Justia Criminal Law Opinion Summaries

In December 2015, Sean Michael Wocelka’s daughter disclosed during a forensic interview that her father had touched her intimate parts using a toy giraffe. The incident occurred shortly before Christmas. Officers found the toy giraffe in Wocelka’s home, and he was charged with three counts of second-degree criminal sexual conduct. At trial, Wocelka’s daughter testified consistently with her initial statement. The jury found Wocelka guilty of two counts of second-degree criminal sexual conduct for the December 2015 incident.The district court convicted Wocelka of one count under Minnesota Statutes section 609.343, subdivision 1(a), which criminalizes sexual contact with a complainant under 13 years old by an actor more than 36 months older. Wocelka petitioned for postconviction relief, arguing that his conduct did not meet the statutory definition of “sexual contact.” The district court denied the petition as untimely and on the merits. The Minnesota Court of Appeals affirmed the district court’s decision on the merits without addressing the timeliness issue.The Minnesota Supreme Court reviewed the case to determine whether the use of an object to make contact with a complainant’s intimate parts constitutes “sexual contact” under Minnesota Statutes section 609.341, subdivision 11(a)(i). The court held that the term “touching” includes bringing an object into contact with the complainant’s intimate parts. Therefore, the court affirmed that Wocelka’s actions met the statutory definition of “sexual contact” and upheld his conviction for second-degree criminal sexual conduct. View "Wocelka vs. State of Minnesota" on Justia Law

The case revolves around Harry Jerome Evans, who was convicted of first-degree murder of a peace officer in 2006. The officer, Sergeant Gerald Vick, was shot during an undercover investigation at a bar in Saint Paul. Evans was identified as the shooter by Sergeant Joseph Strong, who was with Vick at the time, and by a trial witness. Evans's cousin, A.K., also testified that Evans had shot Vick. Evans claimed that A.K. was the actual shooter and that Vick was not performing official duties at the time of the shooting due to his intoxication. Evans was sentenced to life in prison without the possibility of release.Evans appealed his conviction multiple times in both state and federal courts. His appeals were consistently denied, with courts rejecting his claims of ineffective assistance of counsel, prosecutorial misconduct, and allegations that A.K. had admitted to being the actual shooter. Evans also filed petitions for postconviction relief and motions to correct his sentence, all of which were denied.In the current petition, Evans sought postconviction relief, arguing that his petition met the newly-discovered-evidence and interests-of-justice exceptions to the statutory time bar. The district court denied the petition, concluding that the facts alleged in the petition did not meet either exception. Evans appealed this decision.The Minnesota Supreme Court affirmed the district court's decision. The court found that Evans's petition did not meet the requirements of the newly-discovered-evidence exception, as the evidence was either not new, not exonerating, or was known or knowable by Evans at the time of trial. The court also found that Evans's petition did not meet the requirements of the interests-of-justice exception, as Evans did not allege that an injustice prevented him from filing his petition in a timely manner. View "Evans vs. State" on Justia Law

The case revolves around the appellant, McKinley Juner Phillips, who was convicted of first-degree premeditated murder and second-degree intentional murder for the stabbing death of his wife, Shavon Phillips. The appellant had conceded at trial that he caused the death of his wife but had requested that the jury be given instructions for first-degree heat-of-passion manslaughter in addition to the instructions for first-degree premeditated murder and second-degree intentional murder. The district court denied the requested instruction, reasoning that the evidence did not support a heat-of-passion instruction.The appellant appealed the district court's decision, arguing that the court committed reversible error by denying the requested instruction. The appellant's argument was based on the premise that the jury's finding of premeditation does not necessarily preclude a finding of heat-of-passion.The Minnesota Supreme Court, however, affirmed the district court's decision. The Supreme Court held that the appellant was not prejudiced by the district court’s decision not to instruct the jury on first-degree heat-of-passion manslaughter because the court gave instructions on both first-degree premeditated murder and second-degree intentional murder and the jury found the appellant guilty of first-degree premeditated murder. The court reasoned that the mental states of premeditation and heat of passion cannot coexist, and since the jury found the appellant guilty of premeditated murder, it would not have found him guilty of heat-of-passion manslaughter. View "Phillips v. State" on Justia Law

The case involves Angel Ignacio Sardina-Padilla, who was convicted of first-degree premeditated murder for the death of Jose Genis Cuate. Sardina-Padilla appealed the conviction, arguing that the district court erred in denying his motion to suppress evidence obtained from a warrant to search his Facebook accounts. He claimed that the warrant application failed to establish probable cause and did not satisfy minimal constitutional requirements for particularity. He also argued that the district court abused its discretion by summarily denying his petition for postconviction relief, which alleged ineffective assistance of counsel.The district court had denied Sardina-Padilla's motion to suppress the evidence obtained from the June warrant, concluding that the totality of the circumstances described in the June warrant application suggested that the accounts likely contained relevant evidence. The court also concluded that the June warrant satisfied minimal constitutional requirements for particularity.On appeal, the Supreme Court of Minnesota affirmed the district court's decision. The court found that the district court did not err in finding that the warrant application alleged that Sardina-Padilla asked someone to delete his Facebook account during a jail call. The court also concluded that the June warrant was sufficiently particular, considering the circumstances of the case, the nature of the crimes under investigation, and whether the officers could have provided a more precise description of the evidence sought. Finally, the court concluded that there was no reasonable probability that the trial’s outcome would have been different if counsel had successfully challenged the tracking data, and therefore, the district court did not abuse its discretion by summarily denying Sardina-Padilla’s petition for postconviction relief. View "State v. Sardina-Padilla" on Justia Law

The defendant, Sylvester Jones, was charged with third-degree criminal sexual conduct, using force to accomplish sexual penetration. After initially pleading not guilty, Jones later entered a guilty plea to the third-degree criminal sexual conduct charge in return for dismissal of other charges. However, during the plea hearing, Jones made a statement on record denying that he had committed the offense. Despite this, the judge found Jones’s factual basis sufficient to support his guilty plea, accepted it, and adjudged Jones guilty. Jones did not request withdrawal of his guilty plea at the continued sentencing hearing, and the district court sentenced Jones to 153 months in prison.On appeal, Jones argued that his unaddressed assertion of innocence made the factual basis for his guilty plea inaccurate. The court of appeals affirmed the lower court's decision, reasoning that Jones’s assertion of innocence during the plea hearing did not invalidate his plea because after he made the assertion, Jones admitted to the factual basis for the guilty plea through affirmative responses to defense counsel’s leading questions.The Minnesota Supreme Court disagreed with the lower courts. The court found that Jones’s guilty plea was inaccurate because he made a statement at the plea hearing that negated at least one element of the charged offense, and his guilty plea was not sufficiently rehabilitated because defense counsel subsequently used solely leading questions to elicit the necessary admissions for the factual basis. The court concluded that Jones is entitled to withdraw his plea to correct a manifest injustice under Minn. R. Crim. P. 15.05, subd. 1. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "State of Minnesota vs. Jones" on Justia Law

Michael Joseph Letourneau was charged with two counts of first-degree criminal sexual conduct. He was already incarcerated for unrelated reasons, which made him subject to the Uniform Mandatory Disposition of Detainers Act (UMDDA). This act allows incarcerated individuals to demand the speedy disposition of any pending criminal charges. Letourneau signed a formal request for his trial to commence within 6 months, as provided by the Act. However, during pretrial proceedings, Letourneau had multiple changes of counsel and a continuance due to defense counsel’s conflict that delayed resolution of pretrial matters. The district court found good cause to begin his trial in October, past the deadline otherwise required by the Act.The district court's decision to delay the trial was appealed to the Minnesota Court of Appeals, which affirmed the lower court's decision. The appellate court held that the district court did not abuse its discretion in finding good cause for a continuance because the delay was minimal and because Letourneau did not allege any prejudice caused by the delay.The case was then brought before the Minnesota Supreme Court. The Supreme Court affirmed the decision of the Court of Appeals, holding that the district court did not abuse its discretion in delaying the trial. The court noted that the district court had found good cause for the delay, citing changes of counsel, administrative delays, and scheduling issues. The court also noted that Letourneau's counsel did not object to the new trial date or the district court's finding of good cause to continue the trial date. The Supreme Court concluded that Letourneau’s right to a speedy disposition under the Act was not violated, and the district court’s reasonable continuance of the trial was not an abuse of its discretion. View "State of Minnesota vs. Letourneau" on Justia Law

The case involves Anthony James Trifiletti, who was convicted of second-degree unintentional felony murder. The conviction followed a second trial after the first ended in a mistrial due to a deadlocked jury. During the second trial, one of the State’s witnesses was exposed to COVID-19 and was deemed unavailable to testify in person. The district court allowed the transcript of her testimony from the first trial to be read into the record instead of live testimony. Trifiletti appealed, arguing that this violated his right to confrontation under the Sixth Amendment to the United States Constitution and Article I, Section 6, of the Minnesota Constitution.The Minnesota Supreme Court held that the district court erred in determining that the witness was unavailable under the Confrontation Clause. The court found that the State failed to establish that the witness would not have been available to testify in person at some reasonable point in time during the trial. The court also rejected the State's argument that Trifiletti invited the error by choosing to have the witness's prior testimony read aloud for the jury rather than having her testify via video. However, the court concluded that the error was harmless beyond a reasonable doubt, as the jury's determination that Trifiletti did not act in self-defense was surely unattributable to the witness's testimony. Therefore, the court reversed the decision of the court of appeals. View "State of Minnesota vs. Trifiletti" on Justia Law

The case revolves around the 1986 murder of Nancy Daugherty. The defendant, Michael Allan Carbo Jr., was charged with two counts of first-degree murder. The prosecution's case was based on DNA evidence collected from the crime scene and Carbo's garbage, which matched Carbo's DNA. Carbo sought to suppress this evidence, arguing that the collection and analysis of his DNA violated his Fourth Amendment rights. He also sought to introduce evidence suggesting that another individual, B.E., was the actual perpetrator.The district court denied Carbo's motion to suppress the DNA evidence, ruling that Carbo had abandoned his expectation of privacy by leaving his semen at the crime scene and his garbage in a communal bin. The court also denied Carbo's motion to introduce alternative-perpetrator evidence, concluding that the proffered evidence did not have an inherent tendency to connect B.E. to the crime.The Minnesota Supreme Court affirmed the lower court's decision regarding the DNA evidence. It held that Carbo had indeed abandoned his subjective expectation of privacy in the genetic information gathered from the crime scene and his garbage. However, the court reversed the lower court's decision on the alternative-perpetrator evidence. It found that the district court had abused its discretion by holding Carbo's evidentiary proffer to an unobtainable legal standard, thereby violating his constitutional right to present a complete defense. The court concluded that the error was not harmless and remanded the case for further proceedings. View "State of Minnesota vs. Carbo" on Justia Law

The case revolves around the appellant, Said Sharif Maye, who was convicted of second-degree unintentional murder for the death of Idris Yussuf in August 2020. Prior to the trial, the district court denied Maye's motion to exclude testimony that the State's main eyewitness received several threatening phone calls before the trial, instructing him not to testify. The State argued that the evidence was relevant to the witness's credibility, showing that he was willing to testify despite threats. The district court allowed the evidence, reasoning that it was probative of the witness's credibility and that the prejudicial effect of the evidence would be mitigated by the State's suggested clarifying questions.The court of appeals affirmed Maye's conviction, holding that the district court did not abuse its discretion in admitting evidence of the threatening phone calls. The court of appeals reasoned that the evidence was relevant to the witness's credibility, the State's use of the evidence was minimal, and the evidence was admitted with sufficient safeguards to protect against unfair prejudice. The court of appeals also held that even if the evidence was erroneously admitted, its admission was harmless.The Supreme Court of Minnesota held that the district court abused its discretion by admitting the threat evidence on direct examination. The court reasoned that the probative value of the evidence was minimal, and the risk of unfair prejudice to the defendant was substantial. However, the court affirmed the decision of the court of appeals, agreeing that the admission of the evidence was harmless. The court concluded that there was no reasonable possibility that the wrongfully admitted evidence significantly affected the verdict, given the strong evidence of Maye's guilt. View "State of Minnesota vs. Mcneilly" on Justia Law

The case revolves around the appellant, Said Sharif Maye, who was convicted of second-degree unintentional murder for the death of Idris Yussuf in August 2020. Before the trial, the district court denied Maye’s motion to exclude testimony that the State’s main eyewitness received several threatening phone calls before trial telling him not to testify. At trial, the State questioned the eyewitness about the threats at the end of direct examination. The court of appeals affirmed Maye’s conviction and held that the district court did not abuse its discretion in admitting evidence of the threatening phone calls.The Minnesota Supreme Court was tasked with determining whether the district court abused its discretion in admitting evidence on direct examination that a witness received threatening phone calls from an unknown caller and, if so, whether any such error was harmless. The court found that the district court did abuse its discretion by admitting the threat evidence on direct examination. However, the court affirmed the decision of the court of appeals because it agreed that the admission of the evidence was harmless. The court concluded that there was no reasonable possibility that the erroneously admitted threat evidence significantly affected the verdict. View "State of Minnesota vs. Maye" on Justia Law