Minnesota rule in Minnesota

2016Because Bernard held that a warrantless breath test would have been constitutional under the search-incident-to-arrest exception, 859 N.W.2d at 767 , Minnesota’s test-refusal statute does not authorize an unconstitutional search and the unconstitutional-conditions doctrine does not apply.

2016In Bernard, the supreme court analyzed whether Minnesota’s test-refusal statute violates due-process rights by “criminalizing [the] refusal to consent to an unconstitutional search.” 859 N.W.2d at 764 .

2015Minnesota appellate courts have consistently recognized that, unlike the more deferential federal rational-basis test, the Minnesota test does not allow courts to “hypothesize a rational basis to justify a classification.” Russell, 477 N.W.2d at 889 ; see Greene v. Comm’r of Minn. Dep’t of Human Servs., 755 N.W.2d 713, 729 (Minn. 2008).

2015Minnesota appellate courts have consistently recognized that, unlike the more deferential federal rational-basis test, the Minnesota test does not allow courts to “hypothesize a rational basis to justify a classification.” Russell, 477 N.W.2d at 889 ; see Greene v. Comm’r of Minn. Dep’t of Human Servs., 755 N.W.2d 713, 729 (Minn. 2008).

2016To the extent that appellant argues that the test-refusal statute violates the unconstitutional-conditions doctrine, we recently held that “Minnesota’s test-refusal statute does not violate the unconstitutional-conditions doctrine by imposing a criminal penalty on a person who has been arrested for driving while impaired and has refused to submit to a breath test.” State v. Bennett, 867 N.W.2d 539, 540 (Minn. App. 2015), review denied (Minn. Oct. 28, 2015), cert. denied, No. 15-848 (U.S. June 28, 2016); see also Stevens v. Comm’r of Pub.

2016“Minnesota’s test-refusal statute does not violate the unconstitutional- conditions doctrine by imposing a criminal penalty on a person who has been arrested for driving while impaired and has refused to submit to a breath test.” State v. Bennett, 867 N.W.2d 539, 540 (Minn. App. 2015), review denied (Minn. Oct. 28, 2015).

2013“The key distinction between the federal and Minnesota tests is that under the Minnesota test ‘we have been unwilling to hypothesize a rational basis to justify a classification, as the more deferential federal standard requires.’” State v. Garcia, 683 N.W.2d 294, 299 (Minn. 2004) (quoting Russell, 477 N.W.2d at 889 ).

2013“The key distinction between the federal and Minnesota tests is that under the Minnesota test ‘we have been unwilling to hypothesize a rational basis to justify a classification, as the more deferential federal standard requires.’” State v. Garcia, 683 N.W.2d 294, 299 (Minn. 2004) (quoting Russell, 477 N.W.2d at 889 ).

2016In Birchfield , the Court considered the search-incident-to-arrest exception in analyzing the constitutionality of the application of North Dakota’s and Minnesota’s test refusal statutes to warrantless breath and blood tests. 2 Id. at -, 136 S.Ct., at 2170-75 .

2016In Birchfield , the Court considered the search-incident-to-arrest exception in analyzing the constitutionality of the application of North Dakota’s and Minnesota’s test refusal statutes to warrantless breath and blood tests. 2 Id. at -, 136 S.Ct., at 2170-75 .

2017We will therefore uphold a provision in a fire insurance policy “only if it affords the insured all the rights and benefits of the Minnesota standard fire insurance policy or offers additional benefits which provide more coverage to the insured than the statutory minimum.” Id. at 691 (citing Krueger v. State Farm Fire & Gas.

2017We will therefore uphold a provision in a fire insurance policy “only if it affords the insured all the rights and benefits of the Minnesota standard fire insurance policy or offers additional benefits which provide more coverage to the insured than the statutory minimum.” Id. at 691 (citing Krueger v. State Farm Fire & Gas.

2016Minnesota’s test-refusal statute provides that a person may refuse to submit to testing, and in such a case, “a test must not be given.” Minn. Stat. § 169A.52, subd. 1 (2014); see also Brooks, 838 N.W.2d at 571 (“If a driver refuses the test, the police are required to honor that refusal and not perform the test.”).

2016But because drivers have a right to refuse a breath test, the ICA “makes clear that drivers have a choice whether to submit to testing.” State v. Brooks, 838 N.W.2d 563, 570 (Minn. 2013).

2012Similarly, in In re Hansen we declined to waive the requirement of graduation from an ABA-accredited law school to allow Bryan Hansen to sit for the Minnesota bar examination. 275 N.W.2d 790, 798-99 (Minn.1978).

1989I agree with the dissents of Justices Yetka and Otis in In re Hansen, 275 N.W.2d 790, 799-800 (Minn.1978), and of Justices Yetka, Simonett and Otis in In re Busch, 313 N.W.2d 419, 422 (Minn.1981), holding that the facts in each of those cases would have justified the waiver of the Minnesota requirement that an applicant for admission in Minnesota must graduate from an ABA-accredited law school.

2024And the supreme court chose the “most-significant-relationship” test in Castillo-Alvarez because, consistent with prior caselaw considering the admissibility of evidence in criminal trials, the Minnesota rule has “both a procedural and substantive purpose.” Id. at 539 ; see also State v. Heaney, 689 N.W.2d 168, 170 (Minn. 2004) (“A conflict of laws concerning the admissibility of evidence protected by the physician-patient relationship is resolved by applying the two- prong test set forth in Restatement (Second) of Conflict of Laws § 139 (1971).”).

2024And the supreme court chose the “most-significant-relationship” test in Castillo-Alvarez because, consistent with prior caselaw considering the admissibility of evidence in criminal trials, the Minnesota rule has “both a procedural and substantive purpose.” Id. at 539 ; see also State v. Heaney, 689 N.W.2d 168, 170 (Minn. 2004) (“A conflict of laws concerning the admissibility of evidence protected by the physician-patient relationship is resolved by applying the two- prong test set forth in Restatement (Second) of Conflict of Laws § 139 (1971).”).

2017Co., 510 N.W.2d 204, 209 (Minn.App. 1993), rev. denied (Minn. Oct. 27, 1994)).

2017Co., 510 N.W.2d 204, 209 (Minn.App. 1993), rev. denied (Minn. Oct. 27, 1994)).

2016State v. Ness, 834 N.W.2d 177 , 181 3 (Minn. 2013).

2016State v. Ness, 834 N.W.2d 177, 181 (Minn. 2013).

2015Minnesota appellate courts have consistently recognized that, unlike the more deferential federal rational-basis test, the Minnesota test does not allow courts to “hypothesize a rational basis to justify a classification.” Russell, 477 N.W.2d at 889 ; see Greene v. Comm’r of Minn. Dep’t of Human Servs., 755 N.W.2d 713, 729 (Minn. 2008).

2015Minnesota appellate courts have consistently recognized that, unlike the more deferential federal rational-basis test, the Minnesota test does not allow courts to “hypothesize a rational basis to justify a classification.” Russell, 477 N.W.2d at 889 ; see Greene v. Comm’r of Minn. Dep’t of Human Servs., 755 N.W.2d 713, 729 (Minn. 2008).

2012This court has held that the Minnesota rational-basis test “applies when analyzing any case under the equal protection clause of the Minnesota Constitution.” Mitchell v. Steffen, 487 N.W.2d 896 , 904 n. 2 (Minn.App.1992), affd, 504 N.W.2d 198 (Minn.1993). 3 But in the context of analyzing a workers’ compensation statute, the supreme court in Gluba declined to infer from the language or structure of the Minnesota rational-basis test that a higher standard than the federal standard applies to matters concerning the regulation of economic activity and the distribution of economic benefits. 735 N.

2000Mitchell L.Rev. 337, 359 (1994), and have been the topic of some discussion by the court, see, e.g., Turner, 391 N.W.2d at 770 n. 2, 771-72 (Wahl, 1., concurring specially) (majority stating that the two formulations "merely represent different ways of stating the same analysis” but concurring opinion by Justice Wahl concluding that the difference between the federal and Minnesota rational basis test is that Minnesota’s test requires “a reasonable connection [to] be shown between the actual, and not just theoretical, affect of the challenged classification and the statutory goals”); Russell, 4

2024Ex parte Young, 209 U.S. 123, 150-68 (1908); see also U.S. Const. amend.

2024And the supreme court chose the “most-significant-relationship” test in Castillo-Alvarez because, consistent with prior caselaw considering the admissibility of evidence in criminal trials, the Minnesota rule has “both a procedural and substantive purpose.” Id. at 539 ; see also State v. Heaney, 689 N.W.2d 168, 170 (Minn. 2004) (“A conflict of laws concerning the admissibility of evidence protected by the physician-patient relationship is resolved by applying the two- prong test set forth in Restatement (Second) of Conflict of Laws § 139 (1971).”).

2024And the supreme court chose the “most-significant-relationship” test in Castillo-Alvarez because, consistent with prior caselaw considering the admissibility of evidence in criminal trials, the Minnesota rule has “both a procedural and substantive purpose.” Id. at 539 ; see also State v. Heaney, 689 N.W.2d 168, 170 (Minn. 2004) (“A conflict of laws concerning the admissibility of evidence protected by the physician-patient relationship is resolved by applying the two- prong test set forth in Restatement (Second) of Conflict of Laws § 139 (1971).”).

2019See Newman v. Fjelstad , 271 Minn. 514 , 137 N.W.2d 181 , 186 (1965).

2019See Newman v. Fjelstad , 271 Minn. 514 , 137 N.W.2d 181 , 186 (1965).

2016State v. Trahan, 870 N.W.2d 396, 403 (Minn. App. 2015), aff’d ___N.W.2d ___ (Minn. Oct. 12, 2016).

2016State v. Trahan, 870 N.W.2d 396, 403 (Minn. App. 2015), aff’d ___N.W.2d ___ (Minn. Oct. 12, 2016).

2016See State v. Collier, 438 So.2d 652, 655 (La.Ct.App.1983) (holding “that it is error to allow the State to reopen its case in a bench trial to prove an essential element of the offense charged after the State has closed, and after the defendant has moved for a judgment of acquittal”); People v. Whipple, 97 N.Y.2d 1 , 734 N.Y.S.2d 549 , 760 N.E.2d 337, 341 (2001) (holding that the district court may allow a prosecutor to reopen its case in response to a defense motion for acquittal if “the missing element is simple to prove and not seriously contested, and reopening the 'case does not unduly pr

2016See State v. Collier, 438 So.2d 652, 655 (La.Ct.App.1983) (holding “that it is error to allow the State to reopen its case in a bench trial to prove an essential element of the offense charged after the State has closed, and after the defendant has moved for a judgment of acquittal”); People v. Whipple, 97 N.Y.2d 1 , 734 N.Y.S.2d 549 , 760 N.E.2d 337, 341 (2001) (holding that the district court may allow a prosecutor to reopen its case in response to a defense motion for acquittal if “the missing element is simple to prove and not seriously contested, and reopening the 'case does not unduly pr

2016See State v. Collier, 438 So.2d 652, 655 (La.Ct.App.1983) (holding “that it is error to allow the State to reopen its case in a bench trial to prove an essential element of the offense charged after the State has closed, and after the defendant has moved for a judgment of acquittal”); People v. Whipple, 97 N.Y.2d 1 , 734 N.Y.S.2d 549 , 760 N.E.2d 337, 341 (2001) (holding that the district court may allow a prosecutor to reopen its case in response to a defense motion for acquittal if “the missing element is simple to prove and not seriously contested, and reopening the 'case does not unduly pr

2016See State v. Collier, 438 So.2d 652, 655 (La.Ct.App.1983) (holding “that it is error to allow the State to reopen its case in a bench trial to prove an essential element of the offense charged after the State has closed, and after the defendant has moved for a judgment of acquittal”); People v. Whipple, 97 N.Y.2d 1 , 734 N.Y.S.2d 549 , 760 N.E.2d 337, 341 (2001) (holding that the district court may allow a prosecutor to reopen its case in response to a defense motion for acquittal if “the missing element is simple to prove and not seriously contested, and reopening the 'case does not unduly pr