Justia Criminal Law Opinion Summaries

Henry Lee Brown was involved in a fatal collision in 2021 while driving near his home in Minneapolis. After hitting and killing a pedestrian, Brown did not stop at the scene and drove home without notifying the police. He was charged with two counts of criminal vehicular homicide, including leaving the scene of a collision. Brown initially pled not guilty but later changed his plea to guilty for leaving the scene after causing the collision. He admitted to driving the vehicle and leaving the scene but claimed he was unconscious at the time of the collision due to a medical incident.The district court denied Brown's motion to withdraw his guilty plea and sentenced him to 58 months in prison. Brown appealed, arguing that the statute required the State to prove he was volitionally operating the vehicle at the time of the collision. The court of appeals affirmed the district court's decision, holding that the statute did not require volitional operation at the time of the collision.The Minnesota Supreme Court reviewed the case to determine whether the criminal vehicular homicide statute required proof of volitional operation at the time of the collision. The court concluded that the statute does not require an act of operation at the time of the collision. Instead, an act of operating a motor vehicle that takes place before a collision can satisfy the statute's requirements. The court affirmed the decision of the court of appeals on other grounds, holding that Brown's factual basis for his guilty plea was adequate because he admitted to volitionally operating the vehicle before losing consciousness, causing the pedestrian's death, and leaving the scene without returning. View "State v. Brown" on Justia Law

A Nashwauk police officer observed a vehicle swerving and initiated a traffic stop, identifying the driver as Christopher Lee Manska. The officer noted signs of intoxication and discovered Manska's driver's license had been canceled. Manska refused a chemical test, and a search of his vehicle revealed marijuana. He was charged with multiple offenses, including driving while impaired and possession of marijuana. Manska sought the audit trail of the dash camera footage, claiming the footage had been tampered with.The district court denied Manska's motion to compel the audit trail, finding his claims of tampering unsupported and not credible. The court of appeals affirmed, concluding that Manska failed to show the information sought would be "material and favorable" to his defense, applying a higher standard than required.The Minnesota Supreme Court reviewed the case, determining that the lower courts applied the wrong standard. The correct standard under Minn. R. Crim. P. 9.01, subd. 2(3), requires only that the information sought "may relate to the guilt or innocence of the defendant." The Supreme Court concluded that Manska made an adequate showing that the audit trail may relate to his guilt or innocence, as it could reveal discrepancies in the dash camera footage that would challenge the officer's credibility.The Supreme Court reversed the lower courts' decisions and remanded the case. On remand, the district court must require the State to disclose the audit trail. If the audit trail shows tampering, Manska is entitled to a new suppression hearing. If no tampering is found, the conviction stands. View "State v. Manska" on Justia Law

In 2021, Ryan Martens disclosed to his therapist that he had engaged in sexual contact with his children's babysitter when she was 17 years old. The therapist, a mandated reporter, filed a maltreatment report with Kanabec County authorities. At the time of the disclosure, the victim was 18 years old. Martens was subsequently charged with third-degree criminal sexual conduct.The district court denied Martens's motion to exclude the therapist's report and testimony, ruling that the therapist-client privilege did not apply because the report was mandatory under the mandated-reporter statute. A jury found Martens guilty, and the court of appeals affirmed the conviction, concluding that the mandated-reporter statute required the therapist to file the report.The Minnesota Supreme Court reviewed the case to determine whether the mandated-reporter statute, Minn. Stat. § 260E.06, subd. 1(a), requires a report when the maltreated child is over 18 at the time of disclosure. The court held that the statute mandates a report if the reporter knows or has reason to believe that a child has been maltreated within the preceding three years, even if the child reaches adulthood before the disclosure. Consequently, the court affirmed the lower court's decision, ruling that the district court did not err in admitting the therapist's report and testimony. View "State of Minnesota vs. Martens" on Justia Law

A deputy from the Ramsey County Sheriff’s Department stopped Kyaw Be Bee’s vehicle on a public roadway in Saint Paul and found a BB gun under the driver’s seat. Bee was charged with carrying a BB gun in a public place, a gross misdemeanor under Minn. Stat. § 624.7181, subd. 2 (2024). The statute defines “public place” to include property owned or controlled by a governmental unit and private property open to the public, excluding certain private properties and specific locations.The district court dismissed the complaint for lack of probable cause, ruling that the interior of a motor vehicle on a public roadway is not a “public place” under the statute. The State appealed, and the Minnesota Court of Appeals reversed the district court’s decision. The appellate court held that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway, referencing the statutory context and a related exemption for transporting firearms in vehicles.The Minnesota Supreme Court reviewed the case to determine whether the interior of a private motor vehicle on a public road is a “public place” under Minn. Stat. § 624.7181, subd. 1(c). The court concluded that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway. The court reasoned that the statute’s exemptions and related provisions indicate that a motor vehicle on a public road is considered a public place. Consequently, the Supreme Court affirmed the decision of the court of appeals, reinstating the charge against Bee. View "State of Minnesota vs. Bee" on Justia Law

In 2018, Joshua Chiazor Ezeka was convicted by a Hennepin County jury of first-degree premeditated murder, first-degree attempted murder, and second-degree assault for killing Birdell Beeks while shooting at a rival gang member. He was sentenced to life in prison without the possibility of release for the murder, and additional consecutive sentences for the other charges. On direct appeal, the Minnesota Supreme Court affirmed his convictions but remanded for resentencing on the attempted murder charge due to an excessive sentence.After resentencing, Ezeka filed a petition for postconviction relief in 2022, which the district court denied without an evidentiary hearing. The district court concluded that even if the facts alleged in the petition were proven, Ezeka was not entitled to relief. The court also found that most of his claims were procedurally barred as they were known or should have been known at the time of his direct appeal.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the new evidence presented by Ezeka, including reports of general discriminatory practices by the Minneapolis Police Department and the Hennepin County Attorney’s Office, did not meet the legal standard for newly discovered evidence as it did not directly pertain to his case and would not have changed the trial's outcome. The court also found that the alleged failure to disclose this evidence did not constitute a Brady violation as it was not material to the case.Additionally, the court rejected Ezeka’s claims of ineffective assistance of trial and appellate counsel, concluding that his trial counsel’s performance was not objectively unreasonable and that there was no prejudice resulting from the alleged deficiencies. The court determined that the district court did not abuse its discretion in summarily denying the petition for postconviction relief. View "Ezeka vs. State of Minnesota" on Justia Law

Edgard Francisco Talave Latino was charged with misdemeanor domestic assault after an incident with M.T.L., with whom he had a prior romantic and sexual relationship. Latino and M.T.L. met in 2020 and had an on-again, off-again relationship that ended in November 2021. Shortly after their breakup, Latino went to M.T.L.'s apartment, where an argument ensued, and he assaulted her.The district court found Latino guilty of misdemeanor domestic assault, determining that he and M.T.L. had been involved in a significant romantic or sexual relationship, thus meeting the statutory definition of "family or household member." Latino waived his right to a jury trial, and the district court made this finding based on the evidence presented.Latino appealed, arguing that the statutory definition of "family or household member" should only apply to current relationships, not former ones. The Minnesota Court of Appeals disagreed, affirming the conviction by referencing its decision in Sperle v. Orth, which held that former relationships could qualify under the statute. The court of appeals concluded that the evidence was sufficient to prove that Latino and M.T.L. had been in a significant romantic or sexual relationship.The Minnesota Supreme Court reviewed the case to determine whether the statutory definition of "family or household member" includes former significant romantic or sexual relationships. The court held that the definition does include former relationships, subject to the statutory factors of length, type, frequency of interaction, and time since termination. The court found that the evidence was sufficient to support the district court's finding that Latino and M.T.L. had been involved in such a relationship, affirming the decision of the court of appeals. View "State vs. Talave Latino" on Justia Law

Berry Alexander Davis was involved in the kidnapping and murder of Monique Baugh and the attempted murder of her boyfriend, Jon, on New Year’s Eve in 2019. Baugh was abducted, placed in a U-Haul truck, and fatally shot. Davis and a co-defendant, Cedric Lamont Berry, were charged with first-degree premeditated murder, attempted first-degree premeditated murder, and kidnapping. The State's theory was that Davis and Berry attacked Jon on behalf of Lyndon Wiggins, who had a falling out with Jon. Detective Briana Johnson testified about the relationship between Davis, Berry, and Wiggins, indicating they were involved in drug dealing together. Davis waived his right to testify, and the jury found him guilty on all counts. He was sentenced to life in prison without the possibility of release.On direct appeal, Davis argued that the district court erred in joining his trial with Berry’s and that Detective Johnson’s testimony was inadmissible and prejudicial. The Minnesota Supreme Court rejected these arguments and affirmed his conviction and sentence. Davis also filed a pro se supplemental brief raising several claims, including that his sentence violated his constitutional right to a sentencing jury under Blakely v. Washington. The court found these claims lacked merit.Davis subsequently filed a postconviction petition alleging ineffective assistance of trial and appellate counsel and constitutional violations in his sentencing. The district court summarily denied the petition without an evidentiary hearing, concluding that even if Davis proved the facts alleged, he would not be entitled to relief as a matter of law.The Minnesota Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the district court did not abuse its discretion in denying Davis’s postconviction petition without an evidentiary hearing, as his claims failed on their merits as a matter of law. View "Davis vs. State" on Justia Law

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