Supreme Court Digest: March 9, 2022

Civil

Domestic Relations

Dissolution; Judgment

This case raised the following issues: (1) whether a party to a marriage dissolution-or child support-related case may seek relief from judgment based on newly discovered evidence under Minn. Stat. § 518.145, subd. 2(2) if the evidence came into existence after the underlying decision from which that party seeks relief, and (2) whether the Court of Appeals erred in ordering the District Court to consider the post-decision evidence submitted by the movant. These issues arose from marriage dissolution and child support proceedings between appellant and respondent. Years after their divorce, respondent moved the District Court to extend appellant’s child support payments for their special needs child beyond the child’s 21st birthday. After the District Court denied the motion and the Court of Appeals affirmed, respondent moved to modify the child support termination order based on “newly discovered evidence” under § 518.145, subd. 2(2) and Minn. R. Civ. P. 60.02. The District Court denied the motion, but the Court of Appeals reversed and remanded.

The Supreme Court held that (1) under § 518.145, subd. 2(2), a District Court in a marriage dissolution case or child support matter may grant such relief as may be just based on newly discovered evidence that comes into existence after the underlying decision from which a party seeks relief—in exercising its discretion whether to admit this newly discovered evidence, the District Court must consider whether the evidence could not have been discovered before trial or hearing by the exercise of due diligence, is relevant and admissible, and is not merely collateral, cumulative, or impeaching but is likely to affect the outcome of the proceeding; and (2) the Court of Appeals did not err in ordering the District Court to consider whether the movant’s newly discovered evidence warranted relief under § 518.145, subd. 2(2). Affirmed.

A20-1234 Bender v. Bernhard (Court of Appeals)

Taxation

Property Valuation

This case was on direct appeal from the tax court. The taxpayer challenged the denial of two motions to compel, a motion to amend the pleadings, and the tax court’s rejection of its unequal assessment claim. The tax court denied taxpayer’s motion to compel respondent county to produce information about other similar properties, denied taxpayer’s motion to amend its complaint to add unequal assessment and disparate treatment claims under Article X of the Minnesota Constitution and the Fourteenth Amendment to the United States Constitution, and denied a motion to compel the County Assessor to testify when taxpayer failed to subpoena that witness. On the merits, the tax court rejected taxpayer’s statutory claim that its property was unequally assessed, concluding that Chambers did not meet its burden to prove this claim.

The Supreme Court held that (1) because taxpayers may prove unequal assessment claims by using the Department of Revenue’s sales ratio studies, the tax court did not abuse its discretion when it determined that the detailed discovery the taxpayer sought on other properties was not proportional to the needs of this case; (2) because constitutional claims of unequal assessment and disparate treatment under the Minnesota and United States Constitutions employ the same or a more exacting test and provide the same remedies as a statutory unequal assessment claim, the tax court did not abuse its discretion when it denied the taxpayer’s motion to amend its pleadings to add constitutional claims; (3) the tax court did not abuse its discretion when it denied the taxpayer’s oral motion to require disclosure of nonpublic data or to compel the appearance of the county assessor at trial; and (4) the tax court did not err in determining that the taxpayer failed to meet its burden of proof to establish that its property was unequally assessed. Affirmed.

A21-0825 Chambers Self-Storage Oakdale, LLC v. County of Washington (Tax Court)

Criminal

Threats of Violence

Threats

This case involved a facial challenge to a part of the Minnesota threats of violence statute, Minn. Stat. § 609.713, subd. 1, under the First Amendment to the United States Constitution. The State charged defendant with four counts of threats of violence under section 609.713, subdivision 1. Defendant moved to dismiss, claiming that the part of section 609.713, subdivision 1 that applies to threats of violence made “in a reckless disregard of the risk of causing such terror” was unconstitutionally overbroad. The District Court denied her motion and found her guilty of all four counts in a stipulated-facts court trial. The Court of Appeals affirmed.

The Supreme Court held that (1) a threat of violence is made “in a reckless disregard of the risk of causing such terror,” in violation of the Minnesota threats of violence statute when the defendant makes the violent threat while consciously disregarding a substantial and unjustifiable risk that the defendant’s words or actions will cause terror; (2) true threats, a category of speech unprotected by the First Amendment, do not require specific intent to threaten a victim and can encompass violent communications that are made recklessly; Minnesota’s threats of violence statute punishes only true threats; and (3) Minnesota’s threats of violence statute is not substantially overbroad under the First Amendment. Affirmed.

A20-0231 State v. Mrozinski (Court of Appeals)