Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court summarily denying Defendant's second petition for postconviction relief, holding that the district court did not abuse its discretion in denying the petition without holding an evidentiary hearing.After a jury trial, Defendant was found guilty of first-degree felony murder and attempted first-degree premeditated murder, among other crimes. Defendant later filed the postconviction petition at issue, asserting that he was denied his Sixth Amendment right to a trial before an impartial jury and that his trial counsel and appellate counsel provided ineffective assistance. The district court summarily denied the petition as time barred and procedurally barred. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Defendant's second postconviction petition as untimely. View "White v. State" on Justia Law

The Supreme Court held that the district court did not abuse its discretion when it summarily denied Appellant's eighth petition for postconviction relief as untimely.Appellant was convicted of first-degree premeditated murder under an aiding and abetting theory of liability. In his eighth petition for postconviction relief, Appellant invoked the time-bar exception for newly discovered evidence, relying on an affidavit of one of his codefendants. The district court summarily denied the petition as untimely based on its determination that the statements in the affidavit were not newly discovered. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Appellant's postconviction petition. View "El-Shabazz v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion under Minn. R. Civ. P. 60.02 to vacate the denial of his first postconviction petition and the district court's denial of his second postconviction petition, holding that the district court did not abuse its discretion by denying Appellant's motion and second petition.Defendant was found guilty of first-degree premeditated murder, first-degree aggravated robbery and other crimes. The district court imposed a life sentence without the possibility of parole. The Supreme Court affirmed on appeal and also affirmed the denials of Defendant's first postconviction petition and his motion to correct his sentence. At issue on this appeal was the district court's denial of his motion to vacate the denial of his first postconviction petition and the denial of his second postconviction petition. The Supreme Court affirmed, holding that Defendant's claims were time-barred under the postconviction statute. View "Blue Earth County v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder, attempted first-degree premeditated murder, and kidnapping, holding that any error in the proceedings below was harmless.Specifically, the Supreme Court held (1) any error on the part of the district court in failing to hold a hearing on the foundational reliability of cell-site location information (CSLI) evidence was harmless, and the district court was not required to hold a hearing to determine whether the CSLI evidence was generally accepted in the relevant community; (2) the district court did not err in trying Defendant's and his codefendant's cases together; and (3) Defendant was not prejudiced by the district court's denial of his request for an additional peremptory challenge. View "State v. Berry" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder, attempted first-degree murder, and kidnapping, holding that there was no error in the proceedings below.On appeal, Defendant argued, among other things, that the district court erroneously joined his and his codefendant's cases for trial and by denying subsequent severance motions. The Supreme Court affirmed his convictions, holding (1) the district court did not improperly join Defendant's and his codefendant's cases for trial and did not erroneously refuse to sever the cases once the trial was underway; (2) the prosecutor did not commit misconduct during closing arguments; and (3) Defendant was not entitled to relief as to the claims he raised in a pro se supplemental brief. View "State v. Davis" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court denying Defendant's third and fourth petitions for postconviction relief without holding an evidentiary hearing, holding that there was no error.After a jury trial, the district court entered judgment finding Defendant guilty of one count of first-degree premeditated murder and sentenced him to life in prison without the possibility of release. At issue were Defendant's third and fourth petitions for postconviction relief, in which Defendant alleged newly discovered evidence. The postconviction court denied both petitions. The Supreme Court affirmed, holding (1) none of the pieces of evidence proffered by Defendant satisfied the newly discovered evidence exception in Minn. Stat. 590, subd. 4(b)(2); and (2) Defendant failed to satisfy Minn. Stat. 490.01, subd. 4(b)(5)'s interests of justice exception, and his claims were therefore time-barred. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that certification of H.B., who was fifteen years old when he was charged in juvenile court with aiding and abetting second-degree murder and first-degree aggravated robbery, for adult prosecution was proper, holding that certification was required.Delinquency petitions were filed charging H.B. with aiding and abetting first-degree aggravated robbery. The State moved to prosecute H.B. as an adult for the charges, but the district court denied the motion, concluding that the dispositional options available to H.B. did not weigh in favor of certification. The court of appeals reversed and remanded with instructions for the district court to certify H.B. for adult prosecution. The Supreme Court affirmed, holding that the court of appeals correctly found that the district court abused its discretion in determining that the State had not met its burden of proving that retaining H.B. in the juvenile system would not serve public safety. View "In re H.B." on Justia Law

Appellant's petition for postconviction relief and vacating Appellant's conviction and sentence, holding that, in a postconviction proceeding, a district court has the authority under Minn. Stat. 590.04, subd. 1 to order the State to refund restitution that the defendant has paid because of a conviction when that conviction has been invalidated and no retrial will occur.Appellant was convicted of one count of violating Minn. Stat. 609.27, subd. 1(4). Later, subdivision 1(4) was declared facially overbroad and unconstitutional. In her petition for postconviction relief, Appellant asserted that, under Nelson v. Colorado, 581 U.S. __ (2017), she was entitled to a refund of all restitution payments made because of her invalid conviction. The district court vacated her conviction and sentence but denied her request for a refund of restitution on the grounds that it lacked authority to do so. The court of appeals affirmed. The Supreme Court reversed, holding that, in a postconviction proceeding, a district court has the authority to order a refund of restitution when the monetary assessments the defendant paid were imposed solely because of the conviction, the State exacted those assessments, and the conviction was invalidated with no prospect of retrial. View "Byington v. State" on Justia Law

The Supreme Court reversed the court of appeals' opinion affirming the district court's conclusion that Minn. Stat. 609.746, subd. 1(e)(2) does not require a defendant to have knowledge of the victim's age when the offense criminalized under this statute is committed, holding that the district court's pretrial ruling was erroneous.Section 609.746, subd. 1(d)(1) makes it a crime secretly to use a device to record or photograph a person in a place where a reasonable person would have an expectation of privacy and is likely to expose their private parts. At issue was subdivision 1(e)(2), which enhances the offense from a gross misdemeanor to a felony of the defendant secretly records a minor under the age of eighteen. Defendant filed a pretrial motion to dismiss the charge against him because the State failed to allege that he knew or had reason to know that the victim was a minor under the age of eighteen when he committed the offense. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that the plain language of section 609.746, subd. 1(e)(2) requires the State to prove that Defendant committed the offense while knowing or having reason to know a person under the age of eighteen was present. View "State v. Galvan-Contreras" on Justia Law

The Supreme Court held that, for double jeopardy purposes, the unit of prosecution for a violation of Minn. Stat. 243.166, subd. 3(a), which requires a predatory offender to register "with the corrections agent as soon as the agent is assigned to the person," is the assignment of a corrections agent, thus affirming in part and reversing in part the decision of the court of appeals.Defendant was convicted and sentenced on seven separate occasions between 2004 and 2018 for failing to register under subdivision 3(a). In August 2019, Defendant refused to sign required paperwork presented by his new corrections agent. In September 2019, Defendant again refused to sign the paperwork presented by a special agent of the Minnesota Bureau of Criminal Apprehension assigned by Defendant's corrections agent. The State charged Defendant with two counts of failing to register under subdivision 3(a). Defendant moved to dismiss the charges on double jeopardy grounds. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Defendant's earlier convictions did not bar prosecution of the August 2019 offense; but (2) the September 2019 offense was barred. View "State v. Larson" on Justia Law