Justia Criminal Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed the judgment of the court of appeals concluding that a Blakely violation committed by the district court at a sentencing hearing was harmless beyond a reasonable doubt, holding that the Blakely violation was harmless beyond a reasonable doubt.After a jury trial, Defendant was found guilty to two counts of criminal sexual conduct. The complaint alleged that the offenses were committed sometime between 2004 and 2018, but at sentencing, the district court determined that Defendant's offenses were committed after August 1, 2006. The court of appeals affirmed Defendant's sentence, concluding (1) the lower court's determination of Defendant's offense dates was a violation of Blakely v. Washington, 542 U.S. 196 (2004), and its progeny; but (2) the error was harmless. The Supreme Court affirmed, holding that although the district court erred in determining that date of Defendant's offense without receiving a Blakely waiver from Defendant, but the error was harmless beyond a reasonable doubt. View "State v. Reimer" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily denying Appellant's third petition for postconviction relief as untimely, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of first-degree murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed Defendant's conviction and sentence on direct appeal. In 2017, Defendant filed an unsuccessful petition for postconviction relief. In 2019, more than two years after his conviction became final, Defendant filed a second petition for postconviction relief that was also unsuccessful. In 2020, Defendant filed his third petition for postconviction relief. The district court determined that the claim was time-barred under Minn. Stat. 590.01, subd. 4(a) and denied relief. The Supreme Court affirmed, holding that Defendant's third petition for postconviction relief was untimely. View "Griffin v. State" on Justia Law

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The Supreme Court affirmed in part and reversed in part Defendant's conviction of first-degree premeditated murder, second-degree intentional murder, and being an ineligible person in possession of a firearm, holding that the entry of a conviction for the offense of second-degree intentional murder violated Minn. Stat. 609.04.Specifically, the Supreme Court held (1) the district court did not err in denying two requests for advisory counsel to assume full representation of Defendant's defense because Defendant did not make a valid request; (2) the record supported the district court's finding that Defendant voluntarily waived his right to counsel; and (3) the district court violated section 609.04 when it entered a conviction for the offense of second-degree intentional murder. View "State v. Woods" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court finding Defendant guilty of violating a domestic abuse no contact order (DANCO), holding that the State did not violate Defendant's rights under the Minnesota Uniform Mandatory Disposition of Detainers Act (UMDDA).Defendant made a proper request for a final disposition under the UMDDA, and the State dismissed the charges pending against him. Nearly one year later, the State refiled the charges and brought Defendant to trial. The Supreme Court affirmed the resulting conviction, holding (1) once the State dismissed the pending complaint, Defendant no longer enjoyed a right to disposition of that complaint under the UMDDA; (2) the delay between Defendant's speedy trial request and his trial did not violate his constitutional right to a speedy trial; and (3) the district court did not abuse its discretion by declining to dismiss the State's complaint under Minn. R. Crim. P. 30.02. View "State v. Mikell" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of theft under a principal theory of criminal liability and of being an indelible person in possession of a firearm, holding that the district court erred when it failed to conduct a Confrontation Clause analysis surrounding the testimonial statement of a nontestifying co-conspirator, but the error was harmless.On appeal, Defendant argued that the district court violated his right to confrontation by admitting his co-conspirator's statements to the police when Defendant had no opportunity to cross-examine his co-conspirator. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the district court violated Defendant's right to confrontation when it admitted the disputed statements into evidence at trial; but (2) the violation of the Confrontation Clause was harmless beyond a reasonable doubt. View "State v. Sutter" on Justia Law

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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