OPINIONS OF THE SUPREME COURT
FILED Wednesday, May 8, 2024
NOTICE - MEDIA RELEASE TIME IS 10:00 A.M.
A22-1679 State of Minnesota, Respondent, vs. Jerry Arnold Westrom, Appellant.
Hennepin County.
1. The district court did not err in concluding that the genetic analysis of a napkin discarded by appellant was not a search because the analysis was only capable of matching appellant’s DNA to the DNA found at the crime scene and appellant had no reasonable expectation of privacy in his identifying information.
2. Any error in precluding appellant from presenting alternative-perpetrator evidence at trial was harmless beyond a reasonable doubt.
3. The district court did not abuse its discretion when it excluded testimony from appellant’s expert as late discovery because the district court properly exercised its authority to respond to violations of the Minnesota Rules of Criminal Procedure.
4. The State did not commit prosecutorial misconduct during its closing argument because none of the prosecutor’s statements constituted error.
5. The circumstantial evidence presented at trial was sufficient to support the jury’s verdict that appellant was guilty of first-degree premeditated murder, and appellant advances no reasonable hypothesis inconsistent with appellant’s guilt.
6. Appellant did not receive ineffective assistance of counsel in violation of his constitutional rights because appellant has not demonstrated that trial counsel’s personal interests materially limited the representation, and appellant was not prejudiced by the representation.
7. No cumulative errors denied appellant his right to a fair trial where only one potential error was present, and the error was harmless beyond a reasonable doubt.
8. It was error to convict appellant of both first-degree felony murder and the lesser-included offense of second-degree intentional murder.
Affirmed in part, reversed in part, and remanded. Chief Justice Natalie E. Hudson.
A22-0570 State of Minnesota, Respondent, vs. Michael Joseph Letourneau, Appellant.
Court of Appeals.
The district court did not abuse its discretion under the Uniform Mandatory Disposition of Detainers Act, Minnesota Statutes section 629.292 (2022), by beginning trial beyond the statutory 6-month period after finding good cause for a continuance because defense counsel required additional time to prepare for trial.
Affirmed. Justice G. Barry Anderson.
A22-0777 Stacy Demskie, et al., Appellants, vs. U.S. Bank National Association, Respondent.
Court of Appeals.
1. Under the Minnesota notice pleading standard, the allegations in the complaint identifying U.S. Bank, N.A. as a shareholder and describing actions taken by U.S. Bank as facts supporting shareholder status were sufficient to survive a motion for judgment on the pleadings.
2. Because the court is evenly divided on whether beneficial owners of a closely held corporation may initiate an action for a buy-out of their interests under Minnesota Statutes section 302A.751 (2022), we affirm the decision of the court of appeals dismissing appellants’ buy-out claim.
Affirmed in part, reversed in part, and remanded. Justice G. Barry Anderson.
Took no part, Justice Paul C. Thissen.
A22-1823 State of Minnesota, Respondent, vs. Michael Allan Carbo, Jr., Appellant.
St. Louis County.
1. The district court did not err by denying the defendant’s motion to suppress evidence stemming from a genetic analysis of DNA collected from crime scene materials because the defendant had abandoned his subjective expectation of privacy in that information by leaving his semen at the scene of the crime.
2. The district court did not err by denying the defendant’s motion to suppress evidence stemming from a genetic analysis of DNA collected from his garbage because law enforcement lawfully and independently obtained identical information from a DNA sample the defendant voluntarily provided.
3. The district court abused its discretion by denying the defendant’s motion to present alternative-perpetrator evidence because the defendant’s proffered evidence clearly had an inherent tendency to connect the alternative perpetrator to the commission of the crime and could have been admitted under the ordinary rules of evidence, and the error was not harmless beyond a reasonable doubt.
Reversed and remanded. Justice G. Barry Anderson.
Concurring, Justice Karl C. Procaccini.
Concurring in part, dissenting in part, Justice Paul C. Thissen,
Concurring in part, dissenting in part, Justice Anne K. McKeig, Justice Margaret H. Chutich, Justice Gordon L. Moore, III.
A21-1101 State of Minnesota, Appellant, vs. Anthony James Trifiletti, Respondent.
Court of Appeals.
1. Because the State failed to establish that a witness would not have been
available to testify in person at some reasonable point in time during the trial, the district
court erred in determining that a witness against the defendant was unavailable under the
Confrontation Clause of the Sixth Amendment to the United States Constitution and
Article I, Section 6, of the Minnesota Constitution.
2. The defendant did not invite the district court’s error in determining that a
witness against him was unavailable under the Confrontation Clause of the Sixth
Amendment to the United States Constitution and Article I, Section 6, of the Minnesota
Constitution.
3. The district court’s error in determining that a witness was unavailable under
the Confrontation Clause was harmless beyond a reasonable doubt.
Reversed. Justice Paul C. Thissen.
Dissenting, Justice G. Barry Anderson.
Took no part, Justice Karl C. Procaccini.
A22-0468 State of Minnesota, Respondent, vs. Kristi Dannette Mcneilly, Appellant.
Court of Appeals.
1. Search warrants authorizing seizure and search of electronic devices were
sufficiently particular under the Fourth Amendment to the United States Constitution and
Article I, Section 10, of the Minnesota Constitution.
2. The guilty verdict in this case was surely unattributable to the evidence
obtained from the search of a law office and so we need not decide whether the warrants
to search that law office were executed in an unreasonable manner because any error in the evidence’s admission was harmless beyond a reasonable doubt.
3. When searching the law office of an attorney who is suspected of a crime,
specific procedures to safeguard privileged materials are required under the supervisory
powers of the Minnesota Supreme Court.
Affirmed. Justice Paul C. Thissen.
Concurring, Justice G. Barry Anderson, Justice Paul C. Thissen.
Took no part, Justice Karl C. Procaccini.
A22-0316 State of Minnesota, Respondent, vs. Said Sharif Maye, Appellant.
Court of Appeals.
1. The district court abused its discretion by allowing the admission of evidence on direct examination of anonymous, threatening phone calls a witness received before trial when the minimal probative value of the threat evidence was substantially outweighed by the risk of unfair prejudice that its admission posed to the defendant.
2. Because the defendant has not demonstrated a reasonable possibility that the admission of evidence on direct examination of anonymous, threatening phone calls a witness received before trial significantly impacted the jury’s verdict, the defendant is not entitled to a new trial.
Affirmed. Justice Gordon L. Moore, III.
Concurring in part, dissenting in part, Justice G. Barry Anderson, Chief Justice Natalie E. Hudson, Justice Paul C. Thissen.
OPINIONS OF THE SUPREME COURT FILED FRIDAY MAY 10, 2024
NOTICE - MEDIA RELEASE TIME IS 10:00 A.M.
A21-0626 Drake Snell, et al., Appellants, vs. Tim Walz, Governor of Minnesota, in his official capacity, et al., Respondents.
Court of Appeals.
1. The scope of the issues preserved for consideration here, under an exception to the mootness doctrine, permits the review of whether the Emergency Management Act, Minn. Stat. §§ 12.01–.61 (2022), can, in the abstract, authorize a sitting governor to declare a peacetime emergency for a pandemic, whether Governor Walz was specifically authorized to declare a peacetime emergency in response to the COVID-19 pandemic, and whether the Act as a whole violates the nondelegation doctrine.
2. The Emergency Management Act authorizes the declaration of a peacetime emergency in response to a pandemic and did not require the Governor to make an evidentiary showing that the Act’s requirements were satisfied before declaring a peacetime emergency in response to the COVID-19 pandemic.
3. The Emergency Management Act does not provide for an unconstitutional delegation of legislative authority under the Minnesota Constitution.
Affirmed. Justice Gordon L. Moore, III.
Concurring, Justice G. Barry Anderson.
Took no part, Justice Karl C. Procaccini.
A22-1376 Judith Rygwall, as Trustee for the Heirs and Next of Kin of Amy Rygwall, deceased, Appellant, vs. ACR Homes, Inc.
d/b/a ACR Homes, Respondent.
Court of Appeals.
1. Minnesota Statutes section 145.682 (2022) did not modify the common-law standard for causation in medical malpractice cases to require plaintiffs to satisfy a more stringent burden of proof to establish causation than is required in other negligence cases.
2. A genuine issue of material fact over whether a health care provider caused injury to the decedent in a medical malpractice claim precluded summary judgment.
Reversed and remanded. Justice Paul C. Thissen.
Concurring in part, dissenting in part, Justice G. Barry Anderson, Chief Justice
Natalie E. Hudson.
A24-0216 Ken Martin, Petitioner, vs. Steve Simon, Minnesota Secretary of State, Respondent, The Legal Marijuana Now Party,
Intervenor-Respondent.
Supreme Court.
1. The court has subject matter jurisdiction over this petition under Minn. Stat. § 204B.44 (2022).
2. Because the Legal Marijuana Now Party (LMNP) did not maintain a state central committee subject to the state convention’s control, as Minn. Stat. § 202A.12, subd. 2 (2022), requires, and the LMNP’s constitutional challenge to Minn. Stat. § 202A.12, subd. 2, fails, the LMNP has not satisfied the requirements to be a major political party under Minn. Stat. § 200.02, subd. 7(a) (Supp. 2023).
Petition granted; motion to dismiss denied. Per Curiam.
Took no part, Justice Margaret H. Chutich, Justice Karl C. Procaccini.