Justia Criminal Law Opinion Summaries

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

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

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

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

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

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

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

The Supreme Court reversed the conclusion of the court of appeals that this appeal was moot but affirmed the court's decision dismissing the appeal, holding that Appellant, a Level III predatory offender serving the conditional release term of his sentence, was not entitled to a writ of habeas corpus.Before the time that Appellant filed this habeas petition, his conditional release had been revoked on five separate occasions. An order was later entered preventing the Department from using Appellant's inability to maintain an agent-approved placement due to his epilepsy as a basis for future revocations of his conditional release. In his habeas corpus petition, Appellant argued that his epilepsy was the sole reason for the revocation of his conditional release and continued incarceration. During the appeal from the denial of relief the Department released Appellant from prison. The court of appeals determined that Appellant's release from prison rendered his appeal moot. The Supreme Court affirmed in part and reversed in part, holding (1) the mootness exception applied in this case; and (2) The Department did not violate Appellant's substantive due process rights or the rule of law set forth in State ex rel. Marlowe v. Fabian, 755 N.W.2d 792 (Minn. App. 2008). View "State, ex rel. Young v. Schnell" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder of Andrew Gokee and attempted first-degree premeditated murder of Hudson Gauthier, holding that the district court did not abuse its discretion when it denied Defendant's request for an accomplice-testimony jury instruction under Minn. Stat. 634.04.During trial, Defendant requested an accomplice-testimony jury instruction, arguing that the jury could reasonably find that Gauthier was an accomplice. The district court concluded that the instruction was precluded as a matter of law because Defendant intended to present evidence identifying Gauthier as an alternative perpetrator. The Supreme Court affirmed, holding (1) there was no evidence that Defendant and Gauthier worked as accomplices to kill Gokee; and (2) Defendant was not entitled to relief on his remaining claims of error. View "State v. Montano" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of third-degree criminal sexual conduct, holding that a person is mentally incapacitated under Minn. Stat. 609.341, subd. 7 when that person is "under the influence of alcohol...administered to that person without the person's consent." Defendant raped the victim when she was voluntarily intoxicated. At issue was whether a person can be mentally incapacitated under section 609.341, subd. 7 when the person voluntarily ingests alcohol, or whether the alcohol must be administered to the person without her agreement. The Supreme Court remanded this case for a new trial, holding that a person is mentally incapacitated under the statute when that person is "under the influence of alcohol...administered to that person without the person's agreement." View "State v. Khalil" on Justia Law