Minnesota Case Commentaries

No Duty to Plead Around Affirmative Defenses: Minnesota Adopts “Unrebuttable Defense” Standard for Rule 12 Dismissals and Vacates Early Fee Awards

Date: Sep 11, 2025

No Duty to Plead Around Affirmative Defenses: Minnesota Adopts “Unrebuttable Defense” Standard for Rule 12 Dismissals and Vacates Early Fee Awards Introduction In Doug Hoskin v. Josh Krsnak, the...

Bright-Line Ban on Extra-Record Fact-Finding in Postconviction Proceedings: Structural Error Under the Minnesota Constitution (State v. Duol)

Date: Sep 4, 2025

Bright-Line Ban on Extra-Record Fact-Finding in Postconviction Proceedings: Structural Error Under the Minnesota Constitution Introduction In State of Minnesota v. Buay David Duol (Minn. Sept. 3,...

DuPont v. Commissioner: Minnesota Endorses Net-Income Apportionment for Hedging Receipts and Allows Denominator-Only Distortion Showing Under § 290.20

Date: Aug 28, 2025

DuPont v. Commissioner: Minnesota Endorses Net-Income Apportionment for Hedging Receipts and Allows Denominator-Only Distortion Showing Under § 290.20 Introduction In E. I. duPont de Nemours and...

State v. Lerma: Defendant-Requested Mistrial Precludes a Double Jeopardy Bar Absent Intentional Government Provocation; Judges Count as “Government” and No Implied Withdrawal

Date: Aug 28, 2025

Consent Controls: Minnesota Supreme Court Clarifies Double Jeopardy After Defendant-Requested Mistrials Introduction In State of Minnesota v. Johnnie Lerma, the Minnesota Supreme Court addressed when...

No Due Process Bar from Post-Discharge Statutory Change; Mens Rea Under Minn. Stat. § 624.713, subd. 1(2) Requires Knowledge of Prior Conviction, Not Knowledge of Status

Date: Aug 28, 2025

No Due Process Bar from Post-Discharge Statutory Change; Mens Rea Under Minn. Stat. § 624.713, subd. 1(2) Requires Knowledge of Prior Conviction, Not Knowledge of Status Introduction In Joel Armen...

Judicial Factfinding Permitted for § 609.035 Arson–Concealment Exception; Clarified Standards for “Significant Relationship” and “Past Pattern” in Minnesota First-Degree Domestic‑Abuse Murder

Date: Aug 21, 2025

Judicial Factfinding Permitted for § 609.035 Arson–Concealment Exception; Clarified Standards for “Significant Relationship” and “Past Pattern” in Minnesota First-Degree Domestic‑Abuse Murder...

Tribal Courts Recognized as “Jurisdictions” for Reciprocal Discipline; Minnesota Clarifies the RLPR 12(d) Analysis and Rejects Comity Weighting — In re Martins

Date: Aug 14, 2025

Tribal Courts Recognized as “Jurisdictions” for Reciprocal Discipline; Minnesota Clarifies the RLPR 12(d) Analysis and Rejects Comity Weighting Introduction In In re Petition for Disciplinary Action...

Preverdict Interest Under Minn. Stat. § 549.09: Settlement Offers Do Not Excuse the Two‑Year Commencement Rule; Interest Runs on the Net Judgment Excluding Collateral Sources

Date: Aug 14, 2025

Preverdict Interest Under Minn. Stat. § 549.09: Settlement Offers Do Not Excuse the Two‑Year Commencement Rule; Interest Runs on the Net Judgment Excluding Collateral Sources Introduction In Lee...

No Group Frisk Without Particularized Suspicion: Minnesota Supreme Court Clarifies Terry Limits in In re Welfare of C.T.B. (2025)

Date: Aug 14, 2025

No Group Frisk Without Particularized Suspicion: Minnesota Supreme Court Clarifies Terry Limits in In re Welfare of C.T.B. (2025) Introduction In In the Matter of the Welfare of: C.T.B., 24 N.W.3d...

Direct Employee Recovery of Health-Insurer-Paid Medical Expenses and Extinguishment of Non‑Intervening Insurers’ Interests under Minnesota’s Workers’ Compensation Act

Date: Aug 7, 2025

Direct Employee Recovery of Health-Insurer-Paid Medical Expenses and Extinguishment of Non‑Intervening Insurers’ Interests under Minnesota’s Workers’ Compensation Act Introduction In Paula Kay...

No State Serial-Number Crime for Ghost Guns Absent a Federal Mandate: Minnesota Supreme Court Limits Minn. Stat. § 609.667(3) to Firearms Requiring Serial Numbers Under Federal Law

Date: Aug 7, 2025

No State Serial-Number Crime for Ghost Guns Absent a Federal Mandate: Minnesota Supreme Court Limits Minn. Stat. § 609.667(3) to Firearms Requiring Serial Numbers Under Federal Law Introduction In...

State v. Nyonteh: Sleeping Jurors Are Not Juror Misconduct; Abuse-of-Discretion Standard Governs Removal

Date: Jul 31, 2025

State v. Nyonteh: Sleeping Jurors Are Not Juror Misconduct; Abuse-of-Discretion Standard Governs Removal Introduction In State of Minnesota v. James Nyonteh, 24 N.W.3d 271 (Minn. 2025), the Minnesota...

Speak Now or Forfeit: Minnesota Supreme Court Reaffirms Strict Preservation for Restitution Challenges and Narrows Use of the “Legal Authority” Exception

Date: Jul 31, 2025

Speak Now or Forfeit: Minnesota Supreme Court Reaffirms Strict Preservation for Restitution Challenges and Narrows Use of the “Legal Authority” Exception Introduction In State of Minnesota v. Erick...

Setting the Standard: Abuse-of-Discretion Review for Preliminary Denials Under Minnesota’s 2023 Aiding-and-Abetting Felony-Murder Relief Act

Date: Jul 31, 2025

Setting the Standard: Abuse-of-Discretion Review for Preliminary Denials Under Minnesota’s 2023 Aiding-and-Abetting Felony-Murder Relief Act Case: State of Minnesota v. Diamond Lee Jamal Griffin...

Minnesota Supreme Court: § 65A.10 Requires Coverage for Code‑Mandated Sheathing to Replace Damaged Shingles; Overhead and Profit Not Automatic

Date: Jul 31, 2025

Minnesota Supreme Court: § 65A.10 Requires Coverage for Code‑Mandated Sheathing to Replace Damaged Shingles; Overhead and Profit Not Automatic Introduction In Great Northwest Insurance Company v....

Starting the Clock: Minnesota Supreme Court Clarifies Accrual and Strict Enforcement of the Two‑Year Postconviction Time Bar for “New Interpretation” and “Newly Discovered Evidence” Claims

Date: Jul 31, 2025

Starting the Clock: Minnesota Supreme Court Clarifies Accrual and Strict Enforcement of the Two‑Year Postconviction Time Bar for “New Interpretation” and “Newly Discovered Evidence” Claims...

Minnesota Supreme Court Adopts Yee Framework and Upholds Minneapolis’s Voucher-Acceptance Ordinance: No Taking Under Minnesota Constitution; MHRA Does Not Preempt Local Anti-Discrimination Measures

Date: Jul 31, 2025

Minnesota Supreme Court Adopts Yee Framework and Upholds Minneapolis’s Voucher-Acceptance Ordinance: No Taking Under Minnesota Constitution; MHRA Does Not Preempt Local Anti-Discrimination Measures...

A Uniform Corpus Delicti Standard for Attempt and Completed Crimes: Independent Evidence That “Reasonably Tends to Prove” the Offense Suffices (State v. Hill)

Date: Jul 24, 2025

A Uniform Corpus Delicti Standard for Attempt and Completed Crimes: Independent Evidence That “Reasonably Tends to Prove” the Offense Suffices (State v. Hill) Case: State of Minnesota v. Nicholas Lee...

Inherent-Authority Safety Valve for Late Appeals Caused by Missing Rule 77.04 Notice; Minnesota General Rule of Practice 14.01(c)(2) Does Not Extend to Appellate Courts

Date: Jul 24, 2025

Inherent-Authority Safety Valve for Late Appeals Caused by Missing Rule 77.04 Notice; Minnesota General Rule of Practice 14.01(c)(2) Does Not Extend to Appellate Courts Case and Citation Wells Fargo...

Minnesota Supreme Court Establishes Priority of Performing Construction Surety’s Equitable Subrogation Over Earlier Perfected UCC Security Interests; No Mistake-of-Fact Requirement

Date: Jul 17, 2025

Performing Construction Surety’s Equitable Subrogation Trumps Earlier Perfected UCC Security Interests — No Mistake-of-Fact Requirement Introduction In a significant decision for public construction...

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