Justia Criminal Law Opinion Summaries

In 2015, the appellant sexually assaulted a 9-year-old girl, but the crime was not reported until 2021. In the interim, the appellant committed an unrelated second-degree assault in 2016, for which he was convicted in 2017. After the 2015 sexual assault was disclosed in 2021, the appellant was charged and convicted of second-degree criminal sexual conduct.The district court found the appellant guilty of two counts of second-degree criminal sexual conduct. During sentencing, the court applied a sentencing enhancement under Minnesota Statutes section 609.3455, subdivision 3a, classifying the appellant as an engrained offender due to his prior conviction for second-degree assault. This resulted in an upward durational departure of 250 months in prison with a lifetime conditional release term. The appellant appealed, arguing that the term "previously committed" in the statute should mean a predatory crime committed before the commission of the present offense, not before the sentencing determination.The Minnesota Court of Appeals affirmed the district court's decision, holding that the statute required only that the predatory crime be committed before the sentencing determination. The appellant then sought review from the Minnesota Supreme Court.The Minnesota Supreme Court affirmed the lower court's decision, holding that for enhanced sentencing under Minnesota Statutes section 609.3455, subdivision 3a, a predatory crime is considered "previously committed" if it is committed before the fact-finder's sentencing-related determination that the offender is a danger to public safety. The court concluded that the plain language of the statute supports this interpretation, and thus, the appellant's 2017 assault conviction qualified as a "previously committed" predatory crime for the purposes of sentencing enhancement. View "State vs. Balsley" on Justia Law

On August 10, 2021, Jeron Garding was arrested for first-degree narcotics charges after a drug-dog sniff of his parked car led to the discovery of approximately 410 grams of methamphetamine. Garding moved to suppress the evidence, arguing that law enforcement lacked reasonable, articulable suspicion to conduct the drug-dog sniff. The district court held a contested omnibus hearing where State Trooper Jacob Bredsten testified about his observations, including the suspicious behavior of Garding and his passenger, signs of the passenger’s recent drug use, and a plastic bag in the backseat that appeared to contain drugs.The district court denied Garding’s motion to suppress, finding that Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff based on the totality of the circumstances. Garding was subsequently convicted of first-degree possession of narcotics after a stipulated facts trial, preserving his right to appeal the suppression ruling. The Minnesota Court of Appeals reversed the district court’s decision, concluding that the trooper lacked reasonable, articulable suspicion to justify the drug-dog sniff.The Minnesota Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that, under the totality of the circumstances, Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff. The court emphasized that the combination of the passenger’s signs of recent drug use, the appearance of the plastic bag in the backseat, and Garding’s flight to the woods provided sufficient grounds for the suspicion. Therefore, the district court did not err in denying Garding’s motion to suppress the evidence obtained from the search. View "State v. Garding" on Justia Law

The appellant, Earley Romero Blevins, was charged with two counts of second-degree assault-fear with a dangerous weapon after brandishing a machete at a woman and two men on a light rail platform in downtown Minneapolis. Blevins claimed he acted in self-defense after one of the men threatened him with a knife. The incident was captured on surveillance video, which showed Blevins swinging the machete for about a minute, causing the woman and the two men to retreat.The district court found Blevins guilty, concluding that he had a reasonable opportunity to retreat but failed to do so, thus his actions were not justified under Minnesota's self-defense statute. The court sentenced him to a presumptive 39-month prison term. The Minnesota Court of Appeals affirmed the district court's decision, agreeing that the evidence supported the finding that Blevins had a reasonable opportunity to retreat.The Minnesota Supreme Court reviewed the case to address whether the judicially created duty to retreat when reasonably possible applies to a person claiming self-defense in committing the felony offense of second-degree assault-fear with a dangerous weapon. The court held that this duty does apply in such cases, specifically when the weapon is designed to cause death or great bodily harm. The court also concluded that the surveillance video evidence disproved Blevins's claim that he lacked a reasonable opportunity to retreat.The Minnesota Supreme Court affirmed the decision of the court of appeals, holding that Blevins had a duty to retreat when reasonably possible before brandishing the machete and that the evidence showed he had such an opportunity. View "State of Minnesota vs. Blevins" on Justia Law

The case involves the fatal shooting of Abdi Abdi on September 10, 2021, in Moorhead, Minnesota. The shooter exited a Chrysler 200, chased Abdi, and shot him multiple times, resulting in Abdi's death. At the time of the shooting, Ibrahim Abdiaziz Isaac, the appellant, was driving on Interstate 94, approximately 100 miles away. The State's theory was that Isaac knew about the shooter's plan to kill Abdi and aided by purchasing the Chrysler 200 for the shooter.A grand jury indicted Isaac for first-degree premeditated murder under an aiding-and-abetting theory. Isaac waived his right to a jury trial, opting for a court trial instead. The district court found Isaac guilty and sentenced him to life in prison without the possibility of release. The court based its decision on circumstantial evidence, including cell phone data, surveillance footage, and eyewitness testimony, which suggested that Isaac and the shooter traveled together to purchase the Chrysler 200 and that Isaac filled the car with gas before the shooter used it to commit the murder.The Minnesota Supreme Court reviewed the case. The court applied a two-step standard of review for circumstantial evidence, first identifying the circumstances proved and then determining whether these circumstances were consistent with guilt and inconsistent with any rational hypothesis other than guilt. The court concluded that the State presented insufficient evidence to prove beyond a reasonable doubt that Isaac knew about the shooter's plan to murder Abdi before the murder occurred. The court found that a rational hypothesis existed that Isaac only learned about the plan after the murder, as evidenced by his actions following a phone call from the shooter after the murder had taken place.The Minnesota Supreme Court reversed Isaac's conviction for first-degree premeditated murder under an aiding-and-abetting theory of criminal liability. View "State of Minnesota vs. Isaac" on Justia Law

Melissa Zielinski was convicted of first-degree intentional murder and second-degree intentional murder under aiding-and-abetting theories. The case arose from the robbery and fatal shooting of Karl Henderson. Zielinski and her brother, Nicholas, planned to rob Henderson, who was known to keep large sums of money in a safe. During the robbery, Nicholas shot Henderson. Evidence included DNA on the stolen safe, phone location data, and witness testimony.The district court denied Zielinski’s pretrial motion to suppress evidence obtained from her cell phone and her statements to police, finding the search warrants valid and the police questioning lawful. Zielinski was convicted by a jury and sentenced to life without parole for first-degree murder. Her postconviction petition, alleging ineffective assistance of counsel for not challenging the search warrants on particularity grounds, was summarily denied.The Minnesota Supreme Court reviewed the case. It held that any potential Fourth Amendment violation from police questioning was harmless beyond a reasonable doubt due to the overwhelming evidence of guilt. Similarly, any Sixth Amendment violation from limiting cross-examination of Nicholas was also deemed harmless. The court agreed that the district court erred in entering convictions for both first-degree and second-degree murder, as the latter is a lesser-included offense of the former. The court affirmed the first-degree murder conviction, reversed the second-degree murder conviction, and remanded to vacate the latter. The court also upheld the denial of Zielinski’s postconviction relief petition, finding no reasonable probability that the trial outcome would have been different even if the challenged evidence had been excluded. View "State of Minnesota vs. Zielinski" on Justia Law

In February 2019, Keegan Brouillette was found guilty by a jury of two counts of felony domestic assault. On June 24, 2019, the district court sentenced him to 15 months in prison but stayed the execution of the sentence for five years, placing him on supervised probation. Brouillette did not appeal his conviction or sentence. In August 2021, after violating probation, the district court revoked his probation and executed the previously imposed 15-month sentence. Brouillette served his sentence and, in July 2022, filed a petition for postconviction relief, alleging prosecutorial misconduct.The district court denied Brouillette’s petition as untimely, ruling that the August 2021 order executing the sentence was not a new sentence and did not restart the two-year deadline for filing a postconviction petition. The court of appeals affirmed this decision, agreeing that the August 2021 order merely executed the previously imposed sentence without modifying it.The Minnesota Supreme Court reviewed the case to determine whether the two-year limitations period for filing a postconviction petition under Minnesota Statutes section 590.01, subdivision 4(a), began with the original sentencing in June 2019 or the execution of the sentence in August 2021. The court held that the execution of a previously imposed sentence does not constitute a new sentence and, therefore, does not restart the two-year limitations period. The court affirmed the lower courts' decisions, concluding that Brouillette’s petition was untimely as it was filed more than two years after the original sentencing in June 2019. View "Brouillette vs. State of Minnesota" on Justia Law

The case involves Frank James Bigbear, who was charged with third-degree criminal sexual conduct for sexually assaulting a 14-year-old victim, I.M. The State of Minnesota presented multiple witnesses, including the victim, and introduced over 10 exhibits at trial. Among the evidence was a video recording of I.M.'s interview with an investigator and a social worker, which was admitted over Bigbear's hearsay objection. The jury found Bigbear guilty after a three-day trial.Bigbear appealed the conviction, arguing that the admission of the recorded interview was reversible error. The Minnesota Court of Appeals agreed that the video recording did not meet the requirements of Rules 801(d)(1)(B) and 807 of the Minnesota Rules of Evidence. However, the court concluded that the error was harmless, reasoning that the jury could have reached the same verdict based on other evidence presented.The Minnesota Supreme Court reviewed whether the Court of Appeals conducted an incorrect harmless-error analysis. The Supreme Court agreed that the lower court used an improper standard by focusing solely on whether other evidence was sufficient to support the verdict, rather than whether the erroneously admitted evidence substantially influenced the jury's decision. After applying the correct harmless-error standard, the Supreme Court concluded that the erroneous admission of the video was harmless. The court noted that the evidence against Bigbear was overwhelming, including consistent testimonies from the victim and eyewitnesses. Therefore, the Supreme Court affirmed the decision of the Court of Appeals to uphold Bigbear's conviction. View "State of Minnesota vs. Bigbear" on Justia Law

In this case, the appellant, Deshawn Woolridge Carter, was convicted of first-degree criminal sexual conduct. At the time of the offense, he was under court-ordered conditions following a guilty plea to a felony theft offense, with adjudication stayed. During sentencing, the district court included a custody status point in his criminal history score, which increased the presumptive sentencing range. The appellant argued that because no conviction had been entered for his felony theft offense, he was not on "probation," and the district court had not "entered" his guilty plea.The district court concluded that the appellant was on probation when he committed the current offense, satisfying the requirements of Minnesota Sentencing Guidelines 2.B.2.a. The court included one custody status point in his criminal history score, resulting in a higher presumptive sentencing range. The court of appeals affirmed this decision, holding that the guidelines unambiguously authorized the assignment of a custody status point for an offense committed while on probation under a stay of adjudication.The Minnesota Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the term "probation" in the guidelines includes court-ordered conditions under a stay of adjudication following a guilty plea. Additionally, the phrase "entry of a guilty plea" refers to the act of pleading guilty on the record, not the court's acceptance and recording of the plea. Therefore, the district court did not err in assigning a custody status point to the appellant's criminal history score. View "State of Minnesota vs. Carter" on Justia Law

Blair Benedict Oberton was found in direct criminal contempt of court for a profanity-laced outburst during a judicial proceeding, partially directed at the district court judge. The district court summarily imposed a 180-day sentence, the maximum allowed under its inherent authority. Oberton appealed, arguing that the district court was required to make a finding of extraordinary conduct before imposing such a sentence.The district court's decision was affirmed by the Court of Appeals, which concluded that findings were not required to support a 180-day sentence summarily imposed under the court’s inherent authority. By the time the Supreme Court of Minnesota granted Oberton’s petition for review, he had already served his sentence. The Supreme Court determined that the appeal was not moot due to the collateral consequences exception to the mootness doctrine, as the 180-day sentence could impact future sentencing should Oberton be convicted of another offense.The Supreme Court of Minnesota affirmed its holding in State v. Tatum, clarifying that while 180 days is the maximum sentence allowed for direct contempt summarily sentenced for punitive purposes, a district court should limit its sentence to 90 days and a $1,000 fine unless the conduct is extraordinary. The court announced a new rule requiring district courts to make oral or written findings describing the extraordinary conduct within 7 days of the direct contempt order to ensure effective appellate review. The court applied this rule prospectively but concluded that under the unique circumstances of this case, Oberton’s 180-day sentence should be vacated and a 90-day sentence imposed on remand. The decision of the Court of Appeals was reversed, and the case was remanded for further proceedings consistent with the Supreme Court's opinion. View "State of Minnesota vs. Oberton" on Justia Law

Jamal L. Smith was convicted of first-degree intentional murder while committing a drive-by shooting, among other charges, for the fatal shooting of Jay Boughton during a road rage incident. Smith was driving a rented Chevrolet Suburban with two passengers from Chicago to Minnesota. During the trip, Smith brandished a pistol in a video, and later, the Suburban was involved in a road rage incident where Smith allegedly pointed a gun at another driver. On the night of the murder, Smith's Suburban paced Boughton's truck on the highway before a single .45-caliber bullet was fired from the Suburban, striking Boughton in the neck and causing his death.The Hennepin County District Court denied Smith's motion to dismiss the indictment based on the racial composition of the grand jury and admitted evidence of Smith's prior bad acts under the immediate episode exception. A jury found Smith guilty, and he was sentenced to life with the possibility of release for the murder charge and a concurrent sentence for possession of ammunition or a firearm after being convicted of a crime of violence. Smith appealed, arguing judicial bias, ineffective assistance of counsel, improper jury pool composition, erroneous admission of prior bad acts, and insufficient evidence to prove he fired the fatal shot.The Minnesota Supreme Court reviewed the case and found that Smith failed to demonstrate judicial bias or ineffective assistance of counsel. The court also held that Smith did not show that Black persons were underrepresented in the jury pool or that any underrepresentation resulted from systematic exclusion. The court ruled that the district court did not abuse its discretion in admitting evidence of Smith's prior bad acts, as it was admissible under the Spreigl exception or as direct or corroborative evidence of a charged crime. Finally, the court concluded that the only reasonable inference from the circumstances proved was that Smith fired the fatal shot. The court affirmed the judgment of convictions. View "State v. Smith" on Justia Law