Articles Posted in Minnesota Supreme Court

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The Supreme Court affirmed the decision of the court of appeals upholding Defendant’s conviction of simple robbery, holding that the evidence was sufficient to support the conviction. Defendant’s conviction arose from his act of taking a bottle of brandy from a liquor store and assaulting the store manager. On appeal, Defendant argued that he could not be convicted of simple robbery because the bottle that he took belonged to the business and not to a person, and therefore, the property was not “personal property” within the meaning of Minn. Stat. 609.24. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase “personal property” as used in the statute is a technical term that has acquired the specialized meaning of all property other than real property; and (2) therefore, the evidence was sufficient to support the conviction. View "State v. Bowen" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming Appellant’s conviction of felony domestic assault, holding that the evidence was sufficient to prove that Defendant and the victim were “persons involved in a significant romantic or sexual relationship” at the time of the offense under Minn. Stat. 609.2242(4). In affirming, the court of appeals concluded that the phrase “significant romantic or sexual relationship” is unambiguous. The Supreme Court affirmed, holding (1) that to determine whether two persons are involved in a “significant romantic or sexual relationship” for the purposes of the domestic-assault statute, a court must undergo a case-by-case analysis using the statutory factors of Minn. Stat. 518B.01(2), including the length of the relationship, the type of relationship, and the frequency of interactions between the two persons; and (2) the record was sufficient to support the jury’s finding that Defendant and the victim were in a “significant romantic or sexual relationship” when the assault occurred. View "State v. Robinson" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree premeditated murder and sentencing him to life in prison without the possibility of release, holding that, contrary to Defendant's assertions on appeal, Defendant’s conviction was not based on corroborated accomplice testimony and that there was no abuse of discretion in the jury instructions. Specifically, the Court held (1) the testimony of Defendant’s accomplice was sufficiently corroborated, and therefore, Defendant’s premeditated murder conviction did not violate Minn. Stat. 634.04; and (2) the district court did not abuse its discretion when it denied Defendant’s request to instruct the jury about the credibility of drug users or witnesses who could later be charged as accessories after the fact. View "State v. Thoresen" on Justia Law

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The Supreme Court reversed the court of appeals affirming the district court’s competency determination in this criminal case, holding that the court of appeals erred when it did not follow State v. Ganpat, 732 N.W. 2d 232 (Minn. 2007), and place the burden of proving that Defendant was competent on the State. After determining that Defendant was mentally competent to proceed to trial, the district court convicted him of fourth-degree criminal sexual conduct. Defendant appealed, arguing that the district court failed to place the burden of proof on the State as required by Ganpat in determining him to be competent. In affirming, the court of appeals declined to follow Ganpat, instead ruling that competency should be determined based on the greater weight of the evidence without regard to burden of proof. The Supreme Court reversed and remanded, holding that the court of appeals and district court erred in failing to adhere to Ganpat and that it was not certain whether the district court would have made the same competency determination had it applied the correct burden of proof. View "State v. Curtis" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the decision of the postconviction court that Defendant was entitled to a new trial because a juror was actually biased and not sufficiently rehabilitated but that the search of Defendant did not violate his Fourth Amendment rights. Defendant was convicted of possession of a firearm by an ineligible person. Thereafter, Defendant filed a postconviction petition arguing that the district court erred in denying his for-cause strike of Juror 18 and that the police unreasonably searched and seized him, violating his Fourth Amendment rights. The postconviction court rejected Defendant’s Fourth Amendment argument but concluded that the district court committed reversible error by denying the motion to strike Juror 18 for cause. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the search of Defendant was objectively reasonable under the emergency-aid exception to the Fourth Amendment warrant requirement; and (2) Defendant was entitled to a new trial because the presence of the actually biased juror. View "Ries v. State" on Justia Law

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The Supreme Court reversed the decision of the court of appeals holding that Minn. Stat. 609.342(1)(h) does not require the State to prove that “sexual penetration” occurred, holding that the plain language of the statute requires proof of “sexual penetration," and therefore, the State presented insufficient evidence to support Defendant's conviction. Defendant was convicted of first-degree criminal sexual conduct under section 609.342(1)(h) for engaging in genital-to-genital contact with G.M. On appeal, Defendant argued that the State presented insufficient evidence to support the conviction because the statute requires proof of “sexual penetration” and the State did not prove sexual penetration. The court of appeals rejected Defendant’s argument and affirmed. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the plain language of subdivision 1(h) unambiguously requires proof of sexual penetration. View "State v. Ortega-Rodriguez" on Justia Law

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The Supreme Court affirmed the decision of the district court denying Appellant’s motion to correct his sentences under Minn. R. Crim. P. 27.03(9), holding that the district court did not commit reversible error. Appellant was convicted of murdering his ex-wife and kidnapping their three children. The Supreme Court affirmed Appellant’s convictions and sentences. Appellant later filed the present motion to correct his sentences. Relying on Minn. Stat. 611.02, 609.04 and 609.035, Appellant argued that the district court committed reversible error. The district court denied the motion without holding a hearing. The Supreme Court affirmed, holding (1) Appellant’s claims made under Minn. Stat. 609.04 and 611.02 challenging his convictions were outside the scope of Rule 27.03(9); and (2) Appellant’s sentences did not violate section 609.035. View "Munt v. State" on Justia Law

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The Supreme Court affirmed the postconviction court’s summary denial of Defendant’s second postconviction petition, holding that the record conclusively showed that Defendant was not entitled to relief. Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed. This appeal concerned the postconviction court’s summary denial of Defendant’s second petition for postconviction relief in which Defendant argued that he was entitled to relief under the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations governing postconviction petitions. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in summarily denying the petition because (1) certain claims did not satisfy the interests-of-justice exception to the statute of limitations, (2) other claims were untimely, and (3) the remaining claims were unsupported by arguments or legal authority. View "Nissalke v. State" on Justia Law

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The Supreme Court affirmed the postconviction court’s denial of Appellant’s petition for postconviction relief challenging his conviction for first-degree murder for the benefit of a gang, holding that Appellant’s claims were procedurally barred by the rule articulated in State v. Knaffla, 243 N.W.2d 737, 741 (Minn. 1976). The postconviction court found that Appellant was not entitled to relief because his claims were procedurally barred by the Knaffla rule. The Supreme Court affirmed, holding that because Appellant’s postconviction petition was based on claims that were raised and decided in previous proceedings, the postconviction court did not abuse its discretion when it summarily denied the petition. View "Jackson v. State" on Justia Law

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The Supreme Court held that the decision of the United States Supreme Court in Birchfield v. North Dakota, 579 U.S. __ (2016), and this Court’s decisions in State v. Trahan, 886 N.W.2d 216 (Minn. 2016), and State v. Thompson, 886 N.W.2d 224 (Minn. 2016), announced a new rule of constitutional law that applies retroactively to cases on collateral view. In this consolidated appeal arising from two separate traffic stops, the Supreme Court reviewed the decision of the court of appeals concluding that the Birchfield rule did not apply retroactively to Defendant’s final convictions because the rule was procedural in nature, and that, therefore, the district courts properly denied Defendant’s postconviction petitions. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the Birchfield rule is substantive and applies retroactively to Defendant’s convictions on collateral review. View "Johnson v. State" on Justia Law