Justia Criminal Law Opinion Summaries

The Supreme Court reversed the decision of the court of appeals determining that the district court judge presiding in the prosecution of Defendant was not disqualified or prohibited from presiding over Defendant's case, holding that Minn. R. Crim. P. 26.03, subd. 14(3) was violated when the judge continued to preside over Defendant's case.Defendant was charged with violating a domestic abuse no contact order. During trial, Defendant filed a motion to remove the judge for bias, arguing that the judge had claimed knowledge of a disputed fact and had contacted a potential witness regarding the disputed fact. Defendant's motion was denied, and he was convicted. The court of appeals affirmed. The Supreme Court reversed, holding (1) the judge's conduct during a pretrial proceeding reasonably caused the judge's impartiality to be questioned; (2) subdivision 14(3) was therefore violated when the judge continued to preside over Defendant's case; and (3) reversal of Defendant's conviction and a remand for a new hearing were required to pressure the public's confidence in the judicial system. View "State v. Malone" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and the decision of the district court denying Defendant's petition for postconviction relief, holding that there was no error.Specifically, the Supreme Court held (1) the evidence presented at trial was sufficient to support the jury's guilty verdict; (2) the State did not commit prosecutorial misconduct; (3) Defendant's trial counsel did not provide ineffective assistance; and (4) Defendant was not entitled to an evidentiary hearing to consider the opinions of two experts to determine whether a new trial was warranted. View "State v. Allwine" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the Commitment Appeal Panel (CAP) granting Appellant's petition for provisional discharge, holding that the record evidence reasonably supported the CAP's decision that the Commissioner for the Department of Human Services failed to prove by clear and convincing evidence that the provisional discharge was not appropriate for Appellant under Minn. Stat. 253D.30.Appellant was adjudicated delinquent of multiple sexual offenses against minors and was later convicted of first-degree criminal sexual conduct against a minor. Appellant was indeterminately committed to the Minnesota Sex Offender Program (MSOP) as a sexually dangerous person and was later transferred to MSOP's Community Preparation Services. Appellant later petitioned for a provisional discharge. The Special Review Board (SRB) recommended that Appellant's request for a provisional discharge be granted and the CAP granted the petition. The court of appeals reversed. The Supreme Court reversed, holding that the record as a whole reasonably supported the CAP's findings and that the CAP did not clearly err by granting Appellant's petition for provisional discharge. View "In re Civil Commitment of Kenney" on Justia Law

The Supreme Court affirmed the judgment of the district court overruling Appellant's objection to the State's peremptory strike of a prospective juror, holding that Appellant did not meet his burden of proving that the State's race-neutral reason for the strike was a pretext for racial discrimination.Appellant was convicted of first- and second-degree criminal sexual conduct. On appeal, Defendant challenged the State's peremptory strike of the only nonwhite person from the jury venire. The court of appeals affirmed, holding that the prosecutor's explanations for striking the venire-person were race-neutral reasons for the peremptory strike. The Supreme Court affirmed, holding that the district court did not err in denying Appellant's Batson challenge to the State's peremptory strike of the juror. View "State v. Lufkins" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the orders of the district courts in four cases summarily denying postconviction petitions as untimely, holding that the petitions in this case were untimely.At issue was when the two-year time limit prescribed in Minn. Stat. 590.01, subd. 4(c) begins to run for postconviction petitions asserting a claim for relief based on a new, retroactive interpretation of the law. The Supreme Court held (1) the two-year time limit in subdivision 4(c) begins to run from the date the United States Supreme Court or a Minnesota appellate court announces an interpretation of law that forms the basis for a claim that the interpretation is a new rule of law that applies retroactively to the petitioner's postconviction petition; (2) application of the two-year time limit to bar Petitioners' postconviction petitions neither implicated separation of powers concerns nor violated constitutional due process protections; and (3) the postconviction petitions in this case were untimely. View "Aili v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree criminal damage to property, holding that reasonable estimates on the cost to repair or replace damaged property are included in the meaning of the statutory phrase "cost of repair and replacement" and that sufficient evidence supported Defendant's conviction.On appeal, Defendant argued (1) allowing the jury to consider only "estimated" costs to repair or replace the damaged property, rather than the actual costs of repair and replacement, would impermissibly add the word "estimated" to the language of Minn. Stat. 609.595, subd. 1(4); and (2) because the property owner did not repair or replace the damaged property, the estimates presented to the jury on the cost to do so were insufficient to support her conviction for first-degree criminal damage to property. The Supreme Court affirmed, holding (1) the statute unambiguously includes estimates when calculating the reduction in the value of the property due to the damage caused; and (2) the evidence was sufficient to permit the jurors to reach the verdict they did. View "State v. Powers" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pretrial motion to strike down Minn. Stat. 624.714, subd. 1a, the permit-to-carry statute, and convicting Defendant of violating the statute, holding that the permit-to-carry statute does not violate the Second Amendment.Minn. Stat. 624.714, subd. 1a requires individuals to obtain a permit to carry a handgun in public. Defendant was charged with carrying a pistol in a public place without a permit in violation of the statute. Defendant filed a pretrial motion to strike down the permit-to-carry statute, arguing that the requirement that an individual obtain a permit to carry a firearm violates the Second Amendment. The district court denied the motion. The Supreme Court affirmed, holding that the permit-to-carry statute withstands strict scrutiny and does not violate the Second Amendment. View "State v. Hatch" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that a Blakely violation committed by the district court at a sentencing hearing was harmless beyond a reasonable doubt, holding that the Blakely violation was harmless beyond a reasonable doubt.After a jury trial, Defendant was found guilty to two counts of criminal sexual conduct. The complaint alleged that the offenses were committed sometime between 2004 and 2018, but at sentencing, the district court determined that Defendant's offenses were committed after August 1, 2006. The court of appeals affirmed Defendant's sentence, concluding (1) the lower court's determination of Defendant's offense dates was a violation of Blakely v. Washington, 542 U.S. 196 (2004), and its progeny; but (2) the error was harmless. The Supreme Court affirmed, holding that although the district court erred in determining that date of Defendant's offense without receiving a Blakely waiver from Defendant, but the error was harmless beyond a reasonable doubt. View "State v. Reimer" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's third petition for postconviction relief as untimely, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of first-degree murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed Defendant's conviction and sentence on direct appeal. In 2017, Defendant filed an unsuccessful petition for postconviction relief. In 2019, more than two years after his conviction became final, Defendant filed a second petition for postconviction relief that was also unsuccessful. In 2020, Defendant filed his third petition for postconviction relief. The district court determined that the claim was time-barred under Minn. Stat. 590.01, subd. 4(a) and denied relief. The Supreme Court affirmed, holding that Defendant's third petition for postconviction relief was untimely. View "Griffin v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's conviction of first-degree premeditated murder, second-degree intentional murder, and being an ineligible person in possession of a firearm, holding that the entry of a conviction for the offense of second-degree intentional murder violated Minn. Stat. 609.04.Specifically, the Supreme Court held (1) the district court did not err in denying two requests for advisory counsel to assume full representation of Defendant's defense because Defendant did not make a valid request; (2) the record supported the district court's finding that Defendant voluntarily waived his right to counsel; and (3) the district court violated section 609.04 when it entered a conviction for the offense of second-degree intentional murder. View "State v. Woods" on Justia Law