Justia Criminal Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction of violating Minn. Stat. 260C.425, subd. 1(a), holding that section 260C.425, subd. 1 does not require the State to prove that a child is actually in need of protection or services.Under section 260C.425, subd. 1, it is a gross misdemeanor for a person to encourage, cause, or contribute to the need for protection or services. Defendant was convicted under the statute after he sent a note to a ten-year-old girl telling her to meet him at the railroad tracks. The court of appeals reversed, concluding that that the evidence was insufficient to prove that the girl was actually in need of protection or services. The Supreme Court reversed, holding that the court of appeals erred in concluding that the State must prove that actual services were needed. View "State v. Boss" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming the requirement that Defendant register as a predatory offender based on her conviction for aiding an offender to avoid arrest, holding that Defendant was not subject to the predatory offender registration requirement.Defendant helped her husband flee to Ohio after he committed a crime. Defendant was charged with, among other crimes, aiding an offender to avoid arrest. Defendant pled guilty to aiding an offender to avoid arrest and, at the plea hearing, was ordered to register as a predatory offender. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's conviction and charged offenses did not arise from the same set of circumstances; and (2) therefore, the predatory registration statute did not apply to Defendant's conviction. View "State v. Berry" on Justia Law

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The Supreme Court affirmed Defendant's conviction for exposing her child, T.D., to methamphetamine, holding that the State's evidence was sufficient to prove that T.D. was subjected to a risk of harm from methamphetamine.While conducting a search of a home, police found a small purse containing methamphetamine beyond a mattress upon which Defendant's child slept. The State charged Defendant with a violation of Minn. Stat. 152.137 subd. 2(d) for "exposing" her child to methamphetamine. The jury found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that the jury could reasonably have concluded that Defendant subjected her child to risk of harm from the methamphetamine in the purse. View "State v. Friese" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the decision of the district court granting the Commissioner of Correction's motion to dismiss Plaintiff's action seeking declaratory and injunctive relief, holding that some of the facts alleged in the complaint stated a claim upon which relief could be granted.Defendant pleaded guilty with several crimes. After Defendant began serving his sentence the Commissioner denied his application for the Challenge Incarceration Program on the grounds that persons required to register as predatory offenders are not eligible for that program. Defendant then brought this action alleging that the predatory offender registration statute and some of its collateral consequences denied him due process as applied to his charged, but not convicted, enumerated offense of kidnapping. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in dismissing Defendant's claim of substantive and procedural due process violations based on his alleged fundamental right to parent his child. View "Werlich v. Schnell" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction, holding that the State's discovery motion at Defendant's first court appearance seeking to photograph transitory scratches on Defendant's arms was not a critical stage of the criminal proceeding that required the presence of defense counsel.At Defendant's first appearance on criminal sexual conduct charges the State made a discovery motion to take photographs of transitory scratch marks on Defendant's arms. At issue was whether the discovery motion was a critical stage of the proceedings entitling Defendant to have counsel present. The court of appeals concluded that the discovery hearing on the "otherwise-valid" discovery request to noninvasively photograph scratches was not a critical stage of the proceedings. The Supreme Court affirmed, holding that there was no violation of Defendant's Sixth Amendment right to counsel under the circumstances of this case. View "State v. Zaldivar-Proenza" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of third-degree depraved mind murder under Minn. Stat. 609.195(a), holding that Defendant failed to show that an erroneous jury instruction affected his substantial rights.Defendant had an alcohol concentration of more than twice the legal limit when he drove his snowmobile at nearly sixty miles an hour across a frozen lake, fatally injuring an eight-year-old boy. When instructing the jury, the district court used the model jury instruction for third-degree depraved mind murder, which tells jurors that the underlying act must be "committed in a reckless or wanton manner with the knowledge that someone may be killed." Defendant challenged the instruction on appeal. The Supreme Court affirmed, holding (1) the instruction at issue materially misstated the law; but (2) Defendant failed to establish that the error affected his substantial rights. View "State v. Coleman" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court determining that the interior of a private motor vehicle is not a public place when it is not regularly held open to the public, holding that the court of appeals did not err.At issue was whether the driver of a motor vehicle is in a public place for purposes of Minn. Stat. 624.7142, subd. 1(4), which prohibits a person who is under the influence of alcohol from carrying a pistol in a public place. The district court dismissed the count charging Defendant with a violation of the statute. The court of appeals reversed and reinstated the charge. The Supreme Court affirmed, holding that the Legislature intended to prohibit an impaired person from carrying a pistol on public streets even when that person is inside a motor vehicle. View "State v. Serbus" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Appellant's fourth petition for postconviction relief, holding that the district court did not abuse its discretion in summarily denying Appellant's petition.After the Supreme Court reversed Appellant's first conviction on direct appeal, Appellant was convicted of first-degree murder while committing or attempting to commit a kidnapping. The Supreme Court affirmed. In his fourth petition for postconviction relief Appellant challenged his sentence, among other claims. The district court denied the petition without a hearing, holding that Appellant's sentence was lawful and that his remaining claims were untimely. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "Hannon v. State" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals determining that Minn. Stat. 169A.20, subd. 1(7) is a strict liability offense that does not require the State to prove knowledge as an element of the crime, holding that Defendant's conviction was valid.Defendant pleaded guilty to operating a motor vehicle with a schedule I or schedule II controlled substance in his body. Defendant subsequently sought to withdraw his guilty plea under Minn. R. Crim. P. 15.05, subd. 1, arguing that his guilty plea was invalid because he did not admit that he knew or had reason to know that amphetamine was present in his body at the time he was operating his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that strict liability was appropriate because there was a clear legislative intent to dispense with a mens rea requirement. View "State v. Schwartz" on Justia Law

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The Supreme Court reversed the decision of the court of appeals concluding that the United States Supreme Court's decision in Missouri v. McNeely, 569 U.S. 141 (2013), is substantive in the context of a conviction for test refusal, holding that the rule announced in McNeely is procedural and does not apply retroactively to test-refusal convictions on collateral review.In 2010, Defendant was convicted of first-degree test refusal for refusing to submit to a warrantless blood and urine test. In 2016, he filed a petition for postconviction relief, arguing that his conviction was unconstitutional. The district court ultimate determined that Defendant was entitled to postconviction relief, regardless of whether McNeely applied. The court of appeals reversed, holding that McNeely applied retroactively. The Supreme Court reversed and remanded the case, holding that McNeely did not apply retroactively to Defendant's test-refusal conviction, and the district court not properly articulate the pre-McNeely standard for exigent circumstances. View "Johnson v. State" on Justia Law