Justia Criminal Law Opinion Summaries

The Supreme Court held that the unanimity requirement in Minn. Stat. 638.02m, subd. 1 does violate either Minn. Const. art. V, 7 or Minn. Const. art. III, 1.Defendant was convicted of first-degree manslaughter. When Defendant later filed an application for a pardon absolute, the members of the Board of Pardons denied it. Attorney General Keith Ellison and Governor Tim Walz voted to grant the application, and Chief Justice Lorie Gildea voted to deny it. Defendant's application was ultimately denied. Defendant then filed an action for declaratory and injunctive relief. The district court held (1) the unanimity requirement violates article V, section 7, which gives the governor sufficient and separate power to grant pardons; and (2) the unanimity requirement violates article III, section 1 because the state Constitution explicitly provides for the chief justice's participation in the pardon process. The Supreme Court reversed in part and affirmed in part, holding that the statutory provisions did not violate article V, section 7 or article III, section 1 of the Minnesota Constitution. View "Shefa v. Ellison" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Defendant's prior conviction counted as a felony in his criminal history score under Minn. Stat. 152.025, subd. 4(a), holding that there was no error.In 2019, Defendant was convicted and sentenced for domestic assault. Defendant's criminal history included a 2005 petty misdemeanor for marijuana possession and a 2007 fifth-degree controlled substance conviction. At issue on appeal was whether Defendant's 2007 conviction should count as a gross misdemeanor or as a felony in calculating Defendant's criminal history score. The district court concluded that Defendant's petty misdemeanor was a prior conviction under chapter 152 and so his 2007 conviction was properly counted as a felony. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant's 2005 petty misdemeanor qualified as a prior conviction under section 152,025, subd.4(a). View "State v. Morgan" on Justia Law

The Supreme Court reversed Defendant's conviction of illegal possession of ammunition, holding that the district court erred by denying Defendant's motion to suppress.During a traffic stop, law enforcement officers questioned Defendant, who was a passenger in the stopped vehicle, regarding the conditions of his pretrial release. After Defendant was arrested for violating a condition of his pretrial release, a pat-down search revealed ammunition in Defendant's pocket. Defendant filed a motion to suppress, arguing that the officer’s questions about the conditions of his pretrial release improperly expanded the scope of the traffic stop. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) violation of a condition of pretrial release does not constitute criminal activity allowing a law enforcement officer to expand the scope of a traffic stop; and (2) the officer's questioning of Defendant about the conditions of his pretrial release exceeded the permissible scope of a traffic stop. View "State v. Sargent" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court ordering Defendant to pay a total of $87,500 in restitution to two victims, holding that the district court did not consider Defendant's ability to pay as required by Minn. Stat. 611A.045, subd. 1.In the instant case, neither the parties nor the county probation office provided meaningful information to the district court about Defendant's income, resources, and obligations. Further, the record did not reflect that the district court considered Defendant's ability to pay. The Supreme Court reversed the restitution order, holding (1) a district court must expressly state, either orally or in writing, that it has considered a defendant’s income, resources, and obligations when ordering restitution; and (2) the record must include sufficient evidence about the defendant’s income, resources, and obligations to allow a district court to consider the defendant’s ability to pay. View "State v. Wigham" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of obtaining public assistance to which he was not entitled through willfully false statements, holding that there was no error in the proceedings below.At issue on appeal was the correction interpretation of Minn. Stat. 256.98, subd. 1, which prohibits wrongfully obtaining public assistance. Defendant was found guilty of violating the statute. On appeal, Defendant argued that the language of the statute required the State to prove that he intended to defeat the purposes of all of the public assistance programs enumerated within the statute. The Supreme Court affirmed, holding (1) the plain language of section 256.98 does not require a defendant to act with an "intent to defeat the purposes of" every listed public assistance program listed in the statute; and (2) there was sufficient evidence to prove that Defendant acted with the intent to defeat the purposes of two of the listed programs. View "State v. Irby" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's presentence motion to withdraw his guilty plea, holding that there was no error.During his plea hearing, Defendant admitted that he offered to sell thirteen grams of heroin but that only 8.906 grams of heroin were delivered to the buyer. Defendant subsequently moved to withdraw his guilty plea, arguing that the factual basis for his guilty plea was inaccurate because he did not admit that ten or more grams of heroin were delivered to the buyer in this case. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, under Minn. Stat. 152.021, subd. 1(3), individuals sell ten or more grams of heroin when they offer to sell ten or more grams of heroin, even if the individual delivers less than ten grams of heroin to the buyer. View "State v. Fugalli" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming in part and reversing in part Defendant's convictions, holding that Minn. Stat. 634.093 requires a defendant's confession to be corroborated by independent evidence reasonably tending to prove that the specific offense charged was committed.Defendant confessed to committing multiple acts of criminal sexual conduct against his minor stepdaughter. One such incident allegedly occurred when the two were scouting for deer. A jury found Defendant guilty of five counts of criminal sexual conduct, including one count based on the deer-scouting incident. The court of appeals reversed the deer-scouting incident conviction based on a lack of independent evidence corroborating Defendant's confession to that specific incident. The Supreme Court affirmed, holding that the State failed to introduce sufficient evidence to corroborate Defendant's confession to the deer-scouting incident. View "State v. Holl" on Justia Law

The Supreme Court affirmed the district court's decision summarily denying Defendant's second petition for postconviction relief, holding that the district court did not err in denying Defendant's petition for postconviction relief without holding an evidentiary hearing.Defendant was convicted of first-degree premeditated murder on an accomplice-liability theory. In her second petition for postconviction relief Defendant asserted that statements made in an affidavit by her co-defendant were newly discovered evidence that cast doubt on her guilt. The district court denied relief, concluding that the statements were not newly discovered evidence. The Supreme Court affirmed, holding that the facts in Defendant's affidavit were not "newly discovered," and therefore, Defendant's claim was untimely. View "Onyelobi v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court construing Defendant's motion to correct his sentence as an untimely third postconviction petition, holding that the district court did not err.After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life without the possibility of release. The Supreme Court affirmed. Defendant subsequently filed two petitions for postconviction relief, which the district court denied. Thereafter, Defendant filed a motion to correct his sentence. The district court construed the motion as a third postconviction petition and dismissed it as untimely. The Supreme Court affirmed, holding that the district court (1) did not err in treating Defendant's motion as a third postconviction petition; and (2) did not err in summarily denying the petition. View "Bolstad v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that a law enforcement officer lawfully expanded the scope of the underlying traffic stop in this case, holding the court of appeals did not err.Defendant was convicted of first-degree driving while impaired and possessing an opened bottle or receptacle containing an alcoholic beverage. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence because the officer impermissibly expanded the scope of the underlying traffic stop by asking Defendant if he had consumed any beer from the open case in his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances known to the officer and the legitimate inferences to be drawn from them raised a reasonable articulable suspicion of other criminal activity sufficient to expand the scope of the traffic stop. View "State v. Taylor" on Justia Law