Justia Civil Rights Opinion Summaries

Respondent Robert Half International (RHI) terminated Appellant Kim Hansen's employment shortly after she returned from maternity leave and failed to reinstate her to the same or similar position. Hansen filed an action against RHI, alleging that it violated the Minnesota Parenting Leave Act (MPLA) and the Minnesota Human Rights Act (MHRA) by failing to reinstate her to her position or a comparable position after maternity leave, for retaliating against her for taking maternity leave, and for terminating her because of her sex. The district court granted summary judgment in favor of RHI. The court of appeals affirmed. The Supreme Court affirmed, holding that there were no genuine issues of material fact and that judgment was appropriate as a matter of law.

Appellant Denon Rhoads was initially charged with a single count of second-degree burglary. At a pretrial hearing, Rhoads asserted his right to self-representation and signed a written waiver of counsel. The State later amended the complaint to include a count of first-degree burglary that roughly doubled the maximum possible punishment. On the day of trial, Rhoads renewed his waiver-of-counsel. The district court, however, did not conduct an on-the-record inquiry of Rhoads's understanding of the maximum punishment that might be imposed if he were convicted of first-degree burglary. Rhoads was later convicted of first- and second-degree burglary. The Supreme Court reversed Rhoads's first-degree burglary conviction and remanded, holding that because the record did not support an inference that when Rhoads renewed his waiver-of-counsel he understood the maximum possible punishment he faced had doubled, the renewed waiver-of-counsel was not knowing and intelligent. Remanded.

Nicole Beecroft was found guilty of first-degree premeditated murder for the stabbing death of her newborn baby. The key factual issue at trial was whether Beecroft's baby was alive or dead when stabbed by Beecroft. Each party presented testimony on this issue from medical examiners and other forensic pathologists, but certain state officials interfered with Beecroft's forensic experts. Beecroft subsequently filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court reversed Beecroft's conviction, holding (1) the interference by the state officials undermined the integrity of the judicial system in this case; (2) the trial errors alleged by Beecroft did not in and of themselves warrant a reversal and the grant of a new trial; but (3) when the existence of alleged errors is combined with the improper conduct of state officials, a reversal is warranted in the interests of justice. Remanded for a new trial.

At issue in this appeal was how to calculate an offender's criminal history score when the court permissively imposes a felony sentence consecutive to a gross misdemeanor sentence. Respondent Tito Campbell was convicted of six offenses, including gross misdemeanor criminal vehicular operation resulting in bodily harm and felony fleeing a police officer resulting in death. The district court imposed a twelve-month sentence for the gross misdemeanor and a consecutive 234-month sentence for the felony fleeing offense, using a criminal history score of three. The court of appeals reversed Campbell's sentence, concluding that zero criminal history points should have been used to calculate the duration of the felony sentence. The Supreme Court reversed the court of appeals and reinstated the district court's sentence, holding that the district court's calculation of Campbell's sentence was correct.

Appellant Carol LaMont filed suit against her employer, a school district, for violations of the Minnesota Human Rights Act (MHRA). Appellant claimed that she had been subjected to a hostile work environment based on her sex and that she had suffered sexual harassment. The district court granted summary judgment to the school district on both claims, concluding that a hostile work environment based on sex was not actionable, and even if it were, Appellant had not established that the conduct of the school district's employees was sufficiently severe or pervasive. The court of appeals affirmed. The Supreme Court affirmed but under different grounds, holding (1) a cause of action for a hostile work environment based on sex is actionable under the MHRA; but (2) Appellant's allegations were insufficient to state a claim of hostile work environment.

After a jury trial, Chaun Carridine was convicted of first-degree premeditated murder and sentenced to life in prison. The Supreme Court affirmed, holding (1) the district court did not err by rejecting Carridine's challenges to the State's exercise of two peremptory strikes; (2) any error by the district court in allowing the State to impeach Carridine through his prior statement did not substantially influence the jury's verdict, and therefore, the error, if any, was not prejudicial; (3) the district court did abuse its discretion in instructing the jury; (4) in the instances where there was or may have been prosecutorial misconduct, the misconduct was either harmless or did not affect Carridine's substantial rights, and therefore, the objected-to prosecutorial misconduct was harmless.

At issue in this case was how to calculate an offender's criminal history score when the court permissively imposes a felony sentence consecutive to a gross misdemeanor sentence. Respondent Tito Campbell was convicted of six offenses, including gross misdemeanor criminal vehicular operation resulting in bodily harm and felony fleeing a police officer resulting in death. The district court imposed a twelve-month sentence for the gross misdemeanor and a consecutive 234-month sentence for the felony fleeing offense, using a criminal history score of three. The court of appeals reversed Campbell's sentence, concluding that zero criminal history points should have been used to calculate the duration of the felony sentence. The Supreme Court reversed and reinstated the district court's sentence, holding that the district court did not err in assigning its criminal history points to Campbell during sentencing.

The State charged Michael Sahr with first-degree criminal sexual contact. Defense counsel moved to dismiss the complaint, arguing that the facts, as alleged in the complaint, were insufficient to support the charged offense. The trial court dismissed the complaint. The State subsequently moved to file a new complaint charging Sahr with second-degree criminal conduct. The trial court denied the State's motion on the basis that filing a new complaint charging second-degree criminal sexual conduct would violate double jeopardy. The court of appeals remanded to the trial court for further proceedings. On remand, the trial court concluded (1) the offense set out in the proposed amended complaint was the "same offense" the court had dismissed in the original complaint and that jeopardy had attached before the complaint was dismissed; and (2) therefore, the signing of the proposed amended complaint would violate double jeopardy. The court of appeals reversed. The Supreme Court reversed the court of appeals, holding (1) the trial court's dismissal of the original complaint constituted an acquittal on the merits; and (2) Sahr's double jeopardy protections precluded the State from filing a new complaint charging Sahr with second-degree criminal sexual conduct and trying him on that offense.

Appellant Adrian Patterson and his codefendant Leroy Paul were indicted for first-degree murder and attempted first-degree murder. Patterson was scheduled to be tried in a joint trial with Paul. For his defense, Patterson retained Eric Newmark as his counsel of choice. The State moved to disqualify Newmark as Patterson's counsel based on alleged actual and potential conflicts of interest arising out of Newmark's past representation of Paul and three of the State's prospective witnesses. Even though Patterson waived his right to conflict-free counsel with respect to Newmark, the trial court granted the motion on the basis of potential conflicts with two of the State's prospective witnesses. After retaining another attorney and, following a jury trial, Patterson was found guilty and convicted of second-degree murder while committing a drive-by shooting and drive-by shooting. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in disqualifying Newmark as Patterson's counsel.

Appellant Robert Hughes was convicted of first-degree premeditated murder for the shooting death of his wife. The trial court sentenced Hughes to life imprisonment and ordered him to pay restitution to the Crime Victims Reparations board. The Supreme Court affirmed. Hughes subsequently filed a petition for postconviction relief raising eighteen claims. The two most significant claims were (1) the restitution order was improper, and (2) the Confrontation Clause was violated by the introduction at trial of statements made by Hughes's wife. The postconviction court denied Hughes's petition without a hearing. The Supreme Court affirmed, holding (1) because Hughes's wife's statements to her divorce attorney and police were nontestimonial, the trial court did not violate Hughes's Confrontation Clause rights when it admitted the statements at trial; and (2) all of Hughes's other claims were procedurally barred because they were or could have been raised on direct appeal.