Justia Criminal Law Opinion Summaries

In 2018, Ricky Darnell Waiters was convicted of first-degree felony murder, attempted first-degree felony murder, and drive-by shooting for an incident where he shot two people in a bar parking lot, killing one and wounding the other. Waiters admitted to the shooting but claimed self-defense. His convictions were affirmed on direct appeal. Subsequently, Waiters filed multiple motions for postconviction relief, which the district court construed as petitions for postconviction relief and denied each time.Waiters filed a new petition for postconviction relief in November 2023, seeking reversal of his convictions or a new trial based on claims of ineffective assistance of counsel, prosecutorial misconduct, erroneous evidentiary rulings, and insufficient evidence. The district court summarily denied the petition without a hearing and without providing reasons for the denial.The Minnesota Supreme Court reviewed the case and found that the record did not disclose the basis for the district court’s decision. The Supreme Court could not determine whether the district court had considered Waiters’s claims. Therefore, the Supreme Court reversed the district court’s decision and remanded the case for further proceedings to ensure that the district court properly considers and addresses Waiters’s claims for postconviction relief. View "Waiters vs. State" on Justia Law

Robert Lee Baker, III, was charged with second-degree intentional murder after he shot and killed Maurice Anderson. The incident occurred after Anderson and an accomplice robbed Baker and his girlfriend at gunpoint while they were in a car. As the robbers were leaving with Baker's property, Baker exited the car with a firearm and demanded the return of his belongings. Anderson raised his gun in response, and Baker shot him multiple times, resulting in Anderson's death.At trial, Baker claimed self-defense and defense of others, but the district court refused to instruct the jury on these defenses. The court concluded that Baker was not entitled to the instructions because he failed to establish that he was not the initial aggressor and that he did not have a reasonable means to retreat. The jury found Baker guilty of second-degree intentional murder, and he was sentenced to 438 months in prison. The court of appeals affirmed the conviction, but on different grounds, concluding that Baker's use of deadly force was unreasonable as a matter of law.The Minnesota Supreme Court reviewed the case to determine whether the district court abused its discretion by refusing to instruct the jury on self-defense and defense of others. The court held that the proper standard for determining whether a defendant is entitled to a jury instruction on self-defense or defense of others is whether the defendant produced reasonable evidence to support their claim. The court concluded that Baker presented sufficient evidence to support his claims of self-defense and defense of others, and that the district court's failure to give these instructions was not harmless. Therefore, the Minnesota Supreme Court reversed the decision of the court of appeals and remanded the case for a new trial. View "State of Minnesota vs. Baker" on Justia Law

Almanzo Cotton was found guilty by a jury of second-degree intentional murder and second-degree unintentional murder for beating his girlfriend, Kim Laen Theng, to death. The district court sentenced Cotton to 306 months imprisonment and ordered him to pay $2,362 in restitution to the Minnesota Crime Victims Reparations Board (the Board) to cover the cremation expenses paid by Theng’s daughter, S.T. S.T. had paid for the cremation using her personal credit card and later received funds from a GoFundMe campaign. She also submitted a claim to the Board, which awarded her the full amount of $2,362.Cotton challenged the restitution order, arguing that the GoFundMe proceeds should be considered a collateral source that offset the economic loss. The district court, however, concluded that the GoFundMe funds did not constitute recoupment of the cremation expenses from a collateral source and affirmed the restitution order. The court of appeals upheld the district court’s decision but remanded for the inclusion of a payment schedule.The Minnesota Supreme Court reviewed the case and held that the district court may not consider collateral sources when awarding restitution to the Board under Minn. Stat. § 611A.045, subd. 1(a). The court concluded that the exclusive factors for determining restitution are the amount of economic loss sustained by the victim and the income, resources, and obligations of the defendant. The collateral-source provision of the Minnesota Crime Victims Reparations Act does not apply in this context. The Supreme Court affirmed the decision of the court of appeals. View "State of Minnesota vs. Cotton" on Justia Law

Dontae White was convicted of second-degree intentional murder for the shooting death of Kevin Beasley. Beasley's mother, H.T., requested restitution for funeral expenses totaling $15,778.68. White argued that the life-insurance proceeds H.T. received should be subtracted from the restitution amount. The district court disagreed and ordered White to pay the full amount requested, reasoning that life insurance is intended to provide financial security and not just cover funeral expenses.The district court's decision was appealed, and the Minnesota Court of Appeals affirmed the restitution order. The court of appeals found that life insurance proceeds should not be considered when determining the amount of economic loss sustained by a family member of a deceased person for restitution purposes. The court distinguished life insurance from other types of insurance, noting that life insurance provides financial assistance beyond specific expenses like funeral costs.The Minnesota Supreme Court reviewed the case to determine whether life-insurance proceeds should be considered in calculating economic loss for restitution under Minn. Stat. § 611A.045, subd. 1(a)(1). The court held that life-insurance proceeds paid to a family member of the deceased should not be considered in determining the amount of economic loss sustained by the family member as a result of the murder. The court reasoned that life insurance is an investment contract intended to provide financial security, not merely to cover specific expenses. Therefore, the court affirmed the decision of the court of appeals, upholding the full restitution order. View "State of Minnesota vs. White" on Justia Law

In February 2021, Timothy Heller moved into his brother's house in Hennepin County, where his girlfriend, Lacy Krube, joined him. Shortly after, Lacy was asked to leave. The next day, Lacy was found severely beaten and later died from a stomach injury. Heller was arrested and charged with first-degree domestic abuse murder. Evidence included Heller's past domestic abuse against multiple victims and a witness testimony that Heller admitted to hitting Lacy.The Hennepin County District Court convicted Heller of first-degree domestic abuse murder. Heller appealed, arguing errors in jury instructions, admission of past abuse evidence, expert testimony on lethality factors, and exclusion of alternative-perpetrator evidence. The district court had allowed evidence of Heller's past abuse, including a 2000 conviction for abusing J.L., and expert testimony on lethality factors, but excluded certain evidence related to Heller's alternative-perpetrator defense.The Minnesota Supreme Court reviewed the case. It held that any error in the venue instruction was harmless beyond a reasonable doubt. The court found that evidence of singular acts of abuse against different victims constituted a past pattern of domestic abuse under Minnesota law. The court also ruled that the district court did not abuse its discretion in admitting evidence of Heller's past abuse, as it showed a consistent pattern of behavior. However, the court found that admitting expert testimony on lethality factors was an error, but it was harmless. The court upheld the exclusion of certain alternative-perpetrator evidence, finding no abuse of discretion.The Minnesota Supreme Court affirmed the district court's decision, concluding that the errors identified did not significantly impact the verdict. View "State vs. Heller" on Justia Law

Julian Valdez was convicted of second-degree unintentional felony murder for fatally shooting Pablo Gutierrez, who was allegedly attacking Valdez's stepbrother. The incident occurred after Gutierrez, who appeared agitated and unarmed, entered Valdez's garage and later got into a physical altercation with Valdez's stepbrother. Valdez retrieved a gun and, during the altercation, shot Gutierrez once, resulting in his death. Valdez claimed he acted in defense of his stepbrother, who was being choked by Gutierrez.The district court instructed the jury that Valdez had a duty to retreat before using force in defense of his stepbrother. Valdez was found guilty of second-degree unintentional felony murder. He appealed, arguing that the district court's instruction was erroneous. The Minnesota Court of Appeals agreed, concluding that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat. The court of appeals reversed Valdez's conviction and remanded for a new trial, finding that the erroneous instruction was not harmless beyond a reasonable doubt.The Minnesota Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat before acting in defense of his stepbrother. The court clarified that, to justifiably use force in defense of another, a defendant must subjectively believe that the person in peril has no reasonable possibility of safe retreat, and that belief must be objectively reasonable based on the information available at the time. The court also concluded that the erroneous instruction was not harmless, as it could not be said beyond a reasonable doubt that the error had no significant impact on the verdict. Therefore, Valdez's conviction was reversed, and the case was remanded for a new trial. View "State vs. Valdez" on Justia Law

In the late evening of January 24, 2022, Brandon Moore was driving a car with expired registration tabs when he was pursued by police. After a brief chase, Moore was arrested. During the search, officers found over six grams of methamphetamine in Moore's pockets, $3,400 in cash in the car's center console, and a handgun along with more than 110 grams of methamphetamine in the locked glove compartment. The key to the glove compartment was in the ignition.Moore was charged with aggravated first-degree controlled substance crime (sale and possession) and ineligible possession of a firearm. The jury found Moore guilty on all counts. The district court entered convictions for ineligible possession of a firearm and aggravated first-degree controlled substance crime for sale, sentencing Moore to 98 months in prison. Moore appealed, arguing that the evidence was insufficient to prove the firearm was "within immediate reach" as required by the statute because it was in a locked glove compartment.The Minnesota Court of Appeals affirmed the conviction, interpreting "within immediate reach" to include both spatial and temporal proximity, meaning the firearm was accessible without delay and close at hand. Moore then petitioned the Minnesota Supreme Court, which reviewed whether the evidence was sufficient to prove the firearm was "within immediate reach."The Minnesota Supreme Court held that "within immediate reach" does not require instant accessibility. The court concluded that the evidence was sufficient to prove the firearm was within Moore's immediate reach because he was in the driver’s seat and the key to the glove compartment was in the ignition. Therefore, the court affirmed the decision of the court of appeals. View "State vs. Moore" on Justia Law

In 2015, the appellant sexually assaulted a 9-year-old girl, but the crime was not reported until 2021. In the interim, the appellant committed an unrelated second-degree assault in 2016, for which he was convicted in 2017. After the 2015 sexual assault was disclosed in 2021, the appellant was charged and convicted of second-degree criminal sexual conduct.The district court found the appellant guilty of two counts of second-degree criminal sexual conduct. During sentencing, the court applied a sentencing enhancement under Minnesota Statutes section 609.3455, subdivision 3a, classifying the appellant as an engrained offender due to his prior conviction for second-degree assault. This resulted in an upward durational departure of 250 months in prison with a lifetime conditional release term. The appellant appealed, arguing that the term "previously committed" in the statute should mean a predatory crime committed before the commission of the present offense, not before the sentencing determination.The Minnesota Court of Appeals affirmed the district court's decision, holding that the statute required only that the predatory crime be committed before the sentencing determination. The appellant then sought review from the Minnesota Supreme Court.The Minnesota Supreme Court affirmed the lower court's decision, holding that for enhanced sentencing under Minnesota Statutes section 609.3455, subdivision 3a, a predatory crime is considered "previously committed" if it is committed before the fact-finder's sentencing-related determination that the offender is a danger to public safety. The court concluded that the plain language of the statute supports this interpretation, and thus, the appellant's 2017 assault conviction qualified as a "previously committed" predatory crime for the purposes of sentencing enhancement. View "State vs. Balsley" on Justia Law

On August 10, 2021, Jeron Garding was arrested for first-degree narcotics charges after a drug-dog sniff of his parked car led to the discovery of approximately 410 grams of methamphetamine. Garding moved to suppress the evidence, arguing that law enforcement lacked reasonable, articulable suspicion to conduct the drug-dog sniff. The district court held a contested omnibus hearing where State Trooper Jacob Bredsten testified about his observations, including the suspicious behavior of Garding and his passenger, signs of the passenger’s recent drug use, and a plastic bag in the backseat that appeared to contain drugs.The district court denied Garding’s motion to suppress, finding that Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff based on the totality of the circumstances. Garding was subsequently convicted of first-degree possession of narcotics after a stipulated facts trial, preserving his right to appeal the suppression ruling. The Minnesota Court of Appeals reversed the district court’s decision, concluding that the trooper lacked reasonable, articulable suspicion to justify the drug-dog sniff.The Minnesota Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that, under the totality of the circumstances, Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff. The court emphasized that the combination of the passenger’s signs of recent drug use, the appearance of the plastic bag in the backseat, and Garding’s flight to the woods provided sufficient grounds for the suspicion. Therefore, the district court did not err in denying Garding’s motion to suppress the evidence obtained from the search. View "State v. Garding" on Justia Law

The appellant, Earley Romero Blevins, was charged with two counts of second-degree assault-fear with a dangerous weapon after brandishing a machete at a woman and two men on a light rail platform in downtown Minneapolis. Blevins claimed he acted in self-defense after one of the men threatened him with a knife. The incident was captured on surveillance video, which showed Blevins swinging the machete for about a minute, causing the woman and the two men to retreat.The district court found Blevins guilty, concluding that he had a reasonable opportunity to retreat but failed to do so, thus his actions were not justified under Minnesota's self-defense statute. The court sentenced him to a presumptive 39-month prison term. The Minnesota Court of Appeals affirmed the district court's decision, agreeing that the evidence supported the finding that Blevins had a reasonable opportunity to retreat.The Minnesota Supreme Court reviewed the case to address whether the judicially created duty to retreat when reasonably possible applies to a person claiming self-defense in committing the felony offense of second-degree assault-fear with a dangerous weapon. The court held that this duty does apply in such cases, specifically when the weapon is designed to cause death or great bodily harm. The court also concluded that the surveillance video evidence disproved Blevins's claim that he lacked a reasonable opportunity to retreat.The Minnesota Supreme Court affirmed the decision of the court of appeals, holding that Blevins had a duty to retreat when reasonably possible before brandishing the machete and that the evidence showed he had such an opportunity. View "State of Minnesota vs. Blevins" on Justia Law