Court Rulings

Discretionary termination of an applicant's withholding-only proceedings is prohibited by 8 C.F.R. § 1208.2(c)(3)(i) (2025).

Manifest weight of the evidence; Federal Railway Labor Act; motion for new trial. The trial court's judgment was not against the manifest weight of the evidence. The appellant's claims are not covered by the Federal Railway Labor Act. The trial court did not err when it denied the appellant's motion for a new trial.

Expert witness testimony; admissibility; causation; speculation; directed verdict; vicarious liability; respondeat superior; apportionment of damages; consent judgment entry; negligent hiring, training, and supervision; wrongful death; survival action; failure to report child abuse or neglect. The Estate of a deceased boy sought damages for claims, including wrongful death, a survival action, failure to report child abuse or neglect and negligent hiring, training and supervision, against Catholic Charities, a community service provider hired by the Cuyahoga County Department of Children and Family Services to provide services to the boy's mother and her family. The boy's mother and her boyfriend pled guilty to involuntary manslaughter of the boy after law enforcement discovered his body buried in the backyard of his home. Evidence in the record tends to show that the boy died of starvation. The Catholic Charities employee who was assigned to this case pled guilty to food stamp fraud for purchasing the boy's mother's food stamps for a reduced price. The Catholic Charities employee and the Estate entered into a consent judgment entry in which the employee admitted liability for the boy's death. After a jury trial, the court granted a directed verdict on all claims other than Catholic Charities' negligent hiring, training and supervision of its employee who admitted liability. The court found, as a matter of law, that Catholic Charities was not vicariously liable for the negligence of its employee. The jury found in favor of the Estate and against Catholic Charities and awarded the Estate $12 million. After the court applied the statutory cap on non-economic damages, as well as apportionment under the empty-chair defense, the damage award was reduced to $740,000. The Estate appealed. We find that the trial court erred by refusing to acknowledge the consent judgment entry; ruling that the consent judgment entry was inadmissible at trial; ruling that, as a matter of law,

1. The employee's injury occurred "in the course of" employment for the purpose of Minnesota Statutes section 176.021, subdivision 1 (2024), because the undisputed facts show that the employee sustained the injury within an hour of the end of the workday, the injury occurred at the workplace, and the employee was engaged in employment-related activity. 2. Minnesota Statutes section 176.021, subdivision 9 (2024), which excludes from workers' compensation liability injuries that occur while an employee is participating in a voluntary employer-sponsored recreational program, applies only to employer programs that are for the benefit of employees. Affirmed.

1. Under the Minnesota Human Rights Act's (MHRA) protection of transgender individuals against discrimination based on sexual orientation, Minn. Stat. § 363A.03, subd. 44 (2018), a policy that expressly prohibits transgender women from competing in the women's division of a powerlifting competition is facially discriminatory and constitutes direct evidence of discrimination based on sexual orientation under the MHRA's prohibition against business discrimination and discrimination by places of public accommodation, found at Minn. Stat. §§ 363A.11, 363A.17 (2018). 2. There is a genuine dispute of material fact as to whether seeking to ensure competitive fairness in an athletic competition satisfies the legitimate business purpose defense for sexual orientation and sex discrimination in business under Minn. Stat. § 363A.17 (2018) of the MHRA that forecloses partial summary judgment for the plaintiff as to liability on this claim. 3. In the absence of any alleged statutory exemption or defense, the district court properly granted partial summary judgment for the plaintiff on the claim of sexual orientation discrimination in public accommodations. 4. Our holding in Goins v. West Group, 635 N.W.2d 717 (Minn. 2001), is limited to claims of sexual orientation discrimination under the MHRA related to employment. Affirmed in part, reversed in part, and remanded.