EN BANC CALENDAR
Before the Minnesota Supreme Court
February 2024
SUMMARY OF ISSUES
Summaries prepared by the Supreme Court Commissioner’s Office
Monday, February 5, 2024
Supreme Court Courtroom, State Capitol Building, Second Floor
Janine Tea, Respondent, vs. Ramsey County, Self-Insured, Relator – Case No. A23-1207: Respondent Janine Tea had been employed as an adult mental health case manager at Ramsey County when, in February 2020, one of her clients murdered his girlfriend. Tea learned of the murder the following day over the telephone and, as part of her work duties, had to then spend considerable time over the next several days in conversations and meetings describing the details of the murder. Tea also began following news stories and collecting information about the murder on the internet, which was outside the scope of her work duties. She began experiencing trouble sleeping and nightmares and filled out a report claiming work-related secondary trauma related to the violent act committed by her client. Some doctors were of the opinion that Tea had work-related post-traumatic stress disorder (PTSD) based on the criteria in the fifth edition of the Diagnostic and Statistical Manual of Mental Disorders (DSM-5). Another doctor opined that Tea did not meet the diagnostic criteria for PTSD under the DSM-5, which Ramsey County used as the basis for discontinuing workers’ compensation benefits to Tea.
The compensation judge, after reviewing the evidence—including the opinions of the expert doctors—found that Tea did sustain a work-related PTSD injury and ordered workers’ compensation benefits. As relevant here, the Workers’ Compensation Court of Appeals (WCCA), citing Smith v. Carver County, 931 N.W.2d 390 (Minn. 2019), affirmed the compensation judge’s finding that the employee sustained work-related PTSD. Two separate concurrences were also filed.
On appeal to the supreme court, relator’s brief presents the following issues: (1) whether the factual finding of a work-related PTSD condition, made by the compensation judge and affirmed by the WCCA, was “manifestly contrary to the evidence,” requiring reversal; and (2) whether the WCCA committed an error of law by entirely refusing to consider any argument that the facts of the case do not conform to the DSM definition of PTSD, when the legislature explicitly required that any such claim be based upon the DSM definition of PTSD. (Workers’ Compensation Court of Appeals)
State of Minnesota, Respondent, vs. Jamal L. Smith, Appellant – Case No. A23-0007: A grand jury indicted appellant Jamal L. Smith with first-degree murder while committing a drive-by shooting. Before trial, Smith filed a motion challenging the pool of potential grand jurors and requesting an expansion of the pool of potential petit jurors. The district court denied the motion. At trial, the State presented evidence related to the shooting, as well as acts committed by Smith before and after the shooting. The jury found Smith guilty of first-degree murder while committing a drive-by shooting.
On appeal to the supreme court, Smith raises the following issues: (1) whether the district court erred by granting the State’s motion to introduce evidence of multiple bad acts as immediate episode/res gestae evidence where the incidents happened at different locations, hours, days and months apart, and involved different victims, (2) whether the State proved that Smith shot the victim or intentionally aided others in shooting the victim, and (3) whether Smith was denied his constitutional right to grand jury and petit jury pools composed of a fair cross section of county residents. (Hennepin County)
Tuesday, February 6, 2024
Supreme Court Courtroom, State Capitol Building, Second Floor
State of Minnesota, Respondent, vs. Angel Ignacio Sardina-Padilla, Appellant – Case Nos. A21-1642, A23-0628: A grand jury indicted appellant Angel Ignacio Sardina-Padilla with first-degree premeditated murder. Before trial, Sardina-Padilla filed a motion to suppress Facebook evidence that was obtained pursuant to a search warrant. The district court denied the motion to suppress. Following a jury trial, Sardina-Padilla was convicted of first-degree premeditated murder. Sardina-Padilla filed a direct appeal, which was stayed to allow him to pursue postconviction relief. In his postconviction petition, Sardina-Padilla alleged that his attorneys were ineffective when they failed to file a motion to suppress location evidence obtained pursuant to a tracking warrant. The district court denied the petition. Sardina-Padilla filed a motion to consolidate his appeals, which was granted.
On appeal to the supreme court, Sardina-Padilla raises the following issues: (1) whether the evidence obtained from Facebook must be suppressed because the warrant application did not establish a sufficient nexus between the alleged crimes against the victim, and Sardina-Padilla’s Facebook accounts and any of their content and because the warrant, which authorized the seizure of “all content” associated with the Facebook accounts, failed to describe the content to be seized with sufficient particularity, and (2) whether Sardina-Padilla received ineffective assistance of counsel because his trial attorneys failed to file and argue a meritorious motion to suppress the location information obtained from Facebook as the result of the tracking warrant. (Washington County)
Wednesday, February 7, 2024
Supreme Court Courtroom, State Capitol Building, Second Floor
Kay “KT” Jacobs, Appellant, vs. City of Columbia Heights, et al., Respondents – Case No. A23-1780: Appellant Kay “KT” Jacobs is a member of the Columbia Heights City Council. A committee of five city electors presented respondent Sara Ion, the Columbia Heights City Clerk, with a petition stating they intended to seek Jacob’s recall. The committee later submitted a petition signed by enough voters to trigger a recall election under the City’s charter. The City Council considered the recall petition issue at its July 24, 2023 meeting. The City Council passed a resolution to hold a special recall election regarding Jacobs on February 13, 2024.
Jacobs filed a petition under Minnesota Statutes section 204B.44(a) (2022) in district court, contending that the recall election was unlawful. The petition claimed the recall petition did not comply with the procedural requirements in Minnesota Rule 8205.1010 (2023). It also contended that the recall petition did not allege that Jacobs had engaged in malfeasance or nonfeasance, the constitutional grounds to recall an elected municipal official. The petition asked the district court, in part, to cancel the special election. The district court denied the petition.
The supreme court granted accelerated review of the following issues: (1) whether Minnesota Rule 8205.1010, which “applies to any petition required for any election in this state, including nominating petitions, recall petitions, and proposed recall petitions,” applies to the municipal recall petition at bar, and (2) whether “taking no position” on the merits of a recall petition satisfied the requirement under Minnesota Statutes section 204B.44 that the City “show cause” for not correcting a ballot error or wrongful act. (Anoka County)
State of Minnesota, Respondent, vs. Michael Joseph Letourneau, Appellant – Case No. A22-0570: Appellant Michael Letourneau was charged with two counts of first-degree criminal sexual conduct. When the State filed its criminal complaint, Letourneau was detained at a Minnesota prison. Letourneau’s request for final disposition of the charges within 180 days pursuant to the Uniform Mandatory Disposition of Detainers Act (UMDDA), Minn. Stat. § 629.292 (2022), was filed on March 8, 2021. On April 6, 2021, the prosecutor filed correspondence acknowledging receipt of the UMDDA request.
Letourneau was represented by the public defenders office. His original counsel was replaced. When Letourneau’s new public defender first appeared on August 16, 2021, he raised Letourneau’s UMDDA request as a concern for the district court. The court noted two possible dates for expiration of the UMDDA deadline and then found good cause to extend the 180-day deadline beyond both dates.
On October 11, 2021, Letourneau moved to dismiss on the basis that the UMDDA deadline had run. The next day, the district court denied Letourneau’s motion, explaining it had made the good cause finding necessary to extend the deadline in open court on August 16, 2021. A jury trial began that same day. The jury found Letourneau guilty of both counts. The court of appeals affirmed in a nonprecedential opinion.
The supreme court granted review on the following issue: whether the district court plainly erred in finding good cause had been shown to permit Letourneau to be brought to trial outside the time permitted under UMDDA, when the court erroneously determined the date by which trial had to begin, the State had not established good cause for trial to begin beyond the correct date, let alone the district court’s erroneously determined later date, and Letourneau would have remained in custody during the time preceding the trial’s start date. (Ramsey County)
Thursday, February 8, 2024
Supreme Court Courtroom, State Capitol Building, Second Floor
Drake Snell, et. al., Appellants, vs. Tim Walz, Governor of Minnesota, in his official capacity, et al., Respondents – No. A21-0626:On March 13, 2020, acting pursuant to the Minnesota Emergency Management Act of 1996, Minn. Stat. §§ 12.01–.61 (2022), respondent Governor Walz issued Emergency Executive Order 20-01, declaring a peacetime emergency in Minnesota relating to COVID-19. The Governor extended the peacetime emergency multiple times. On July 22, 2020, the Governor issued Emergency Executive Order 20-81 (the “mask mandate”), which required most Minnesotans to wear face coverings in certain places. In August of 2020, appellants—a group of Minnesota residents, businesses, and churches—filed a petition for a writ of quo warranto in the district court against the Governor and others, challenging the mask mandate as unlawful for various reasons, and seeking to enjoin its enforcement. Respondents moved to dismiss the petition for failure to state a claim upon which relief could be granted. In March 2021, the district court granted the motion and dismissed appellants’ claims on the merits.
On May 13, 2021, appellants appealed the district court’s decision dismissing their claims. On May 14, 2021, the Governor issued an executive order lifting the mask mandate “in most settings.” And on June 30, 2021, the Governor signed a bill that the Legislature had passed earlier that same day, terminating the peacetime emergency as of July 1, 2021. The court of appeals dismissed appellants’ appeal, concluding that the lifting of the mask mandate and the subsequent end of the peacetime emergency had rendered the appeal moot, and that no exception to mootness applies.
The supreme court affirmed in part and reversed in part, concluding that although the appeal was technically moot, it nevertheless presented a functionally justiciable issue of statewide importance that should be decided immediately under an exception to the mootness doctrine—namely, whether the Emergency Management Act allows the Governor to declare a peacetime emergency in response to a public health crisis. On remand from the supreme court, the court of appeals answered that question in the affirmative.
The supreme court granted review on the following issue: whether the Minnesota Emergency Management Act of 1996 authorizes the Governor to declare a peacetime emergency based on a public-health emergency such as the COVID-19 pandemic. (Ramsey County)
Keegan James Rich Brouillette, Appellant, vs. State of Minnesota, Respondent – Case No. A23-0020: After a jury trial, appellant Keegan Brouillette was convicted of two counts of felony domestic assault. On June 24, 2019, the district court sentenced Brouillette to 15 months in prison, stayed execution of the sentence, and placed Brouillette on probation for 5 years. That same day, the district court filed an order/warrant of commitment, which served as the judgment of conviction. Brouillette did not file a direct appeal.
Brouillette later admitted to violating his probation conditions. On August 26, 2021, the district court revoked Brouillette’s probation and executed his 15-month sentence. That same day, the district court filed an amended order regarding Brouillette’s sentence.
On July 19, 2022, Brouillette filed a petition for postconviction relief, asking the district court to vacate his convictions and grant a new trial. He argued that unobjected-to prosecutorial misconduct deprived him of a fair trial. Brouillette claimed the petition was timely, in part, because it was filed within 2 years of his August 26, 2021 sentencing hearing. In response, the State argued that the petition was time-barred. In the alternative, it argued that the petition should be summarily denied because, even if there was prejudicial plain error, failure to correct the error would not seriously affect the fairness, integrity, or public reputation of judicial proceedings.
The district court summarily denied the petition. It concluded that the petition was time-barred because it was not filed within 2 years of the entry of judgment of conviction or sentence, both of which occurred on June 24, 2019. It also concluded that petitioner’s prosecutorial misconduct claim failed on the merits. The court of appeals affirmed.
The supreme court granted review on the following issue: whether Brouillette’s postconviction petition challenging his conviction was timely when it was filed within 2 years of the amended order resentencing him from a probation term to a prison sentence. (Scott County)