Kathleen A. Blatz

This case arose from a police pursuit of a mentally disturbed woman who refused to stop after a 911 call from her therapist, during which officers rammed her vehicle, causing it to strike and kill a pedestrian. The pedestrian's wife sued the driver for negligence, and the driver brought federal constitutional claims under the Fourth and Fourteenth Amendments plus state tort claims against the officers and City of Minneapolis. The Minnesota Supreme Court held that the officers were entitled to qualified immunity on the Fourteenth Amendment substantive due process claim but not on the Fourth Amendment claim, and denied official immunity on the state tort claims, thereby also denying vicarious immunity to the city. The core reasoning applied the 'shocks the conscience' test to the due process claim while distinguishing the objective reasonableness standard for the Fourth Amendment and finding no basis for official immunity under state law.

civil rightstorts & liability

This case involves a pedestrian, Kristen Thompson, who was injured when an SUV driven by Michael Litz struck her while fleeing from Minneapolis police officers in a detox van. Thompson sued Litz, the officers, and the City of Minneapolis for negligence, alleging the officers' failure to use emergency lights and sirens during the pursuit caused her injuries. The district court granted summary judgment to the city and officers based on official immunity for the discretionary decision to pursue, but the court of appeals reversed. The Minnesota Supreme Court affirmed the denial of summary judgment and remanded for fact-finding on whether the officers initiated a vehicular pursuit under the city's policy and whether they used lights and sirens as required, because official immunity does not apply to ministerial duties once a pursuit begins and factual disputes prevent resolution at this stage.

torts & liabilityprocedurecriminal law

This case involves a workers' compensation dispute between an employee named Ellingson and the employer Brady Corporation. The Workers’ Compensation Court of Appeals issued a decision in the matter on June 28, 2005. On further review, the state supreme court was evenly divided and therefore affirmed the lower court's ruling without issuing an opinion. One justice took no part in considering or deciding the case.

labor & employmentprocedure

The case involved Geralyn Engler, who was in the zone of danger during a car accident that seriously injured her young son and who later sought underinsured motorist coverage for emotional distress damages exceeding the settlement with the at-fault driver. The Minnesota Supreme Court reversed the district court and court of appeals, which had limited recovery to distress arising only from Engler's fear for her own safety. The court held that a plaintiff asserting negligent infliction of emotional distress may recover damages for distress from fearing for the safety of or witnessing serious injury to a close relative, provided the plaintiff still meets the three required elements: presence in the zone of physical danger, reasonable fear for her own safety, and resulting severe emotional distress with physical manifestations.

torts & liability

The case involved Hy-Vee Food Stores challenging its three-year disqualification from the WIC program by the Minnesota Department of Health after a cashier at one of its stores accepted a WIC voucher that included payment for a pack of cigarettes along with eligible food items. The court affirmed the disqualification, concluding that federal regulations and corresponding state rules require a three-year vendor disqualification for any exchange of tobacco products for WIC vouchers. The core reasoning was that the rules contain no intent element, so inadvertence or mutual mistake by the parties does not avoid the violation or the mandatory sanction.

business & regulatoryhealthcare

This case involved three Minnesota clinics owned by a non-licensed individual that provided chiropractic, physical therapy, and massage therapy services; the clinics sued insurers for unpaid bills, and the insurers counterclaimed that the clinics' corporate structure violated the corporate practice of medicine doctrine, rendering their contracts illegal. The district court granted summary judgment to the insurers on that ground, but the court of appeals reversed. The Minnesota Supreme Court affirmed in part and reversed in part, holding that the common-law doctrine prohibits lay-owned corporations from practicing chiropractic but does not extend to physical therapy or massage therapy, and remanded for further proceedings. The court reached this result by examining the doctrine's historical application to learned professions, Minnesota statutes regulating the relevant fields, and the absence of precedent barring corporate practice of physical therapy or massage.

business & regulatoryhealthcare

The case involved Christopher Cabrera's convictions for first-degree murder while committing a drive-by shooting, second-degree intentional murder, and four counts of attempted first-degree murder following a shooting incident after a bar fight in Minneapolis. On appeal, Cabrera argued that prosecutorial misconduct during closing arguments, including the prosecutor's claim that the defense theory amounted to 'racist speculation,' warranted reversal. The Minnesota Supreme Court reversed the convictions and remanded for a new trial, holding that the prosecutor's injection of race into the arguments constituted serious misconduct that undermined the defendant's right to a fair trial. Although the evidence of guilt was strong, the court exercised its supervisory powers to reverse in the interests of justice, emphasizing the need to remove any suggestion of racial bias from the proceedings.

criminal law

The case involved Pierre Leake's conviction for first-degree premeditated murder in the stabbing death of Megan Fisher. Leake appealed, arguing that the evidence was insufficient to prove premeditation, that his sentence of life without release was unconstitutional under Apprendi and Blakely, and raising additional claims in a pro se brief about inconsistent verdicts, prosecutorial misconduct, and inconsistent testimony. The Minnesota Supreme Court affirmed the conviction and sentence, holding that phone records, the timing of events, and other circumstances provided sufficient evidence of premeditation and that the constitutional and other challenges lacked merit.

criminal lawprocedure

The case involved a dispute over no-fault automobile insurance benefits under Minnesota law. After American Family discontinued Kiess's benefits following an independent medical exam, Kiess underwent surgery in 1997 without notifying the insurer and had the bills paid by his health insurer; he later filed an arbitration petition in 2001 seeking the no-fault claim plus interest calculated from shortly after the surgery. The Minnesota Supreme Court affirmed the court of appeals, holding that under Minn. Stat. § 65B.54, subd. 1, interest on the claim began to accrue only 30 days after the insurer received actual notice, which occurred when the arbitration petition was filed. The court reasoned that the statute conditions payment of basic economic loss benefits on the insurer receiving reasonable proof of the fact and amount of benefits, and found no basis to apply equitable estoppel to shift the notice obligation based on the discontinuation letter.

business & regulatorytorts & liability

In State v. Jacobson, the defendant was charged with conspiracy to procure unlawful voting and conspiracy to commit forgery after he and employees registered voters using the address of his strip club in Coates, Minnesota. Jacobson sought to introduce evidence that he had relied on advice from his attorney and a letter from the Dakota County Attorney’s Office concluding there was no criminal wrongdoing in a similar case involving police officers registering at their work addresses. The district court excluded this evidence, but the Minnesota Supreme Court held that the evidence of mistake of law was admissible because it was relevant to whether Jacobson had the specific intent to break the law, an element of the conspiracy charges. The court reasoned that excluding the evidence would violate the defendant’s due process right to present a defense and explain his conduct to the jury.

electionscriminal lawprocedure

In State v. Dahlin, the defendant was convicted after a jury trial of aiding and abetting first-degree premeditated murder and sentenced to life in prison. Dahlin appealed, arguing that the trial court committed reversible error by denying his request for jury instructions on the lesser-included offenses of second-degree intentional murder and second-degree unintentional felony murder. The Minnesota Supreme Court held that the trial court erred in refusing to instruct on second-degree intentional murder because the evidence, viewed in the light most favorable to Dahlin, warranted the instruction and the omission was prejudicial. The court reversed the conviction and remanded for a new trial, without reaching the defendant's other claims regarding prosecutorial misconduct and jury selection.

criminal lawprocedure

In State v. Modtland, the defendant pleaded guilty to first- and second-degree burglary charges and received a stayed 107-month sentence conditioned on completing the Minnesota Teen Challenge program. After being discharged from the program, the district court revoked his probation at a hearing based on his admission of the violation but did not explicitly address on the record whether the violation was intentional or inexcusable or whether the need for confinement outweighed the policies favoring probation, as required by State v. Austin. The Minnesota Supreme Court reversed the court of appeals and remanded for a new revocation hearing, holding that district courts must make specific findings on all three Austin factors rather than relying on general statements or allowing appellate courts to search the record for supporting evidence.

criminal lawprocedure

This case involved a wrongful death lawsuit brought by a father against a county and its child protection workers, alleging negligence in investigating reports of suspected child abuse that led to the death of his 19-month-old son. The district court dismissed the claim, and the court of appeals affirmed, finding no civil cause of action under the Child Abuse Reporting Act. The Minnesota Supreme Court reversed, holding that a negligence cause of action can be maintained because the statute imposes a duty on child protection workers to protect specific children suspected of abuse or neglect, creating a special relationship rather than merely a public duty.

family lawtorts & liability

The case involved Ryan Michael Pederson's postconviction petition for a new trial after his convictions for aiding and abetting first-degree murder while committing burglary and second-degree intentional murder. The Minnesota Supreme Court affirmed the postconviction court's denial of relief, concluding that the state's nondisclosure of a seven-page summary of witness Tony Moses's statements did not compromise Pederson's right to a fair trial and that claims regarding impeded access to the witness were procedurally barred under Knaffla. The core reasoning was that Moses's testimony was corroborated by physical evidence and other testimony, the summary contained no material new information that would have altered the outcome, and issues known at the time of the direct appeal could not be relitigated.

criminal lawprocedure

This case arose from a personal injury lawsuit after a car accident, in which the plaintiffs rejected the defendant's $25,000 pretrial offer of judgment under Minn. R. Civ. P. 68 and ultimately obtained a net judgment of only $12,000 after trial and no-fault offsets. The district court and court of appeals allowed the defendant to recover all his costs and disbursements totaling over $8,000 from the beginning of the case. The Minnesota Supreme Court affirmed, holding that the plain language of the post-1985 version of Rule 68 requires the offeree to pay the offeror's costs and disbursements without any limitation to post-offer expenses when the final judgment is not more favorable than the offer. The court rejected arguments relying on the pre-amendment rule language, dicta from prior decisions, federal rule comparisons, and advisory committee comments, concluding that the unambiguous text governs the award.

proceduretorts & liability

In A.C. Ford v. State, Ford appealed the denial of his third and fourth petitions for postconviction relief following his 1993 convictions for first-degree premeditated murder of a police officer and attempted first-degree murder. The Minnesota Supreme Court held that it lacked jurisdiction over the appeal from the third petition because the notice of appeal was filed nearly eleven months after the order, exceeding the 60-day limit under Minn. R.Crim. P. 29.03. Regarding the fourth petition, which alleged that two judge-jury communications during deliberations violated Ford's right to be present, the court affirmed the denial without an evidentiary hearing, finding no disputed material facts and that the record conclusively showed Ford was not entitled to relief under Minn.Stat. § 590.04. The decision rested on jurisdictional rules for appeals and the standard for granting postconviction hearings.

criminal lawprocedure

This case involves a workers' compensation dispute between Wilson and Scanlon International, Inc. The Minnesota Supreme Court reviewed an appeal from a decision of the Workers’ Compensation Court of Appeals filed in September 2004. The court affirmed that decision without issuing its own opinion. It cited precedent establishing that such summary dispositions have no precedential value beyond the specific case at hand.

labor & employmentprocedure

The case involved a workers' compensation dispute between employee Cyr and employer Wensmanns Homes, Inc. The Minnesota Supreme Court affirmed the August 12, 2004 decision of the Workers’ Compensation Court of Appeals. The court issued the affirmation without an opinion, citing precedent that such summary dispositions have no precedential value and only establish the law of the case. The employee was awarded $1,200 in attorney fees.

labor & employment

The case involved a petition by Independence Party candidates seeking placement on Minnesota's 2004 general election ballot after the Secretary of State excluded them for failing to meet the primary vote threshold under Minn. Stat. § 204D.10, subd. 2. The court granted relief to the petitioners and directed that the candidates appear on the ballot. The ruling was based on the conclusion that application of the threshold law was unconstitutional in violation of rights to associate and vote, an argument the Secretary of State did not dispute.

electionscivil rights

The case concerned a petition filed by Bonn Clayton under Minnesota election statutes challenging the eligibility of Judge David Minge to appear on the 2004 ballot as a candidate for the Court of Appeals seat designated for the second congressional district. Clayton alleged that Minge failed to satisfy the one-year residency requirement in Minn. Stat. § 480A.02, subd. 3 at the time of his 2002 appointment following congressional redistricting, and that his subsequent move to another district rendered him ineligible. The Minnesota Supreme Court denied the petition, holding that the statute's provision allowing a judge appointed to a designated seat to remain eligible without regard to later residence changes applied here, that the appointment was valid based on the seat's original designation, and that redistricting did not invalidate the prior appointment or trigger new residency calculations for eligibility purposes.

electionsprocedure