Justia Criminal Law Opinion Summaries

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

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