Justia Civil Rights Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing in part and affirming in part the district court's grant of summary judgment for Defendant, a school district, in this employment dispute, holding that summary judgment was properly granted on all of Plaintiff's claims.Plaintiff brought this action alleging that the suffered a hostile work environment and disparate treatment culminating in constructive discharge during her employment with Defendant. The district court granted Defendant's motion for summary judgment on both claims. The court of appeals reversed in part, concluding that Plaintiff had "presented sufficient evidence of disparate-treatment age discrimination to withstand summary judgment[.]" The Supreme Court reversed in part, holding that Plaintiff established a genuine issue of material fact as to whether she suffered an adverse employment action in the form of constructive discharge. View "Henry v. Independent School District #625" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Defendant's second petition for postconviction relief, holding that the district court did not abuse its discretion in denying the petition without holding an evidentiary hearing.After a jury trial, Defendant was found guilty of first-degree felony murder and attempted first-degree premeditated murder, among other crimes. Defendant later filed the postconviction petition at issue, asserting that he was denied his Sixth Amendment right to a trial before an impartial jury and that his trial counsel and appellate counsel provided ineffective assistance. The district court summarily denied the petition as time barred and procedurally barred. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Defendant's second postconviction petition as untimely. View "White v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder, attempted first-degree murder, and kidnapping, holding that there was no error in the proceedings below.On appeal, Defendant argued, among other things, that the district court erroneously joined his and his codefendant's cases for trial and by denying subsequent severance motions. The Supreme Court affirmed his convictions, holding (1) the district court did not improperly join Defendant's and his codefendant's cases for trial and did not erroneously refuse to sever the cases once the trial was underway; (2) the prosecutor did not commit misconduct during closing arguments; and (3) Defendant was not entitled to relief as to the claims he raised in a pro se supplemental brief. View "State v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the district court's decision to grant summary judgment in favor of Cornelius Emily and Earnest Rhoney, Department of Corrections officers, and dismiss Plaintiff's claims of cruel and unusual punishment, holding that Plaintiff's 42 U.S.C. 1983 claim survived summary judgment.Plaintiff, who was incarcerated in the Stillwater correctional facility, suffered serious injury in both of his wrists when Officers Emily and Rhoney improperly applied overtightened handcuffs on Plaintiff for three and one-half hours. Plaintiff brought this action seeking damages. The district court granted summary judgment, concluding that the officers did not act maliciously or sadistically. The court of appeals reversed. The Supreme Court affirmed, holding (1) the conduct of the officers should be assessed under the deliberate indifference standard applicable to conditions of confinement and medical care; and (2) qualified immunity did not bar Plaintiff's deliberate indifference claim. View "Welters v. Minn. Dep't of Corrections" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to dismiss the charge of fifth-degree marijuana possession against him for lack of probable cause, holding that the evidence was sufficient to survive a motion to dismiss for lack of probable cause.This case arose when law enforcement officers discovered a plant substance in Defendant's car during a traffic stop. While the State did not test the concentration of THC in the substance before charging gate case, a field test of the substance detected the presence of THC. The district court granted Defendant's motion to dismiss for lack of probable cause. The court of appeals reversed, concluding that chemical testing establishing the THC concentration of substance was not required when there is other sufficient evidence to support a probable cause finding. The Supreme Court affirmed, holding that Defendant's admission that the material in the vehicle was marijuana was sufficient to survive a motion to dismiss the charge of fifth-degree marijuana possession. View "State v. Dixon" on Justia Law

The Supreme Court held that, for double jeopardy purposes, the unit of prosecution for a violation of Minn. Stat. 243.166, subd. 3(a), which requires a predatory offender to register "with the corrections agent as soon as the agent is assigned to the person," is the assignment of a corrections agent, thus affirming in part and reversing in part the decision of the court of appeals.Defendant was convicted and sentenced on seven separate occasions between 2004 and 2018 for failing to register under subdivision 3(a). In August 2019, Defendant refused to sign required paperwork presented by his new corrections agent. In September 2019, Defendant again refused to sign the paperwork presented by a special agent of the Minnesota Bureau of Criminal Apprehension assigned by Defendant's corrections agent. The State charged Defendant with two counts of failing to register under subdivision 3(a). Defendant moved to dismiss the charges on double jeopardy grounds. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Defendant's earlier convictions did not bar prosecution of the August 2019 offense; but (2) the September 2019 offense was barred. View "State v. Larson" on Justia Law

The Supreme Court affirmed the denial of Appellant's petition for postconviction relief arguing that the district court committed reversible error by denying his pretrial motion to suppress his statements to law enforcement officers, holding that the district court did not abuse its discretion by denying Appellant's request for postconviction relief.Appellant was convicted of second-degree murder and first-degree arson and sentenced to a total of 528 months in prison. Appellant later filed for postconviction relief, asserting that the district court committed reversible error by denying his pretrial motion to suppress statements he made to law enforcement officers. The district court denied relief on the grounds that Appellant was not subjected to custodial interrogation at the time he made his statements. The court of appeals affirmed on different grounds. The Supreme Court affirmed on the grounds cited by the district court, holding that Defendant could not invoke his Fifth Amendment right to counsel because no custodial interrogation took place. View "Charette v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for four counts of possession of pornographic work involving minors, holding that, assuming that Defendant had a reasonable expectation of privacy in his online cloud storage account, the government's search of his account was lawful under the private search doctrine.At issue in this case was the conduct of law enforcement officers who discovered digital child pornography files stores in Defendant's cloud storage account with Dropbox. Defendant moved to suppress the evidence acquired from his Dropbox account, arguing that the search violated his Fourth Amendment rights. The district court denied the motion to suppress. The court of appeals affirmed. The Supreme Court affirmed, holding that the warrantless search of Defendant's online cloud storage account did not violate the Fourth Amendment. View "State v. Pauli" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of threats of violence in violation of Minn. Stat. 609.713, subd. 1, holding that Defendant's constitutional right to a speedy trial was not violated in this case.At issue was whether trial delays caused by judicial orders issued in response to the COVID-19 global pandemic weighed against the State in the evaluation of whether Defendant's constitutional right to a speedy trial had been violated. The Supreme Court answered the question in the negative and affirmed Defendant's conviction, holding (1) trial delays caused by statewide orders issued in response to the COVID-19 global pandemic statewide orders do not weigh against the State; and (2) the State brought Defendant to trial quickly enough so as not to violate his constitutional right to a speedy trial. View "State v. Paige" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the order of the district court granting summary judgment in favor of the County of Anoka in this case concerning the proper interpretation of Minn. Stat. 103D.311, which governs the appointment of watershed district managers, holding that several of the district court's conclusions were erroneous.The City of Circle Pines brought this action alleging that the County followed an improper procedure in reappointing Patricia Preiner, a resident of the City of Columbus, to the Rice Creek Watershed District board of managers. The district court granted summary judgment for the County, ruling that section 103D.311 unambiguously allowed the County the discretion to appoint a manager from any city that neglected to submit a list of nominees. The Supreme Court reversed, holding (1) section 103D.311 is ambiguous; (2) the statute requires the aggregate list of city nominees to have three nominees to be valid; and (3) the requirement under the statute that counties appoint managers from city nominees applies unless those nominees cannot fairly represent the various hydrologic areas in the watershed district. View "City of Circle Pines v. County of Anoka" on Justia Law