Judge, Court of Appeals of Minnesota
U.S. Bank N.A. v. Cold Spring Granite Co.
Court of Appeals of Minnesota · 2010-09-14 · cited 4×
This case involved minority shareholders in Cold Spring Granite Company who, after refusing offers to redeem or convert their shares, challenged a board-approved 1-to-7,132.23 reverse stock split that fractionalized their holdings and led to involuntary redemption at a board-determined price of $986.50 per share. The shareholders sued for judicial valuation under the Minnesota Business Corporations Act, arguing they were entitled to dissenters' rights or equitable relief for unfairly prejudicial conduct. The district court, adopting the special master's findings, ruled in favor of the corporation and its majority shareholder, concluding that the reverse split and redemption were permitted without a shareholder vote, that the board's fair-value determination was conclusive absent fraud, and that no dissenters' rights applied. The Court of Appeals affirmed, holding that the statutory scheme did not provide for judicial revaluation here and that the transaction followed corporate formalities, including an independent appraisal and abstention by interested directors, so equitable relief was unavailable on these facts.
business & regulatory
State v. Jeffries
Court of Appeals of Minnesota · 2010-08-31 · cited 1×
In State v. Jeffries, the defendant was charged with felony domestic assault and entered a guilty plea under a negotiated agreement for a stayed sentence, which the district court accepted in open court before later rejecting the agreement due to the defendant's criminal history and allowing withdrawal of the plea. Jeffries then entered a second guilty plea and was convicted and sentenced to 60 months. On appeal, he argued that the initial plea acceptance constituted a conviction that triggered double jeopardy protections and barred further prosecution. The Minnesota Court of Appeals affirmed, holding that jeopardy attaches at sentencing rather than plea acceptance in guilty plea proceedings and that the second counseled guilty plea waived the double jeopardy claim. The court also rejected the ineffective assistance of counsel argument, concluding that the claim was tenuous under existing Minnesota law.
criminal lawprocedure
State v. Holmes
Court of Appeals of Minnesota · 2010-08-17 · cited 1×
In State v. Holmes, Todd Holmes was convicted of theft by nonpayment for improvements under Minn. Stat. § 514.02, subd. 1(b), after accepting a $5,000 down payment for barn and house repairs but failing to perform the work or return the funds. The district court instructed the jury that the statute prohibits receiving payment for a real-estate improvement and not using the proceeds for that improvement. On appeal, the court reversed the conviction, ruling that the statute instead requires proof that the defendant failed to pay others for labor, skills, materials, or machinery contributed to the improvement, knowing those costs remained unpaid. No evidence showed that Holmes had obtained any such contributions for the project, so the conviction was reversed for insufficient evidence.
criminal law
State v. Robideau
Court of Appeals of Minnesota · 2010-06-15 · cited 4×
This case involved Raymond Robideau's appeal from his conviction for second-degree intentional murder after stabbing his girlfriend to death. The court affirmed the conviction, finding no error in admitting an allegedly involuntary statement for impeachment or in the detective's credibility opinions, as any issues were harmless given the strong evidence of guilt including confessions to inmates and physical evidence. Regarding sentencing, although one aggravating factor was invalid, the court upheld the upward departure because it was also based on the valid factor of the crime occurring in the presence of the victim's child, whom the defendant knew would likely discover the body, and the district court indicated it would have imposed the same sentence on that basis alone.
criminal lawprocedure
Harrison v. Commissioner of Public Safety
Court of Appeals of Minnesota · 2010-05-04 · cited 18×
The case involved Jesse Wayne Harrison challenging the revocation of his driver's license on two occasions following DWI arrests, where he had consented to blood tests under the implied-consent law. Harrison argued that the subsequent warrantless testing of the preserved blood samples for alcohol concentration violated his rights against unreasonable searches under the U.S. and Minnesota Constitutions, and that the evidence should have been suppressed. The district courts sustained the revocations, finding no warrant was needed for testing after lawful seizure of the samples. The appellate court affirmed, reasoning that once blood is lawfully obtained specifically for alcohol-concentration analysis, the individual has no legitimate expectation of privacy in that information, so the testing does not constitute a search implicating constitutional protections.
criminal lawcivil rightsprocedure
Rodenwald v. State Department of Natural Resources
Court of Appeals of Minnesota · 2010-01-19
The case involved a negligence claim by Charles Rodenwald against the Minnesota Department of Natural Resources after he slipped on smooth, clear ice in a DNR driveway while working there and sustained injuries. The district court granted summary judgment to the DNR, applying the mere-slipperiness rule, which holds that a governmental entity has no duty to remove ice from public areas unless it has formed dangerous ridges, obstructions, or irregularities. The Court of Appeals affirmed, reasoning that the rule's rationale—avoiding physically impossible or financially unreasonable burdens in Minnesota's climate—applies equally to state agencies as to municipalities, and that the rule limits the duty of care rather than conferring immunity. The court also found no genuine issues of material fact, as the ice was undisputedly smooth and slippery without additional hazards, and rejected arguments that the rule had been statutorily abrogated or did not extend to state entities.
torts & liability