Sandra Gardebring Ogren

The case involved Solomon Shannon's appeal from his first-degree murder conviction in the shooting death of Eric Davis, where the central issue was the trial court's admission of evidence regarding Shannon's alleged participation in a separate robbery and shooting five months earlier. The Minnesota Supreme Court reversed the conviction and remanded for a new trial, concluding that the admission of this Spreigl evidence constituted reversible error. The court reasoned that the evidence failed to clearly and convincingly establish Shannon's involvement in the prior incident, was not sufficiently relevant to prove identity or common scheme or plan under the applicable standards, and its prejudicial effect outweighed any probative value.

criminal lawprocedure

The case concerned Arthur Dale Senty-Haugen, a convicted sex offender who stipulated to commitment as a sexual psychopathic personality or sexually dangerous person (SPP/SDP) under Minnesota statutes but sought placement in a less restrictive private treatment program called Alpha House instead of a state secure facility. After funding for Alpha House could not be secured and the district court denied efforts to compel government agencies to pay for it, Senty-Haugen was committed indefinitely to the state program; the court of appeals affirmed. The Minnesota Supreme Court affirmed on different grounds, holding that the SPP/SDP commitment statutes contain no requirement for treatment in the least restrictive alternative, unlike statutes governing commitments for mental illness or other conditions, and that a procedural rule imposing such a requirement does not apply because the statute controls. The court rejected mootness arguments and declined to address unraised constitutional claims.

criminal lawcivil rightsprocedure

This case involved Ka Ying Vue seeking uninsured motorist benefits under her husband's State Farm policy after being injured in a collision with an uninsured vehicle while riding in her husband's other car, the Buick Skylark, which lacked insurance. State Farm denied coverage, arguing that Vue was a co-owner of the Skylark due to her marriage and thus subject to policy exclusions for occupying an owned but uninsured vehicle. The district court granted summary judgment to State Farm, but the court of appeals reversed, and the Minnesota Supreme Court affirmed that decision. The court held that legal title creates a rebuttable presumption of ownership under the Minnesota No-Fault Act, with no statutory or precedential basis for presuming spousal co-ownership in this context absent rebuttal evidence. Accordingly, Vue was not an owner, the exclusions did not apply, and she could pursue benefits based on the uninsured status of the colliding vehicle.

business & regulatoryproperty

The case concerned whether a trust established by Lois Doyle for the benefit of her husband William Doyle qualified as a spendthrift trust, thereby shielding its assets from attachment by Doyle's judgment creditors. The creditors had obtained a 1993 judgment against Doyle arising from a defaulted business loan guarantee and sought to attach trust assets after alleging fraudulent transfers. The trial court and court of appeals held the trust was not spendthrift because Doyle served as both primary beneficiary and trustee with discretion over distributions, allowing attachment. The Minnesota Supreme Court reversed, concluding that the settlor's intent to protect the assets from creditors created an implied spendthrift trust and that Doyle's trustee powers did not defeat that protection under trust law principles.

propertyprocedure

In State v. Gisege, the appellant, who had been convicted of first-degree murder and sentenced to life imprisonment, filed a postconviction petition seeking independent DNA retesting of blood evidence presented by the state at his trial. The district court denied the petition after treating it as a request for postconviction relief under Minn. Stat. § 590.01. The Minnesota Supreme Court affirmed, holding that the request was procedurally barred because the issue of independent DNA testing was known to trial counsel before trial but was not pursued, and it was also not raised on direct appeal. The court relied on precedent such as Miller v. State, which precludes postconviction claims that were known but not raised earlier, absent newly discovered evidence unavailable at the time of trial.

criminal lawprocedure

In 1988, Jerald Boitnott was convicted of first-degree felony murder and second-degree assault and sentenced to life in prison. Nearly eight years later, he filed a petition for postconviction relief alleging ineffective assistance of trial counsel for failing to communicate an alleged state offer to accept a guilty plea to second-degree murder. The postconviction court denied both an evidentiary hearing and the petition, and the Minnesota Supreme Court affirmed. The court reasoned that none of the documents submitted by Boitnott, including depositions, letters, and notes, showed that the state had ever extended a second-degree murder plea offer, as the prosecutor and defense counsel both testified that the only offer involved a plea to first-degree felony murder. Because the record contained no evidence supporting the existence of the claimed offer, no hearing or relief was required.

criminal lawprocedure

The case concerned the constitutionality of Minnesota's contamination tax, which recaptures lost property tax revenue by taxing the reduction in a parcel's assessed value caused by environmental contamination. Property owners John and Sharolyn Westling, whose industrial site was contaminated and had its market value reduced to zero, challenged the tax under the Minnesota Constitution's uniformity clause, the federal Equal Protection Clause, and state and federal takings clauses. The tax court upheld the statute, and the Minnesota Supreme Court affirmed, concluding that the tax created no constitutional violation. The court reasoned that the tax applied only to qualifying reductions in value and used variable rates based on whether the owner was responsible for the contamination and whether cleanup was underway, without infringing on any fundamental right to taxation at actual value.

taxesenvironmentproperty

This case involves Randy Folkers' 1996 conviction for two counts of second-degree murder in the shooting death of his girlfriend Alicia Srozinski in his Minneapolis garage, where the main dispute at trial was whether Folkers or his friend Joshua Ploog fired the gun. On appeal, Folkers challenged the admission of a letter describing Ploog's plea agreement with the state, the sufficiency of the evidence, and the trial court's upward departure from the presumptive 306-month sentence to 360 months. The Minnesota Supreme Court held that admission of the plea agreement was not error, the evidence including witness testimony, physical evidence from the scene, and forensic analysis was sufficient to support the conviction, and the sentencing departure was not an abuse of discretion, affirming the court of appeals' decision upholding the conviction and sentence.

criminal lawprocedure

The case involved Sarith Peou's appeal from his conviction on two counts of first-degree murder while committing aggravated robbery for the 1996 killings of two St. Paul jewelry store owners. Peou raised issues concerning jury instructions on the timing of intent for felony murder, the refusal to instruct on lesser-included manslaughter, the sufficiency of evidence disproving self-defense, and the sufficiency of evidence supporting the felony-murder convictions. The Minnesota Supreme Court affirmed the convictions, holding that the trial court did not abuse its discretion on the instructions, that the evidence was sufficient to reject self-defense, and that the jury could reasonably find the murders and robbery formed a single continuous transaction even if the robbery occurred after the killings.

criminal lawprocedure

The case involved Debra Ann Souto, who was convicted of fifth-degree possession of a controlled substance after a search of her home pursuant to a warrant uncovered a small amount of methamphetamine. Souto appealed, arguing that the warrant application lacked probable cause because it did not sufficiently connect her alleged drug activities to her residence, relied on outdated information, and provided insufficient details on the informant's reliability. The Minnesota Supreme Court reversed the conviction, concluding that the affidavit did not provide a substantial basis for finding probable cause that drugs or related evidence would be found at the residence at the time of the search. The decision focused on the requirements for establishing a nexus between the suspected criminal activity and the place to be searched under the totality of the circumstances.

criminal lawprocedure

This case was a pretrial appeal by the state in a prosecution of Aron Edrozo for second-degree assault with a dangerous weapon (plus related charges) arising from an alleged vehicle-ramming incident. The Minnesota Supreme Court reversed the trial court's suppression of two sets of statements: a secretly tape-recorded conversation between Edrozo and a companion while seated in the rear of a marked police car, and later unrecorded voluntary statements Edrozo made to an investigator at an impound lot. The court held that the recording did not violate the Fourth Amendment or state privacy statutes because a person in the back of a police car has no reasonable expectation of privacy, and that the impound-lot statements were admissible because they were unsolicited, voluntary, and not the product of interrogation after Edrozo had invoked counsel. The decisions suppressing the statements were therefore clearly erroneous.

criminal lawprocedure

The case concerned a property owner's petition challenging the county's assessed value of its mall for property tax purposes. The tax court dismissed the petition because the owner failed to provide required income and expense data to the county within 60 days of filing, as mandated by Minn. Stat. section 278.05, subd. 6(a). The Minnesota Supreme Court affirmed the dismissal, holding that the statute's plain language requires submission of all available information even if the petitioner views it as incomplete or subject to later audit. This ruling followed directly from the court's prior decision in BFW Co. v. County of Ramsey, which interpreted the same provision.

taxespropertyprocedure

This case involved David Lee Cross's appeal from his convictions for first-degree domestic abuse homicide and second-degree intentional homicide in the 1996 death of his girlfriend, Heidi Rae Haines, in Minnesota. The court affirmed the convictions after a jury trial, addressing challenges to the admission of evidence showing a past pattern of domestic abuse by Cross against Haines, including witness testimony about bruises, assaults, threats, and arguments, and to the lack of a specific jury instruction requiring proof of each prior incident beyond a reasonable doubt. The opinion reviewed the domestic abuse homicide statute, which requires a past pattern of qualifying acts against a family or household member, and prior precedent interpreting the law as neither unconstitutionally vague nor requiring additional restrictions on the definition of a pattern. The court held that the evidence was properly admitted without a heightened pretrial showing and that the jury instructions were adequate, as the pattern element does not demand separate beyond-a-reasonable-doubt findings on each predicate act.

criminal law

This case concerned an employer's claim for reimbursement from Minnesota's special compensation fund under the former second-injury law for workers' compensation benefits paid after an employee with pre-existing diabetes suffered a worsened ankle injury. The employer had filed a registration form in 1987 that listed the impairment and a physician's signature but omitted the employee's name, employer details, and other identifying information. A compensation judge denied reimbursement, finding the registration invalid under Minn. Stat. § 176.131, but the Workers' Compensation Court of Appeals reversed. The Minnesota Supreme Court reversed again, holding that the incomplete application did not substantially comply with statutory registration requirements and therefore could not support reimbursement for the 1989 injury.

labor & employmentprocedurebusiness & regulatory

The case involved Carson Pirie Scott & Co. challenging the Hennepin County tax court's assessed values for its retail department store property in the Ridgedale shopping center for the tax years 1991 through 1994. The tax court had valued the property higher than the county's original assessments, at $6.9 million for 1991-92, $7.1 million for 1993, and $7.3 million for 1994. The Minnesota Supreme Court affirmed the tax court's decision, holding that the valuations were not clearly erroneous because they were reasonably supported by the evidence, including expert appraisals using income, cost, and market approaches, as well as a 1995 sale of the property. The court noted that on appeal without motions for new findings, review is limited to whether the evidence sustains the findings.

taxesproperty

This case concerned the conviction of Richard Allen Ihnot on four counts of first-degree criminal sexual conduct involving a young child. Prior to trial, the state sought to introduce Ihnot's 1984 conviction for third-degree criminal sexual conduct as impeachment evidence if he testified, which the trial court allowed after balancing probative value against prejudice under Minn. R. Evid. 609. The court of appeals reversed, finding an abuse of discretion and a violation of Ihnot's right to testify, but the Minnesota Supreme Court reversed that decision and upheld the trial court's ruling. The court reasoned that the conviction was not stale, credibility was central to the case given the lack of conclusive physical evidence, and the probative value of the evidence outweighed any prejudice despite the similarity of the offenses.

criminal lawprocedure

The case concerned a dispute between Hertz, a self-insured rental car company, and State Farm over liability coverage for an accident involving a rented vehicle driven by Jeffrey Powers, who had declined Hertz's optional liability supplement and had his own State Farm policy. Hertz's rental agreement made its coverage effective only if the renter lacked other liability insurance, and lower courts upheld this as consistent with the Minnesota No-Fault Act. The Minnesota Supreme Court reversed, holding that Hertz's agreement violated the Act. The court reasoned that the No-Fault Act requires every vehicle owner, including self-insured entities like Hertz, to maintain minimum liability coverage that cannot be shifted to the renter's personal insurer through contract terms, and that priority rules under Minn. Stat. § 65B.49 applied to make Hertz's coverage primary.

business & regulatorytorts & liability

The case involved a dispute between Franklin Outdoor Advertising and its lessors, the Laudenbachs, over termination of a lease for land where Franklin maintained advertising signs. Franklin sued for a declaratory judgment interpreting the lease, and the Laudenbachs counterclaimed with claims including trespass. Franklin sought defense coverage from its insurer Western National under a CGL policy and broad form endorsement for personal injury and property damage, but Western National refused. The Minnesota Supreme Court held that Western National had no duty to defend, reasoning that the counterclaim was fundamentally a contract dispute over lease terms rather than a covered tort claim, the alleged trespass arose from intentional acts not qualifying as an "occurrence," and the facts did not trigger coverage for "wrongful entry or other invasion of the right of private occupancy."

business & regulatorypropertytorts & liability

This case involved property owners who inherited agricultural land enrolled in Minnesota’s Green Acres tax deferment program and later challenged payback taxes assessed upon sale of the property. The owners argued that the county’s failure to provide required annual notices of increases in the estimated market value violated state statutes and deprived them of due process, rendering the payback tax calculation invalid, and that the 1995 estimated market value was excessive. The tax court found a statutory notice violation but held that it did not invalidate the assessment or taxes and upheld the county’s $395,400 valuation as reasonable given the later sale price. On appeal, the Minnesota Supreme Court affirmed, concluding that the lack of notice did not prevent collection of the payback taxes under Minn. Stat. § 273.111 and that the valuation decision was supported by the evidence.

taxesproperty

This case addressed whether male-on-male sexual harassment claims are actionable under the Minnesota Human Rights Act (MHRA) in an all-male workplace, specifically when both parties are heterosexual. The plaintiff, a seasonal truck driver, alleged repeated unwelcome sexual comments, gestures, and physical contact by his supervisor that created a hostile work environment, leading to a charge with the Department of Human Rights and a subsequent lawsuit after his seasonal layoff. The trial court granted summary judgment for the defendants, but the court of appeals reversed, and the Minnesota Supreme Court affirmed that reversal. The court held that the MHRA's explicit definition of sexual harassment as a prohibited employment practice does not require proof that the conduct was based on gender or sexual orientation, distinguishing it from federal Title VII standards that focus on sex discrimination. The decision allows the claim to proceed to a factfinder for determination of whether the alleged conduct meets the statutory criteria.

civil rightslabor & employment