Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree sexual conduct and domestic assault by strangulation, holding that Minn. R. Crim. P. 9.01 subs. 1-1a does not authorize an inspection of a crime scene in the control of a third party and that, even if Defendant had a constitutional right to inspect the crime scene, any error in denying that right was harmless.Before trial, Defendant filed a motion to allow his counsel and investigator to enter his former residence to inspect and photograph the crime scene. The district court denied the motion. The court of appeals held that Defendant had a right under Rule 9.01, subs. 1-1a, to inspect the crime scene but was not entitled to a new trial because the denial of his motion to inspect was harmless. The Supreme Court affirmed, holding (1) Rule 9.01, subs. 1-1a, does not allow the State to allow a defendant to inspect a crime scene that is the control of a third party; and (2) even if assuming Defendant had the constitutional inspection rights he asserted here, any error in denying his motions to inspect the property was harmless beyond a reasonable doubt. View "State v. Lee" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the district court's ruling that the admission of statements made by Defendant using a foreign language interpreter did not violate the Confrontation Clause of the Sixth Amendment to the United States Constitution or hearsay rules, holding that the Confrontation Clause was not violated in this case and that the statements were not subject to the hearsay rules.The district court convicted Defendant of first-degree criminal sexual conduct and sentenced him to 144 months in prison. Defendant appealed, arguing that the admission of his translated statements violated the Confrontation Clause and hearsay rules. The court of appeals upheld the district court's ruling that the court's admission of the interpreter's translated statements were proper. The Supreme Court affirmed, holding that the translated statements did not violate the Confrontation Clause and that the district court did not abuse its discretion in admitting the translated statements into evidence over the hearsay objection by Defendant. View "State v. Lopez-Ramos" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court summarily denying Appellant's claims for ineffective assistance of trial and appellate counsel without holding an evidentiary hearing, holding that Appellant's claims were barred by the relevant statute of limitations.Appellant was convicted of first-degree premeditated murder under an aiding-and-abetting theory of liability. The district court imposed a sentence of life without the possibility of release. Appellant later filed his postconviction petition requesting an evidentiary hearing on his claims for ineffective assistance of trial and appellate counsel and mentioning a motion for testing conducted under Minn. Stat. 590.01, subd. 1a. The postconviction court concluded that Appellant's claims were barred by the two-year statute of limitations, Minn. Stat. 590.01, subd. 4. The Supreme Court affirmed, holding (1) Appellant's claims were barred by the two-year statute of limitations; and (2) Appellant's reference to testing did not satisfy the requirements of subdivision 1a. View "Jackson v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals dismissing the Minnesota Department of Natural Resource's (DNR) appeal of an order of the Chippewa/Swift Joint Board of Commissioners (Board) reestablishing the records for a public drainage system pursuant to Minn. Stat. 103E.101(4)(a), holding that the Board's order was a quasi-judicial decision subject to certiorari review.In dismissing the appeal, the court of appeals held that the order reestablishing records was not a quasi-judicial decision subject to certiorari review because the order was not a binding decision regarding the disputed claim but, rather, a preliminary step in a repair process. The Supreme Court disagreed, holding that record-reestablishment orders are final and binding and are therefore quasi-judicial decisions subject to quasi-judicial review. View "Minnesota Department of Natural Resources v. Chippewa/Swift Joint Board of Commissioners" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment for Respondent on Appellant's complaint alleging that Respondent failed to engage in an interactive process to determine reasonable accommodations for her disability before Respondent ended her employment, holding that genuine factual disputes existed that precluded summary judgment.Appellant brought this action under the Minnesota Human Right Act, Minn. Stat. 363A.01-.44, that included a claim for failure to accommodate her disability. Respondent argued that no interactive process was required under the Act, and regardless, Appellant could not perform the essential functions of her position and continuing her employment posed a serious threat to her health. The Supreme Court reversed the district court's grant of summary judgment for Respondent, holding (1) the Act does not mandate an interactive process; but (2) it was error to grant summary judgment for Respondent because genuine factual disputes existed regarding the essential functions of Appellant's employment and Respondent's defense that there was a "serious threat to the health or safety" of Appellant. View "McBee v. Team Industries, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying the motion for summary judgment filed by the City of Minneapolis as to Plaintiff’s claims under the Human Rights Act that the City discriminated against him by failing to accommodate his disability and retaliated against him for seeking an accommodation, holding that Plaintiff’s claims under the Human Rights Act were not barred by the exclusive-remedy provision of the Minnesota Workers’ Compensation Act.In moving for summary judgment, the City argued that Plaintiff’s claims were barred by the exclusivity provision in the Workers’ Compensation Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court overruled its decision in Karst v. F.C. Hayer Co., 447 N.W.2d 180 (Minn. 1989) and reversed, holding that an employee can pursue claims under both the Workers’ Compensation Act and the Human Rights Act because each act provides a distinct cause of action that redresses a discrete type of injury to an employee. View "Daniel v. City of Minneapolis" on Justia Law

The Supreme Court affirmed the decision of the postconviction court summarily denying Appellant’s present petition for postconviction relief, holding that the record conclusively established that Appellant was not entitled to relief.Appellant was convicted of aiding and abetting first-degree felony murder. After the conviction was affirmed on direct appeal, Appellant filed three petitions for postconviction relief, each of which was summarily denied. At issue int his appeal was Appellant’s fourth petition for postconviction relief, which the postconviction court denied without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his claims. View "Crow v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions but reversed his sentence for first-degree murder of an unborn child, holding that the plain language of Minn. Stat. 609.106 does not authorize a sentence of life imprisonment without the possibility of release for a conviction of first-degree murder of an unborn child.Defendant was convicted of first-degree premeditated murder and first-degree premeditated murder of an unborn child. The Supreme Court upheld the convictions but reversed Defendant’s life sentence, holding (1) structural error did not occur when the district court judge presided over Defendant’s jury trial after defense counsel commented during an ex parte conversation that Defendant might commit perjury; (2) Defendant received effective assistance of counsel; (3) the district court did not commit plain error in its jury instructions; and (4) Defendant’s sentence of life imprisonment without the possibility of release for his conviction of first-degree murder of an unborn child was not authorized by section 609.106. View "State v. Mouelle" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the decision of the postconviction court that Defendant was entitled to a new trial because a juror was actually biased and not sufficiently rehabilitated but that the search of Defendant did not violate his Fourth Amendment rights.Defendant was convicted of possession of a firearm by an ineligible person. Thereafter, Defendant filed a postconviction petition arguing that the district court erred in denying his for-cause strike of Juror 18 and that the police unreasonably searched and seized him, violating his Fourth Amendment rights. The postconviction court rejected Defendant’s Fourth Amendment argument but concluded that the district court committed reversible error by denying the motion to strike Juror 18 for cause. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the search of Defendant was objectively reasonable under the emergency-aid exception to the Fourth Amendment warrant requirement; and (2) Defendant was entitled to a new trial because the presence of the actually biased juror. View "Ries v. State" on Justia Law

The Supreme Court held that a warrantless narcotics-dog sniff in the hallway outside Defendant’s apartment did not violate Defendant’s right to be free from unreasonable searches under the Minnesota and United States Constitutions.A jury found Defendant guilty of first-degree and fifth-degree possession of a controlled substance and possession of a firearm by a prohibited person. The court of appeals reversed the convictions, concluding that the narcotics-dog sniff in the hallway immediately adjacent to Defendant’s apartment door was a search under the Fourth Amendment because it violated Defendant’s reasonable expectations of privacy and that the warrantless search of Defendant’s home was unreasonable. The Supreme Court reversed, holding (1) the police did not intrude upon the curtilage of Defendant’s apartment or his reasonable expectation of privacy when they conducted the dog sniff, and therefore, no Fourth Amendment search occurred; and (2) because the police were lawfully present in the hallway and had a reasonable suspicion of criminal activity, the dog sniff did not violate Minn. Const. art. I, section 10. View "State v. Edstrom" on Justia Law