Latest 5 Cases: Griffin v. State (Civil Rights), State v. Alger (Criminal Law), State v. Dexter (Criminal Law)

When Children Stay Home—A COVID-19 Consequence

KATHRYN ROBB

Kathryn Robb, executive director of CHILD USAdvocacy, describes how the COVID-19 pandemic uniquely endangers children who are being sexually abused by people close to them. Robb describes ways in which teachers, coaches, and other adult figures in children’s lives must do to ensure the safety of children in this time when schools and other safe spaces are shut down.

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Griffin v. State

Dockets: A18-1002, A19-1083

Opinion Date: April 8, 2020

Judge: Hudson

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

The Supreme Court affirmed the decisions of the district court denying Appellant's ineffective assistance of trial counsel claim raised in his first petition for post conviction relief and the claims raised in his second petition for postconviction relief, holding that the district court did not abuse its discretion by denying Appellant's claims. After a jury trial, Appellant was found guilty of first-degree felony murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed. In his first petition for postconviction relief, Appellant raised some of the same issues addressed in his direct appeal but also claimed that he received ineffective assistance of trial counsel. The district court ordered an evidentiary hearing only on the ineffective assistance of counsel claim and, after a hearing, denied the claim. Appellant then filed a second petition for postconviction relief, which the district court summarily denied. The Supreme Court affirmed both of the district court's orders, holding (1) Appellant did not satisfy the first prong of Strickland on his ineffective assistance of counsel claim; and (2) all of Appellant's claims in his second petition were time barred.

State v. Alger

Docket: A18-1000

Opinion Date: April 8, 2020

Judge: Lorie Skjerven Gildea

Areas of Law: Criminal Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's sentences in connection with his conviction for two counts of violating an order of protection (OFP) under Minn. Stat. 518B.01, subd. 14(d)(1), holding that the multiple-victim rule authorized two sentences in this case and that Defendant's consecutive sentences did not unfairly exaggerate the criminality of his behavior. A temporary OFP prohibited Defendant from contacting either his infant son or his son's mother. After Defendant had contact with both his son and the mother at a hotel, the State charged Defendant with two counts of violating an OFP. Defendant pleaded guilty to both counts, and the district court sentenced him to two permissive consecutive sentences. The court of appeals affirmed the sentences, concluding that Minn. Stat. 609.035, subd. 1 did not prohibit the district court from imposing multiple sentences for crimes that were committed during a single behavioral incident. The Supreme Court affirmed, holding (1) the multiple-victim rule applied in this case because Defendant made in-person contact with two protected persons, and therefore, there were two victims of the OFP-violation crime; and (2) Defendant's sentences did not exaggerate the criminality of his behavior.

State v. Dexter

Docket: A18-0761

Opinion Date: April 8, 2020

Judge: Chutich

Areas of Law: Criminal Law

The Supreme Court affirmed the decision of the court of appeals reversing the district court's denial of Defendant's request for non-identifying information about a confidential reliable informant's relationship with police and the informant's information-gathering activities, holding that the State's common law privilege to withhold the identity of an informant does not protect non-identifying information. Defendant was charged with drug possession and sale crimes. Defendant filed discovery and suppression motions seeking information about a confidential reliable informant, on whose observations the State relied to obtain a warrant to search Defendant's home. The district court denied the motions, concluding that Defendant was not entitled to discover the informant's identity or any other information about the informant. Defendant was convicted of fifth-degree sale of a controlled substance. The court of appeals reversed, holding that the State's common law privilege did not protect non-identifying information. The Supreme Court affirmed, holding that the court of appeals (1) properly concluded that the State's common law privilege does not apply to non-identifying information; and (2) did not err in concluding that the non-identifying information Defendant requested related to the case, as required by Minn. R. Crim. P. 9.01.

Cilek v. Office of Minnesota Secretary of State

Docket: A18-1140

Opinion Date: April 8, 2020

Judge: David L. Lillehaug

Areas of Law: Election Law

In this case involving a Minnesota voter's request for access to information in Minnesota's statewide voter registration list the Supreme Court held that registered Minnesota voters have access to "public information lists" as defined by law, as well as to information provided by the secretary of state, but the Legislature has restricted access to the other information sought. A statewide voter registration list is contained in the Statewide Voter Registration System (SVRS). The Secretary of State is responsible for administering the SVRS, and the Legislature has allowed some of the information in the SVRS to be made available for inspection in the form of a "public information list." Plaintiff sought access to non-private government data"from the SVRS. The Secretary informed Plaintiff that he was entitled to information in the SVRS related to currently registered Minnesota voters but declined to produce SVRS information on voter status and other issues. The district court ordered the Secretary to produce the requested data. The court of appeals affirmed. The Supreme Court reversed, holding that the relevant provisions of the Minnesota Government Data Practices Act and the Minnesota Election Law provides that access to the voter registration list contained in the SVRS is limited to "public information lists" and to information provided by the Secretary.

Marquardt v. Schaffhausen

Docket: A18-0968

Opinion Date: April 8, 2020

Judge: Lorie Skjerven Gildea

Areas of Law: Medical Malpractice

In this medical malpractice case, the Supreme Court reversed the decision of the court of appeals concluding that the district court abused its discretion by admitting testimony about causation from Dr. John Stark, an orthopedic surgeon, and Dr. Kevin Stephan, an infection-disease specialist, holding that the district court did not abuse its discretion in admitting the doctors' causation testimony. This action arose from right-knee arthroplasty Dr. James Schaffhausen performed on Plaintiff. In her complaint, Plaintiff argued that, as a result of the surgery, she suffered permanent neurologic damage. The jury found for Plaintiff. Dr. Schaffhausen moved for judgment as a matter of law or a new trial, arguing that it was error for Dr. Stark and Dr. Stephan to testify as to causation because they were not neurologists. The district court denied the motions. The court of appeals reversed, concluding that the experts were not qualified to testify as to causation because they lacked the requisite occupational experience in neurology. The Supreme Court reversed, holding that where the district court carefully weighed the qualifications of Dr. Stark and Dr. Stephan before deciding to admit their testimony, the court did not abuse its discretion in admitting their testimony on the issue of causation.