Supreme Court Digest: Sept. 13, 2023

Civil

Civil Rights

Statute of Limitations

The question presented in this appeal was whether the continuing violation doctrine applied to toll the statute of limitations for a First Amendment retaliation claim under 42 U.S.C. § 1983. The District Court ruled that the claim was time-barred. The Court of Appeals reversed and reinstated the claim, concluding that the alleged retaliatory acts constituted a continuing violation that tolled the statute of limitations.

The Supreme Court held that the continuing violation doctrine does not apply to a First Amendment retaliation claim where, as here, the plaintiff has alleged discrete acts of retaliation under 42 U.S.C. § 1983. Reversed and remanded.

A22-0374 Ringsred v. City of Duluth (Court of Appeals)

Criminal

Filing False Reports

Venue

This case arose from defendant’s false report to police that the father of her child had abused their child. Based on this report, a Waseca County jury found defendant guilty of falsely reporting a crime to a police officer in violation of Minn. Stat. § 609.505. Because she was in Blue Earth County when she made the report, defendant alleged on appeal that venue was improper in Waseca County. In the alternative, defendant argued that the evidence was not sufficient to support her conviction. The Court of Appeals affirmed.

The Supreme Court held that (1) because the “informs” element of the offense of falsely reporting a crime is satisfied when a law enforcement officer receives the false report of a crime, venue for the crime of filing a false report is proper in the place where the officer receives the false report; (2) because the circumstantial evidence proved beyond a reasonable doubt that the law enforcement officer received the false report of a crime in Waseca County, the evidence was sufficient to sustain defendant’s conviction. Affirmed.

A21-1360 State v. Johnson (Court of Appeals)

Traffic Stops

Expansion of Scope

The State charged defendant with possession of methamphetamine paraphernalia in the presence of a minor and fifth-degree possession of a controlled substance after a traffic stop and subsequent search of defendant’s vehicle. This search was justified only by the odor of marijuana emanating from the vehicle. Defendant moved to suppress the evidence found during the search, arguing that the odor of marijuana, alone, was insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement. The District Court granted defendant’s motion, suppressed the evidence, and dismissed the complaint. The State appealed. The Court of Appeals affirmed the District Court’s suppression order.

The Supreme Court held that (1) the odor of marijuana is one of the circumstances in the totality of circumstances analysis that should be considered in determining if there is a “fair probability” that contraband or evidence of a crime will be found in the location searched; and (2) because it was undisputed that there were no other circumstances supporting the probable cause determination in this case other than the odor of marijuana emanating from the vehicle, there was not a fair probability that the search would lead to the discovery contraband or evidence of a crime, and therefore the evidence obtained during the search must be suppressed. Affirmed.

A22-0425 State v. Torgerson (Court of Appeals)