Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of malicious punishment of a child - less than substantial bodily harm, in violation of Minn. Stat. 609.377, subd. 2, holding that section 609.377 does not require the State to prove both that a defendant used unreasonable force and that it was in the course of punishment.On appeal, Defendant argued that there was insufficient evidence to support her conviction. The Supreme Court affirmed, holding (1) the malicious punishment of a child statute is subject to only one reasonable interpretation, the interpretation being that the State must prove that a defendant used unreasonable force but need not prove that the force occurred in the course of punishment; and (2) because Defendant's insufficiency of the evidence claim is premised on the erroneous conclusion that the State needs to prove that she used unreasonable force in the course of punishment, Defendant failed to show that the State presented insufficient evidence. View "State v. Altepeter" on Justia Law

The Supreme Court reversed the decision of the court of appeals denying B.H.'s petition for a writ of prohibition asking that the district court be prohibited from enforcing its written order stating that she was required to provide her cell phone to defense counsel, holding that the district court's order denying B.H.'s motion to quash was unauthorized by law and that the issuance of the writ was necessary to prevent irremediable harm to B.H.After the State charged Defendant with third-degree criminal sexual conduct the district court granted Defendant's motion for a subpoena requiring B.H., the alleged victim of the sexual assault, to produce her cell phone to a computer forensic expert hired by Defendant. B.H. filed a motion to quash the subpoena. The district court denied the motion and ordered B.H. to produce her phone to defense counsel or Defendant's expert. B.H. filed a petition for a writ of prohibition, which the court of appeals denied. The Supreme Court reversed, holding that when it failed to analyze whether compliance with the subpoena was reasonable under the totality of the circumstances the district court committed an error of law for which no other adequate remedy exists and which would result in irremediable harm to B.H. View "State v. Yildirim" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief arguing that the rule announced in Miller v. Alabama, 567 U.S. 460 (2012), and later clarified in Montgomery v. Louisiana, 577 U.S. __ (2016), should be extended to adult offenders whose crimes reflect the transient immaturity of youth, holding that the district court did not abuse its discretion when it denied Defendant's postconviction petition.Defendant was convicted of first-degree premeditated murder and sentenced to a mandatory term of life in prison without the possibility of release. Defendant was eighteen years and seven days old on the date of the offense. On appeal from the denial of his postconviction motion, Defendant renewed his Miller/Montgomery argument and further asked the Supreme Court to interpret Minn. Const. art. I, 5 to provide greater protection than the Eighth Amendment. The Supreme Court affirmed, holding (1) because the Miller/Montgomery rule is clearly limited to juvenile offenders under the age of eighteen at the time of the offense, the district court did not abuse its discretion when it denied Defendant's petition for postconviction relief; and (2) Defendant forfeited appellate review of his claim under the Minnesota Constitution. View "Nelson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court and the court of appeals concluding that Minn. Stat. 609.27 subd. 1(4) was constitutionally overbroad and could not be saved through a narrowing construction or by severing part of it, holding that subdivision 1(4) criminalizes a substantial amount of protected speech and is thus unconstitutional on its face.Defendant was charged with one felony count of attempted coercion under section 609.275, the attempted coercion statute. Defendant filed a motion to dismiss, arguing that the statute was overly broad in violation of the First Amendment. The district court granted the motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that Minn. Stat. 609.27 subd. 1(4) is substantially overbroad and cannot be narrowed or saved by severance and therefore must be invalidated as violating the First Amendment. View "State v. Jorgenson" on Justia Law

The Supreme Court reversed the portion of the court of appeals' decision reversing in part Defendant's convictions, holding that the district court did not violate Minn. Stat. 609.04 when it convicted Defendant of both an electronic solicitation offense and an electronic distribution offense and did not violate Minn. Stat. 609.035 when it sentenced Defendant on both the electronic solicitation conviction and an attempted third-degree sexual assault conviction.Defendant was convicted of attempted third-degree criminal sexual conduct, electronically soliciting a child to engage in sexual conduct, and electronically distributing any material, language, or communication that relates to or describes sexual conduct to a child. The court of appeals reversed in part, holding that the district court violated section 609.04 and section 609.035. The Supreme Court reversed in part, holding (1) the State presented sufficient evidence to support the attempt conviction; (2) the offense of electronic solicitation necessarily includes the offense of electronic distribution; and (3) the State proved that the electronic solicitation conviction and the attempted third-degree sexual assault conviction were not part of a single behavioral incident. View "State v. Degroot" on Justia Law

The Supreme Court affirmed Defendant's convictions for of first-degree premeditated murder and attempted first-degree premeditated murder but reversed Defendant's 360-month sentence for attempted first-degree premeditated murder, holding that the sentence was error because it exceeded the statutory maximum.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by denying Defendant's pretrial motion to suppress his post-Miranda statements; (2) the jury instruction on the elements of premeditated murder was not erroneous, and the district court did not err by failing to give a jury instruction on accomplice testimony; and (3) because the statutory maximum for the offense of attempted first-degree premeditated murder is 240 months, Defendant's sentence on this offense is remanded for resentencing. View "State v. Ezeka" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Appellant's claim of ineffective assistance of counsel failed under the second prong of Strickland v. Washington, 466 U.S. 668 (1984), holding that, even if Appellant had offered to plead guilty to second-degree murder, Appellant made no showing that there was a reasonable probability that the State would have entered into a plea agreement.A jury found Appellant guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. Appellant later filed a postconviction motion, alleging that her counsel provided ineffective assistance by failing to recommend that she plead guilty to second-degree murder and by failing adequately to inform her about the power of the State's case. The district court concluded that Appellant had satisfied the first but not the second prong of Strickland. The Supreme Court affirmed, holding that, even assuming that defense counsel's recommendation could have persuaded Appellant to make a qualifying offer, Appellant failed to show that any such offer would have been accepted by the State and presented to the court. View "Peltier v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted third-degree criminal sexual conduct, holding that the State proved that Defendant committed an act that was "a substantial step forward, and more than preparation for" the commission of third-degree criminal sexual conduct.Specifically, the Supreme Court held (1) in the statutory phrase "a substantial step toward, and more than preparation for" in the attempt statute, Minn. Stat. 609.17, the substantial step must be strongly corroborative of the actor's criminal purpose, but it need not objectively reveal the nature of the intended crime; and (2) the evidence in this case proved beyond a reasonable doubt that Defendant intended to commit the crime of third-degree criminal sexual conduct and that he committed an act that was a substantial step toward, and more than preparation for, the commission of the intended crime. View "State v. Wilkie" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's denial of Defendant's petition for postconviction relief, holding that, under Minn. Stat. 260B.245, subd. 1(b), delinquency adjudications may be deemed "felony convictions" for the purpose of the statutory definition of a crime of violence.Defendant was charged with possession of a firearm by an ineligible person, which required proof that Defendant had been convicted of a crime of violence. Defendant pled guilty to the offense, admitting that he had been adjudicated delinquent for committing fifth-degree possession of a controlled substance. The district court accepted the plea and placed Defendant on probation. Defendant later filed a petition for postconviction relief, asserting that his juvenile delinquency adjudication failed to satisfy the definition of a "crime of violence" because, under section 260B.245, a delinquency adjudication cannot be deemed a "conviction of crime." The district court denied postconviction relief. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase "felony convictions," as used in the statutory definition of crime of violence, includes a juvenile delinquency adjudication for felony-level offenses listed in Minn. Stat. 624.712, subd. 5; and (2) Defendant provided an adequate factual basis for his guilty plea. View "Roberts v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to suppress evidence seized from his vehicle during a traffic stop, holding that a driver violates Minn. Stat. 169.30(b) by driving past the stop sign or stop line before coming to a complete stop.Defendant's vehicle was stopped after he failed to stop at a stop sign and stop line. The district court suppressed the evidence seized from Defendant's vehicle, concluding that the traffic stop was unlawful because Minn. Stat. 169.30(b) requires a driver "to stop at the intersection, not at the stop sign or stop line." The court of appeals reversed. The Supreme Court affirmed, holding (1) section 169.30(b) is violated when the driver a vehicle drives past the stop sign or stop line before coming to a complete stop; and (2) because Defendant failed to bring his vehicle to a complete stop before he drove his vehicle past the stop line and the stop sign, the traffic stop was lawful. View "State v. Gibson" on Justia Law