David Minge

The case involved a Minnesota lawsuit by subcontractor JL Schwieters Construction against Goldridge Group and related entities over unpaid work on a senior living center project and alleged fraudulent transfers from the insolvent White Pines LLC subsidiary to its parent Goldridge Group. Goldridge Group, a Wisconsin company, moved to dismiss for lack of personal jurisdiction, arguing insufficient minimum contacts with Minnesota. The district court denied the motion, and the appellate court affirmed, reasoning that pretrial evidence showed Goldridge Group treated White Pines LLC as its alter ego or instrumentality by controlling its operations, guaranteeing loans, and receiving direct transfers, allowing imputation of the subsidiary's Minnesota contacts.

procedurebusiness & regulatory

The case involved the City of St. Paul challenging the dismissal of its certiorari appeal from a civil service commission decision under the Veterans Preference Act that prevented the termination of a veteran firefighter. The district court had dismissed the city's appeal as untimely under the 15-day deadline in Minn. Stat. § 197.46. The appeals court reversed, holding that the 60-day deadline in Minn. Stat. § 484.01, subd. 2 applies to first-class cities seeking judicial review of such decisions because the VPA's appeal provisions address only veterans' appeals and do not govern employers. The court reasoned from the plain statutory language and principles of statutory construction that the VPA does not authorize or set deadlines for an employer's appeal.

labor & employmentprocedure

The case involved Adolph Valentine's conviction on two counts of felony domestic assault against his girlfriend J.K. following an incident in which witnesses reported he pulled her from a car and struck her. Valentine appealed, arguing that the district court erred by admitting evidence of his prior assaults on another girlfriend as relationship evidence under Minn. Stat. § 634.20 and as Spreigl evidence, allowing expert testimony on battered-woman syndrome, admitting voicemail messages, and that prosecutorial misconduct and cumulative errors deprived him of a fair trial. The Minnesota Court of Appeals affirmed the conviction, concluding the prior-assault evidence was properly admitted because its probative value was not substantially outweighed by the danger of unfair prejudice, the other evidentiary rulings were not erroneous or did not meet the plain-error standard, and any errors were harmless given the strength of the evidence against Valentine.

criminal lawprocedurefamily law

The case concerned voters in the Eastern Carver County school district who sought a writ of mandamus to compel the school board to hold a board election on November 3, 2009, after the board adopted a resolution transitioning its elections from odd- to even-numbered years by extending the terms of sitting members by one year. The district court denied the writ, and the court of appeals affirmed. The court held that Minnesota law authorizes school boards to make such a transition through an orderly plan, that the board's plan satisfied this requirement and involved discretionary judgment not subject to mandamus, and that alternative remedies such as a petition under Minn. Stat. § 204B.44 were available to the appellants.

electionsprocedure

In State v. Arends, the state charged the defendant with theft by swindle for unauthorized credit card use against her former employer, after the parties had settled a related civil wrongful-termination lawsuit that included counterclaims for the alleged theft. The civil settlement released all claims arising from the employment and provided that neither party would pay anything. The district court certified the question of whether such a complete civil settlement precludes the state from seeking restitution for the victim in the criminal case. The court of appeals answered yes, holding that a valid, complete settlement resolving all economic-loss claims means the victim has no uncompensated loss, so restitution—which requires proof of actual economic loss under Minn. Stat. § 611A.045—is unavailable.

criminal lawprocedure

This case involved a bank suing borrowers and their company for defaulting on promissory notes, a contract for deed, and related security agreements covering both real property and business assets, after a series of transactions that refinanced prior debts; the bank also sought attorney fees incurred in enforcing its rights, including in a prior related lawsuit by another creditor. The district court awarded the bank attorney fees, denied a jury trial on the fees issue, dismissed counterclaims including for punitive damages, and distributed court-deposited funds to the bank. On appeal, the court affirmed, holding that the state constitution does not require a jury trial for attorney fees that are collateral to a contract rather than direct damages, that the fee award was reasonable and supported by the loan documents, and that the funds were properly awarded under procedural rules governing deposits in lieu of a supersedeas bond. The decision rested on contract interpretation, the distinction between contractual fee recovery and other remedies, and the absence of error in factual findings or discretionary rulings.

business & regulatorypropertyprocedure

The case involved LeAnn Taylor's claim that LSI Corporation terminated her employment in violation of the Minnesota Human Rights Act because her husband was also leaving the company as its president. The district court granted summary judgment to LSI, finding that Taylor failed to show a direct attack on the institution of marriage. The Court of Appeals reversed, holding that the MHRA's definition of marital status discrimination expressly covers an employer's adverse action based on the identity or situation of an employee's spouse. The court reasoned that the statute, as amended and interpreted in prior cases, prohibits such discrimination without requiring proof of animus toward marriage itself. The matter was remanded for further proceedings on whether Taylor established a prima facie case.

labor & employmentcivil rights

The case involved a teacher employed at Pines School, a facility within Anoka County's juvenile corrections center, who sought unemployment benefits after his summer work hours were reduced due to lower student enrollment. The court affirmed the denial of benefits, applying Minn. Stat. § 268.085, subd. 7, which bars use of wage credits from educational institution employment for benefits during periods between successive academic years or terms if the employee has reasonable assurance of future work. The core reasoning established that Pines School qualifies as an educational institution under the statute because it is operated by the county, approved by the state education department, and provides credit-bearing instruction, and that the variable summer session fell between academic years despite year-round operations. The court noted that the statute applies to county employees providing services to educational institutions and narrowly construed eligibility to exclude benefits in this context.

labor & employment

In State v. Heiges, Samantha Anne Heiges was convicted of second-degree murder after confessing to drowning her newborn daughter in a bathtub at the direction of her abusive boyfriend and disposing of the body. Heiges appealed, arguing insufficient evidence to corroborate her confessions under Minnesota statute, errors in jury instructions on burden of proof and duress, improper admission of a late-disclosed witness's testimony, and an improper sentence. The Minnesota Court of Appeals affirmed the conviction, holding that the confessions were adequately corroborated by consistent statements to friends and other evidence, and finding no reversible errors in the trial proceedings or sentencing. A dissent argued that there was insufficient independent evidence of the child's live birth and death to support the conviction.

criminal law

The case involved a defendant whose driver's license had been canceled, who was convicted of driving without a valid license after being stopped while operating a two-wheeled motorized vehicle with a 50cc engine and capable of 30 mph. She argued that the vehicle qualified as a motorized foot scooter under Minn. Stat. § 169.01, subd. 4c, which would exempt it from licensing requirements in chapter 171. The district court found her guilty, and the court of appeals affirmed, concluding that the vehicle's wheels measured 15 inches in diameter including the tires and thus exceeded the statutory limit of ten inches or smaller. The court interpreted the term "wheel" according to its ordinary meaning, which encompasses the tire as the portion that contacts the ground.

criminal law

State v. Borg concerned the conviction of appellant Brett Borg for third-degree criminal sexual conduct, based on allegations that he engaged in sexual penetration with M.W. while she was mentally incapacitated or physically helpless after a night of drinking. Borg challenged the conviction on multiple grounds, including the admission of evidence regarding his pre-arrest silence. The court reversed the conviction and remanded the case, holding that the district court erred by permitting the state to elicit testimony about Borg's pre-Miranda, pre-arrest silence during its case-in-chief. This violated the Fifth Amendment because the right to silence is constitutional and not dependent on Miranda warnings, and the error was not harmless beyond a reasonable doubt in a case that turned on witness credibility with limited supporting evidence.

criminal law

In this case, property owner Chad DeRosier sued contractor Utility Systems of America after the parties' oral agreement for USA to deposit 1,500 cubic yards of fill material on DeRosier's land was breached when USA deposited approximately 6,500 cubic yards, causing extra removal costs and construction delays. The district court awarded DeRosier $22,829 in general damages and $8,000 in consequential damages. On appeal, the Minnesota Court of Appeals reversed the consequential damages award because such special damages were not specifically pleaded as required by court rules, affirmed the general damages award as supported by the evidence, and held that DeRosier had no obligation to mitigate damages by accepting USA's offer to remove the excess fill for $9,500 given the strained relationship and other available options. The court therefore modified the judgment to $22,829.

business & regulatorypropertyprocedure

This case involved a claim by Phillip Kelly, an African-American man, that Minneapolis police officers engaged in racial discrimination when they detained and arrested him for disorderly conduct and obstruction after he was cleared as a suspect in a nearby robbery. The Minneapolis Commission on Civil Rights found that the officers did not use excessive force but that the continued detention after the show-up was unreasonable and that race was a discriminatory factor, awarding Kelly damages and imposing civil penalties. On appeal by the police department, the Minnesota Court of Appeals affirmed the commission's decision, holding that it was supported by substantial evidence under the applicable standards for public-services discrimination claims and that the officers' actions violated city ordinances prohibiting racial discrimination. The court applied a burden-shifting framework similar to McDonnell Douglas and found the commission's factual determinations on the role of race and the improper arrest under Minn. R. Crim. P. 6.01 were not arbitrary or unsupported.

civil rightscriminal law

This case involved a boundary dispute between two parcels of Torrens-registered property, where respondents sued for trespass after appellants destroyed survey stakes and appellants counterclaimed that a fence encroached on their land. The parties submitted the matter to binding arbitration, which determined the correct boundary line and awarded damages, and the district court confirmed the arbitrator's full decision including the boundary findings. The appellate court reversed, ruling that Minn. Stat. ch. 508 establishes the exclusive statutory procedure for altering boundary lines of Torrens property and that arbitration cannot be used to make such determinations.

propertyprocedure

The case involved competing mortgages on a residential homestead property purchased by the Schultzes. The Goreses recorded a mortgage that lacked the required signature of Cody Schultz (whose name was forged by her husband), while the Banks later recorded their own mortgages on the same property. The district court dismissed the Banks' challenge to the validity of the Goreses' mortgage under Minn. Stat. § 507.02 and ruled that it had priority due to earlier recording. The court of appeals reversed, holding that the Banks could raise the voidness issue and that the Goreses' mortgage was invalid because the statute requires both spouses' signatures for any conveyance of homestead property.

property

This case involved a dispute over the redemption period following foreclosure by advertisement on a townhome-association lien. Palladium Holdings foreclosed on the lien and obtained a district court order shortening the statutory six-month redemption period to five weeks under Minn. Stat. § 582.032, subd. 7, based on affidavits claiming the property was abandoned and the lienholder could not be found for service. Zuni Mortgage Loan Trust moved under Minn. R. Civ. P. 60.02 to vacate the order, and the district court granted the motion after analyzing the Finden factors. On appeal, the Minnesota Court of Appeals affirmed, holding that rule 60.02 applies to such orders, that the Finden factors supported vacating the order, and that any error in accepting untimely affidavits was harmless.

propertyprocedure

The case involved appellants injured in a car accident allegedly caused by a city-employed firefighter's negligent driving while on duty. Appellants entered a Drake v. Ryan partial release and satisfaction with the firefighter, accepting payment from his primary insurer while reserving claims up to the limits of believed excess coverage and then sued the city for vicarious liability. The district court granted summary judgment to the city, holding that the release fully released the firefighter and thereby eliminated the city's vicarious liability. The appellate court reversed, concluding that the release did not fully release all claims against the firefighter and that the city had no indemnity claim against the firefighter due to a statute requiring the city to defend and pay judgments arising from the firefighter's official duties, so the vicarious liability claim survived.

torts & liabilityprocedurelabor & employment

In State v. Stockwell, the defendant was convicted of felony stalking after she followed a Muslim woman in her vehicle, confronted her in a parking lot about her religion and Islamic terrorism, and made threatening statements, causing the victim to feel frightened. The defendant challenged her conviction under Minn. Stat. § 609.749, subd. 2(a)(2), arguing that the stalking statute was unconstitutionally overbroad in violation of the First Amendment, both facially and as applied, that it was unconstitutionally vague, and that the evidence was insufficient to support the conviction. The court affirmed the conviction, holding that the statute did not implicate protected expressive conduct in this context, that it was not vague, and that the evidence of aggressive following and statements based on the victim's religion was sufficient to prove the required elements of harassment. The decision emphasized that the statute includes a savings clause preserving constitutional protections and that the jury could accept portions of the victim's testimony.

criminal lawfree speechreligious libertycivil rights

The case involved an insurance coverage dispute arising from a high school shop class incident in which Shawn Meyer pulled a stool out from under Curtis Nietfeld as a joke, leading to Nietfeld's serious head injury after further horseplay. RAM Mutual Insurance Company sought a declaratory judgment that its homeowner's policy did not cover the resulting negligence and assault claims against Meyer, arguing that the incident was not an "occurrence" (defined as an accident neither expected nor intended) and that the policy's intentional-act exclusion applied. A jury found that Meyer did not know or have reason to know that significant harm was substantially certain to result, and the district court ruled in favor of coverage. The court of appeals affirmed, holding that absent specific intent to injure, the conduct qualified as an occurrence under Minnesota precedent, the exclusion did not bar coverage, and the special-verdict question was within the district court's discretion.

torts & liabilitybusiness & regulatory

The City of Willmar sought to acquire private property in fee simple through eminent domain to build interceptor sewers and related infrastructure for a new wastewater-treatment facility needed to meet regulatory requirements. The district court granted the city's petition after trial, and the landowners appealed, arguing that state law limited the city to taking only an easement for sewer purposes, that the taking was unnecessary, and that the decision was arbitrary. The court of appeals affirmed, holding that Minn. Stat. § 465.01 authorizes cities to take land in fee simple for sewerage and drainage even though it also mentions acquiring a right-of-way, that the city had shown necessity, and that its actions were reasonable. The decision rested on statutory interpretation treating the relevant clauses as conjunctive and on the narrow scope of review in condemnation cases, which focuses on public purpose and necessity.

property