Justia Criminal Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed in part and reversed in part Defendant's convictions for first-degree premeditated murder, first-degree domestic abuse murder, and second-degree intentional murder, holding that the district court violated Minn. Stat. 609.04 when it entered convictions on the offenses of first-degree domestic abuse murder and second-degree intentional murder in addition to the conviction for first-degree premeditated murder. The Supreme Court affirmed the jury's verdicts but remanded the case to the district court to vacate the convictions for first-degree domestic abuse murder and second-degree intentional murder, holding (1) the evidence was sufficient to support the jury's verdicts; (2) the district court did not commit reversible error in admitting statements Defendant made during interviews with police; but (3) the district court erred by convicting Defendant of first-degree domestic abuse murder and second-degree intentional murder in addition to first-degree premeditated murder. View "State v. Balandin" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of check forgery, holding that a government inspection of a guest registry is a search under the Minnesota Constitution and that the district court committed reversible error by admitting evidence illegally seized from Defendant's hotel room. Based on evidence that law enforcement officers discovered in Defendant's hotel room, Defendant was charged with check forgery. Defendant filed a motion to suppress, arguing that the officers violated Minn. Const. art. I, 10 when they inspected the hotel guest registry, which led them to his room, without having any individualized suspicion of criminalized activity. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) law enforcement officers must have at least a reasonable, articulable suspicion to search a guest registry; (2) the hotel guest registry statutes, Minn. Stat. 327.10-.13 are constitutional because they do not authorize suspicionless searches; and (3) because the evidence admitted in this case was the fruit of the illegal, suspicionless search of the guest registry the district court erred by denying Defendant's motion to suppress. View "State v. Leonard" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first-degree murder and second-degree murder but reversed the sentence in part, holding that the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder but any other error in the proceedings below was harmless. Specifically, the Supreme Court held (1) any error the district court may have made by declining to hold an evidentiary hearing regarding the admissibility of DNA evidence was harmless, and the district court did not abuse its discretion by denying Defendant's motion to exclude the DNA evidence; (2) Defendant was not prejudiced by alleged prosecutorial misconduct; and (3) the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder in its sentencing order, and therefore, the cause must be remanded to the district court to correct the error. View "State v. Garland" on Justia Law

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The Supreme Court affirmed Defendant's sentences for drive-by shooting at an occupied vehicle and second-degree assault, holding that Minn. Stat. 609.035 did not prohibit the sentences for both offenses when the crimes arose from a single behavioral incident. The district court sentenced Defendant to forty-eight months for drive-by shooting at an occupied vehicle and thirty-six months for second-degree assault and imposed the two sentences to run concurrently. The court of appeals affirmed. The Supreme Court affirmed, holding that, under this Court's analysis in State v. Ferguson, 808 N.W.2d 586 (Minn. 2012), the district court properly imposed multiple sentences in this case. View "State v. Branch" on Justia Law

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The Supreme Court affirmed the order of the state district court that revised Appellant's sentence from two consecutive terms of life without the possibility of release to two consecutive terms of life with the possibility of release after thirty years, holding that the court did not abuse its discretion when it strictly followed the terms of the federal district court's remand order. Appellant was convicted of two counts of first-degree premeditated murder and sentenced to two life without parole sentences consecutively. After Miller v. Alabama, 567 U.S. 460 (2012), was decided Appellant filed a petition for a writ of habeas corpus. Ultimately, the federal district court vacated the "without possibility of release" provision of Appellant's sentences and remanded for resentencing. On remand, the state district court, without a resentencing hearing, revised Appellant's sentence to two consecutive terms of life with the possibility of release after thirty years. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that the language of the federal district court order reflected a limited remand; and (2) did not abuse its discretion in concluding that the issue of whether Appellant's sentences should be served consecutively was beyond the scope of the remand order. View "State v. Thompson" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing Defendant's request for postconviction relief and remanding the case for a new trial, holding that the trial court did not abuse its discretion under Minn. R. Evid. 106 by overruling Defendant's objection and allowing the jury to hear only an excerpt of a recorded police interview. Defendant was charged with second-degree sexual conduct. At trial, the State offered as evidence an eight-minute excerpt of an hour-long, videotaped, voluntary interview of Defendant by a police detective. Defendant objected and argued that the entire recording should be admitted into evidence and played for the jury under Rule 106. The trial court overruled the objection and played only the requested excerpt for the jury. The jury found Defendant guilty. Defendant filed a petition for postconviction relief, challenging the trial court's decision to play only the excerpt of the police interview for the jury. The district court denied postconviction relief. The court of appeals reversed, concluding that the entire interview should have been played for the jury. The Supreme Court reversed, holding that the trial court did not abuse its discretion when it properly overruled Defendant's objection under Rule 106. View "Dolo v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree murder and sentencing him to life in prison without the possibility of release, holding that the district court did not err in denying Defendant's motion to present an alternative-perpetrator defense. Specifically, the Supreme Court held (1) the district court did not abuse its discretion in holding that Defendant's proffered evidence in support of his motion to present alternative-perpetrator evidence for lack of sufficient foundation; and (2) the district court committed an error that was plain in instructing the jury on the order in which to consider the charges against Defendant, but there was no reasonable likelihood that the instruction affected the jury's verdict and therefore did not affect Defendant's substantial rights. View "State v. Woodard" on Justia Law

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The Supreme Court affirmed Defendant's conviction for first-degree murder, holding that there was no error in the proceedings below. Specifically, the Supreme Court held (1) Appellant's right to a fair trial before an impartial tribunal was not violated when the district court stated that it might reconsider its prior Spreigl ruling if the defense presented certain witnesses; (2) the jury instructions on accomplice liability were plainly erroneous, but Appellant failed to establish that there was a reasonable likelihood that the error had a significant effect on the verdict; (3) the prosecutor did not commit misconduct in his closing arguments regarding the law of accomplice liability; (4) the district court did not abuse its discretion by granting the State’s motion to admit evidence of appellant’s past convictions for impeachment purposes, including by allowing the specific convictions to be disclosed to the jury; and (5) Appellant’s pro se arguments were without merit. View "State v. Reek" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for first-degree sale of a controlled substance and second-degree possession of a controlled substance, holding that the district court did not abuse its discretion by admitting a witness's statements under Minn. R. Evid. 807, the residual hearsay exception. Defendant's convictions were based on a transaction in which Defendant sold methamphetamine to L.P. After she was arrested, L.P. was interviewed by law enforcement and made statements regarding her meeting with Defendant and the drug transaction. During trial, the district court admitted into evidence L.P.'s statements under Rule 807. At issue on appeal was whether the district court abused its discretion by admitting the statements. The Supreme Court affirmed, holding that the district court did not abuse its discretion by admitting L.P.'s statements because admission of the statements satisfied the enumerated requirements of Rule 807. View "State v. Vangrevenhof" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of second-degree driving while impaired, holding that the State properly used Defendant's license revocation as an aggravating factor to enhance his charge of driving while impaired. Defendant was charged with second-degree driving while impaired for refusal to submit to chemical testing in violation of Minn. Stat. 169A.25, subd. 1(b), which requires that the defendant both refuse to submit to chemical testing and the presence of one aggravating factor. Defendant's prior license revocation was the aggravating factor, but the State waited until the license revocation was sustained to charge Defendant. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) a license revocation is "present" as an aggravating factor as of its effective date, and it may be used to enhance a charge of driving while impaired once review has occurred or the right to review has been waived; and (2) therefore, the State properly used Defendant's license revocation as an aggravating factor. View "State v. Anderson" on Justia Law