed, holding (1) the court of appeals did not err in concluding that Owner could not be liable on an aiding and abetting theory; but (2) two separate errors of law infected the district court's determination that Employees did not prove their sexual harassment claims, and therefore, the Court was unable to ascertain exactly how the errors impacted the court's decision to dismiss Employees' claims. Remanded to the district court to reevaluate the evidence using the correct legal standard. View "Rasmussen v. Two Harbors Fish Co." on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief requesting a new trial or an evidentiary hearing based on recanted testimony from a witness and newly discovered evidence. The postconviction court denied Appellant's motion on the grounds that it was untimely because it was filed after the two-year statutory limit, and no exception to the limitations applied. The court further concluded that the jury would not have reached a different outcome without the witness's testimony. The Supreme Court affirmed, holding that Appellant's petition was untimely, and Appellant failed to demonstrate he was entitled to relief under the newly discovered evidence exception to the time bar. View "Clifton v. State" on Justia Law

After a trial, Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct and was sentenced to life in prison. On appeal, Appellant challenged his conviction on several grounds but did not raise an ineffective assistance of counsel claim. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, asserting a claim of ineffective assistance of trial counsel. The district court summarily denied Appellant's petition. The Supreme Court affirmed, holding that Appellant's postconviction claim was barred by application of State v. Knaffla, which provides that claims that were not raised on direct appeal or were known or should have been known but were not raised on direct appeal, are procedurally barred. View "Sontoya v. State" on Justia Law

After the City of Moorhead annexed Americana Estates (Americana), a residential subdivision with sixty-five metered electric service accounts, the City filed a condemnation petition to begin municipal electric service to residents of Americana. After a hearing, a three-member commission of the district court awarded the Red River Valley Cooperative Power Association (RRVC), which previously served Americana, $307,214. Both parties appealed the commission's award of damages. After a jury trial, the district court awarded a total compensation award to RRVC of $385,311. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the City's valuation was inconsistent with the plain language of Minn. Stat. 216B.47 by failing to give meaningful consideration to four statutory factors and thus was properly excluded from consideration by the district court; and (2) the district court did not abuse its discretion in excluding portions of an untimely revised report submitted by the City dealing with facility replacement costs. View "City of Moorhead v. Red River Valley Coop. Power Ass'n" on Justia Law

Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct causing personal injury. The Supreme Court affirmed the conviction on appeal. Appellant subsequently filed a petition for postconviction relief, alleging a claim of newly discovered evidence. After an evidentiary hearing, the postconviction court denied the petition, concluding that the newly discovered evidence was not credible and, therefore, was not likely to produce a result more favorable to Appellant. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Appellant's petition for postconviction relief, as the record supported the court's credibility determinations. View "Tscheu v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, second-degree intentional murder, and second-degree unintentional murder while committing a felony. Defendant appealed, seeking a new trial based on the district court's allegedly erroneous admission of expert testimony offered by a medical examiner and a firearms examiner. Defendant argued that the testimony was improperly admitted because it intruded on the fact-finding role of the jury. Defendant did not object to the testimony at trial. The Supreme Court affirmed Defendant's convictions, holding that the district court properly admitted the expert testimony of the medical examiner and the firearms examiner. View "State v. Xiong" on Justia Law

Defendant was charged with several misdemeanor offenses, including driving a motor vehicle with a blood-alcohol concentration of 0.08 percent or more. Defendant filed a request to preserve "blood tests," but subsequently, the State destroyed Defendant's blood sample used in a blood alcohol test in accordance with its retention policy. Defendant pleaded not guilty and successfully moved to suppress the results of his blood-alcohol test. The court of appeals affirmed the district court's suppression order, adopting a per se rule requiring suppression when the State destroys evidence after a defendant has made a demand to preserve the evidence. The Supreme Court reversed, holding that the State did not violate any of the Minnesota Rules of Criminal Procedure when it destroyed Defendant's blood sample, and the district court erred in suppressing the results of the blood test. View "State v. Hawkinson" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, first-degree intentional drive-by shooting murder, attempted first-degree premeditated murder, and attempted first-degree intentional drive-by shooting murder. Defendant filed two petitions for postconviction relief, both of which were denied. Several years after his convictions, Defendant filed a third petition for postconviction relief, arguing that the grand jury selection process in Hennepin County violated his constitutional rights to due process and equal protection. Defendant maintained that his current petition was excepted from the statutory two-year time limit. The postconviction court denied Defendant's petition for postconviction relief, concluding that the petition was time barred and that the newly-discovered-evidence exception did not apply and alternatively, that the petition was barred under the Knaffla doctrine. The Supreme Court affirmed, holding that Defendant's petition failed to satisfy an exception to the two-year limitations period, and therefore, the petition was time barred. View "Francis v. State" on Justia Law