Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the district court's denial of Appellant's petition for postconviction relief after determining that his stay of adjudication and discharge from probation was not a conviction, holding that Appellant's stay of adjudication was not a conviction.Pursuant to a plea agreement, Appellant pleaded guilty to domestic assault-intentional infliction of bodily harm. The district court accepted Appellant's plea of guilty and stayed adjudication under the parties' agreement. After Appellant successfully completed and was discharged from probation he received notice that he was scheduled for immigration removal proceedings. Appellant filed a petition for postconviction relief seeking to withdraw his guilty plea on grounds that he received ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356 (2010). The postconviction court concluded that Appellant had not been convicted of a crime and was therefore not eligible for postconviction relief. The Supreme Court affirmed, holding (1) the plain meaning of the phrase "a person convicted of a crime" in Minn. Stat. 590.01, subd. 1 means a person who has a conviction under Minnesota law; and (2) Appellant's stay of adjudication did not meet this definition. View "Johnston v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court finding that Minn. Stat. 617.261 was unconstitutional under the First Amendment, holding that the statute does not violate the First Amendment because it survives strict scrutiny.Defendant was charged with a felony-level violation of Minn. Stat. 617.261, the statute that criminalizes the nonconsensual dissemination of private sexual images. Defendant moved to dismiss the charge on constitutional grounds. The district court denied the motion, concluding that the conduct regulated by the statute is entirely unprotected obscene speech and that any degree of overbreadth was insubstantial. The court of appeals reversed, concluding that the statute is unconstitutionally overbroad because it criminalizes a substantial amount of protected speech. The Supreme Court reversed, holding (1) section 617.261 prohibits more than obscenity; but (2) the restriction does not violate the First Amendment because it is justified by a compelling government interest and is narrowly tailored to serve that interest. View "State v. Casillas" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that a distress flare launcher might qualify as a firearm under Minn. Stat. 624.713, subd. 1 if used or intended to be used as a weapon, holding that a distress flare launcher is not a firearm under the statute.Defendant was charged with possession of a firearm by an ineligible person for possessing a distress flare launcher. The district court granted Defendant's motion to dismiss, concluding that there was insufficient probable cause to support the charge. The court of appeals reversed, concluding that a distress flare launcher could be a "firearm" under section 624.713, subd. 1 if the fact-finder were to conclude that Defendant used or intended to use it as a weapon. The Supreme Court reversed, holding (1) the term "firearm" is limited to weapons, meaning instruments designed for attack or defense; and (2) accordingly, the distress flare launcher in this case was not a weapon and could not be a firearm under the statute. View "State v. Glover" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct his sentence of life imprisonment for first-degree premeditated murder, holding that the court did not abuse its discretion in denying Defendant's motion to correct his sentence.The district court convicted Defendant of first-degree premeditated murder and sentenced him to life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant later filed his motion to correct his sentence, arguing that his conviction violated Minn. Stat. 611.02, under which when "there exists a reasonable doubt as to which of two or more degrees the defendant is guilty" a defendant shall be convicted only of the lowest degree offense. The district court denied the motion without a hearing. The Supreme Court affirmed, holding that the district court did not abuse its discretion in concluding that Defendant's conviction did not violate section 611.02. View "Steward v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's request for counsel and his pro se petition for post conviction relief, holding that the district court did not abuse its discretion.Appellant was found guilty of first-degree intentional felony murder. Appellant later filed a pro se petition for postconviction relief and requested appointment of counsel, alleging error in the jury instructions, abuse of prosecutorial discretion, and ineffective assistance of counsel. After a hearing, the district court denied relief. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying Appellant's postconviction claim that the judge who presided over his trial committed reversible error by not instructing the jury on the lesser-included offense of second-degree unintentional felony murder; (2) the district court did not err in rejecting Appellant's claim of abuse of prosecutorial discretion; and (3) Appellant's claim of ineffective assistance of counsel failed under the first Strickland prong. View "Eason v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of giving a fictitious name to a peace officer in violation of Minn. Stat. 609.506, subd. 1, holding that a fictitious name includes a partial legal name for purposes of section 609.506, subd. 1.On appeal, Defendant argued that the evidence introduced at trial was insufficient to prove that he gave the peace officer a fictitious name because he gave police a name that was part of his full name. The court of appeals affirmed, holding that "the statute criminalizes giving an investigating police officer any name or name variant that would tend to mislead the officer away from one's true identity in official records." The Supreme Court affirmed, holding (1) the plain meaning of "fictitious name" in section 609.506, subd. 1 means names that are false and includes names that use only parts of a full legal name; and (2) there was sufficient evidence to support Defendant's conviction. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief without holding an evidentiary hearing, holding that, even if the facts alleged in the petition were proven by a preponderance of the evidence, Defendant was conclusively entitled to no relief.Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. In his postconviction petition, Defendant alleged that both his trial counsel and his appellate counsel provided ineffective assistance. The district court summarily denied Defendant's claims of ineffective assistance, concluding that Defendant failed to allege facts that, if proven by a fair preponderance of the evidence, would entitle him to postconviction relief. The Supreme Court affirmed, holding that Defendant was conclusively entitled to no relief, and therefore, the district court did not abuse its discretion by summarily denying Defendant's claims. View "Chavez-Nelson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first-degree murder under an aiding and abetting theory of liability and one count of second-degree murder under an aiding and abetting theory, holding that Defendant was not entitled to a new trial.Specifically, the Supreme Court held (1) assuming that the district court’s failure to give the jury an instruction that accomplice testimony must be corroborated was plain error, the error did not affect Defendant's substantial rights; (2) the evidence against Defendant was sufficient to prove his guilt beyond a reasonable doubt; and (3) any flaws in the indictment did not prejudice Defendant's substantial rights. View "State v. Davenport" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that an ordinance adopted by the City of Minneapolis that prohibits certain property owners, property managers, and others from refusing to rent property to prospective tenants in order to avoid the burden of complying with the requirements of Section 8 of the United States Housing Act survives due process and equal protection rational basis scrutiny, holding that the ordinance is constitutional.Plaintiffs, property owners who owned and rented residential properties in the City, alleged, among other things, that the ordinance violated the Due Process Clause and the Equal Protection Clause of the Minnesota Constitution. The district court granted summary judgment in favor of Plaintiffs, concluding that the ordinance violated equal protection and due process protections. The court of appeals reversed on both claims. The Supreme Court affirmed, holding that the Minneapolis ordinance did not violate the Minnesota Constitution's guarantee of substantive due process or equal protection guarantee. View "Fletcher Properties, Inc. v. City of Minneapolis" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's third petition for postconviction relief, holding that Defendant's petition was untimely under Minn. Stat. 590.01, subd. 4(c).Defendant was convicted of first-degree premeditated murder and unlawful possession of a firearm. The Supreme Court affirmed the convictions. After his first and second petitions for postconviction relief were denied, Defendant filed a third petition for postconviction relief. The district court denied the petition without a hearing, concluding that Defendant's attempt to invoke the interests-of-justice exception was untimely under section 590.01, subd. 4(c). The Supreme Court affirmed, holding that the district court correctly denied the petition as untimely. View "Pearson v. State" on Justia Law