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The Supreme Court Chamber in the Minnesota Capitol in St. Paul. (Staff photo: Kevin Featherly)

Supreme Court Digest: Dec. 14, 2022

Civil

 

Civil Rights

Qualified Immunity

Respondent-inmate brought an action under 42 U.S.C. § 1983 against Minnesota Department of Corrections officers, alleging they subjected him to cruel and unusual punishment when they improperly applied handcuffs in a manner that caused him injury and refused to loosen the handcuffs when he complained that the handcuffs were too tight and causing numbness. Respondent remained in the overtightened handcuffs for 3½ hours, including while under general anesthesia for an endoscopy. Respondent suffered serious injury in both wrists that required surgery and left him with permanent nerve damage that continues to cause pain and decreased function.

The Supreme Court held that (1) when no specific, immediate threat to order or institutional security exists, the deliberate indifference standard applies to Eighth Amendment claims seeking relief under 42 U.S.C. § 1983 for injuries resulting from corrections officers overly tightening and unsafely applying mechanical restraints while transporting an inmate to a medical procedure, while the inmate is waiting in a medical holding cell, and while the inmate is undergoing a medical procedure; and (2) the inmate’s claim under 42 U.S.C. § 1983 cannot be dismissed on summary judgment based on the corrections officers’ qualified immunity defense because a reasonable factfinder could conclude that the facts alleged showed an objective and substantial risk of harm that the corrections officers subjectively recognized and nevertheless disregarded, and because the constitutional obligation to prevent the substantial risk of harm posed by the improper use of restraints in non-emergency situations was clearly established on the date the restraints were used. Affirmed.

A20-1481 Welters v. Minn. Dep’t of Corrections (Court of Appeals)

 

Criminal

 

Postconviction Relief

Newly Discovered Evidence

Following trial, a jury found petitioner guilty of the first-degree premeditated murder. At issue here was the question of whether the postconviction court erred in denying petitioner’s third and fourth petitions for postconviction relief without holding an evidentiary hearing. Petitioner claimed that the District Court abused its discretion in refusing to hold an evidentiary hearing to consider three pieces of evidence: (1) shell casings recovered from the site of the murder; (2) an affidavit claiming that the affiant saw someone put a rifle in petitioner’s barn; and (3) an affidavit from a second affiant that he observed the victim’s wife and son driving around at a time when they claimed to have heard gunshots. Petitioner also argued that the Court should use its supervisory powers to grant a new trial in the interests of justice. The postconviction court summarily denied petitioner’s petition, concluding that none of the three pieces of “newly discovered” evidence satisfied the factors articulated in Minn. Stat. § 590.01, subd. 4(b)(2), nor did the evidence fall under the “interests of justice” exception in in Minn. Stat. § 590.01, subd. 4(b)(5). The court also denied petitioner’s request for a new trial.

The Supreme Court held that (1) petitioner’s claims did not qualify under the newly discovered evidence exception to the statute of limitations in the postconviction statute, Minn. Stat. § 590.01, subd. 4; (2) the District Court did not err in refusing to consider petitioner’s time-barred claims in the interests of justice; and (3) the District Court did not err in denying petitioner’s request for a new trial. Affirmed.

A20-1602, A22-0057 Andersen v. State (Becker County)

 

Orders

 

Attorney Discipline

Disability Inactive Status

Gary A. Gittus was transferred to disability inactive status.

A22-1005 In re Gittus

 

Attorney Discipline

Reinstatement

Patrick Chinedu Nwaneri was conditionally reinstated to the practice of and placed on probation for two years.

A21-0547 In re Nwaneri


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