Justia Criminal Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree manslaughter, holding that the plain language of the first-degree manslaughter statute, Minn. Stat. 609.20(2), does not require the State to prove that death or great bodily harm was a reasonably foreseeable result when the underlying crime is fifth-degree assault. On appeal, Defendant argued that the district court erred by failing to instruct the jury that a conviction for first-degree manslaughter required proof that he committed fifth-degree assault with such violence or force that great bodily harm or death was reasonably foreseeable. The court of appeals affirmed, concluding that the district court did not err in declining to so instruct the jury. The Supreme Court affirmed, holding that section 609.20(2) does not require the State to prove that death or great bodily harm was a reasonably foreseeable result of the defendant's conduct when the underlying crime is fifth-degree assault. View "State v. Stay" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree felony murder, first-degree aggravated robbery, and possession of a firearm by an ineligible person related to a fatal shooting, holding that the district court did not clearly err by overruling Defendant's Batson objection to the State's peremptory challenge of a prospective juror. On appeal, Defendant argued that the district court erred in overruling his Batson objection to the State's peremptory challenge of the juror because the State's challenge was racially motivated and the proffered explanation for exercising the challenge was pretextual. The Supreme Court affirmed, holding that the district court did not clearly err in determining that the race-neutral reason for striking the juror was not a pretext for racial discrimination. View "State v. Adams" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the district court's decision denying Defendant's petition for postconviction relief asserting the invalidity of a test-refusal conviction under Birchfield v. North Dakota, 579 U.S. ___ (2016), and Johnson v. State, 916 N.W.2d 674 (Minn. 2018), holding that the district court properly placed the burden of proof on Defendant instead of the State. Birchfield announced the rule that, in the absence of a warrant or an exception to the warrant requirement, refusal to submit to a blood or urine test cannot be criminalized. Johnson made the rule retroactive. The district court denied Defendant's request for postconviction relief, concluding that he failed to prove there was no applicable exception to the warrant requirement. The court of appeals reversed, holding that the district court erred by placing the burden of proof on Defendant instead of the State. The Supreme Court reversed and announced a heightened pleading standard for Birchfield/Johnson postconviction proceedings, holding that the district court properly placed the burden of proof on Defendant. View "Fagin v. State" on Justia Law

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The Supreme Court reversed the decision of the court of appeals vacating as moot the district court's order granting Antwone Ford's petition for a writ of habeas corpus and ordering the Department of Corrections either to approve housing for Ford or to modify the terms of his conditional release, holding that Ford's claims were justiciable and that Ford was entitled to the writ. In his habeas petition, Ford asserted that the Commissioner of Corrections unlawfully extended his incarceration for sixteen months after his conditional release term began but failing to approve housing in a community in which he could be supervised. The court of appeals vacated the district court's order as moot. The Supreme Court reversed the court of appeals and reinstated the district court's order, holding that the Department's failure to abide by its internal policies and State ex rel. Marlowe v. Fabian, 755 N.W. 792 (Minn. App. 2008), kept Ford incarcerated for an extended period of time, and this petition for a writ of habeas corpus was an appropriate procedural remedy. View "State, ex rel. Ford v. Schnell" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first-degree murder and attempted first-degree murder, holding that Defendant's allegations of error did not warrant reversal of his convictions. Specifically, the Court held (1) the admission of certain evidence did not violate the Fourth Amendment to the United States Constitution or the substantive requirements of Minn. Stat. 626A.42; (2) to the extent the challenged evidence violated Minn. R. Evid. 702 the error was harmless; (3) the district court did not clearly err when it determined that Defendant failed to make a prima facie showing of discrimination under step one of the Batson v. Kentucky, 476 U.S. 79 (1986), inquiry; and (4) Defendant's claims of ineffective assistance of counsel and prosecutorial misconduct were without merit. View "State v. Harvey" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of knowingly failing to register as a predatory offender, holding that to convict a defendant of knowingly failing to register as a predatory offender the State must prove not only that the defendant's living arrangement at the primary address had ended but also that the defendant knew that this living arrangement had ended. A jury found Defendant guilty when he did not register with local law enforcement authorities within twenty-four hours of leaving his registered primary address, a motel room. The court of appeals affirmed, concluding that sufficient evidence sustained Defendant's conviction. The Supreme Court reversed, holding (1) the State tried to prove by circumstantial evidence that Defendant knew that his living arrangement at the motel had ended, but the circumstances were consistent with a reasonable inference to the contrary; and (2) therefore, the evidence at trial was insufficient to support Defendant's conviction. View "State v. Alarcon" on Justia Law

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The Supreme Court affirmed Appellant's conviction of first-degree criminal sexual conduct and false imprisonment, holding that Defendant was not deprived of a fair trial when a detective testified about photographs that were found on Appellant's cellphone. After a jury trial, Defendant was found guilty of two counts of criminal sexual conduct in the first degree and one count of false imprisonment. The court of appeals affirmed. On appeal, Defendant argued that he was deprived of a fair trial because a detective improperly testified and offered opinions about photographs on Defendant's cellphone. The Supreme Court affirmed, holding (1) the detective's opinion testimony concerning the images on Defendant's cellphone should not have been admitted; (2) the State did not bear the burden to prove that an error in admitting the detective's testimony was harmless beyond a reasonable doubt; and (3) there was no reasonable possibility that the erroneously admitted evidence significantly affected the outcome of the trial. View "State v. Jaros" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction, holding that a body cavity search performed by forcing Defendant to be strapped down and sedated in order to undergo an invasive anoscopy against his will in the presence of nonmedical personnel was unreasonable under the Fourth Amendment. After Defendant was strapped down and sedated he was forced against his will to undergo an anoscopy. During the procedure, the doctor located a plastic baggie containing cocaine in Defendant's body cavity. The State charged Defendant with one count of fifth-degree possession of a controlled substance. Defendant moved to suppress evidence of the drugs, arguing that the search, even though conducted pursuant to a valid search warrant, was unreasonable. The district court denied the motion, and Defendant was convicted. The court of appeals affirmed, concluding that the anoscopy was a reasonable search. The Supreme Court reversed, holding that the extreme intrusion of Defendant's dignitary rights by the coerced anoscopy outweighed the State's need to retrieve relevant evidence of drug possession, and therefore, the evidence retrieved from the search must be suppressed. View "State v. Brown" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing Defendant's sentence on the basis that the district court had misapplied Minn. Sent. Guidelines 2.B.7.a, holding that the classification of a prior offense is determined by reference to the statute setting forth the elements of the crime, rather than by reference to Minn. Stat. 609.02 defining "felony" and "gross misdemeanor." Defendant was convicted of first-degree sale of a controlled substance. After the district court sentenced Defendant he appealed, arguing that his criminal-history score was improperly calculated because the district court had misapplied section 2.B.7.a. The court of appeals agreed and remanded to the district court for resentencing. The Supreme Court affirmed, holding that the term "offense definitions" in section 2.B.7.a means the element-based definition of a crime under the statute setting forth a particular offense. View "State v. Strobel" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief, holding that the district court did not err in denying the petition without holding an evidentiary hearing. Defendant was convicted of first-degree murder as an accomplice. The Supreme Court affirmed on direct appeal. Thereafter, Defendant filed the present petition for postconviction relief, alleging several claims of error. The district court denied the petition without a hearing, reasoning that Defendant's arguments were either procedurally barred or lacked merit. The Supreme Court affirmed, holding that Defendant's claims were either procedurally barred or failed on the merits. View "Onyelobi v. State" on Justia Law