Justia Criminal Law Opinion Summaries

The appellant was convicted by a jury of three counts of first-degree murder and three counts of second-degree murder for the deaths of three individuals in 1995. He was sentenced in 1996 to three consecutive life sentences, as required by statute for first-degree murder. At the time of sentencing, a probation agent advised the court that a presentence investigation (PSI) would not affect the sentence because the law mandated life imprisonment. The appellant did not receive a PSI, and a post-sentence investigation was to be conducted by the Department of Corrections. Over the years, the appellant challenged his convictions and sentences through multiple postconviction petitions, all of which were denied.In 2024, the appellant filed a motion to correct or reduce his sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, arguing that the lack of a PSI and alleged errors in calculating his criminal history score rendered his sentences unlawful. The State argued that the motion was actually a postconviction petition subject to the two-year statute of limitations under Minnesota Statutes § 590.01, subdivision 4, and that the court lacked jurisdiction. The Carver County District Court agreed with the State, denied the motion, and stated it lacked jurisdiction, but did grant jail credit for time served.The Minnesota Supreme Court reviewed the case and held that the district court erred in concluding it lacked jurisdiction to hear the appellant’s motion under Rule 27.03, subdivision 9, because such motions are not subject to the statutory time bar and, even if they were, the time bar is not jurisdictional. However, the Supreme Court affirmed the district court’s denial of relief, holding that the appellant’s mandatory life sentences were lawful. The absence of a PSI and the alleged miscalculation of the criminal history score did not render the sentences unlawful, as neither the PSI statute nor the sentencing guidelines apply to mandatory life sentences for first-degree murder. View "Riley vs. State of Minnesota" on Justia Law

Atravius Weeks was indicted for first-degree premeditated murder, first-degree domestic abuse murder, and second-degree intentional murder after he confessed to shooting and killing Cortney Henry in Dakota County, Minnesota. The incident occurred in June 2021, and Weeks was apprehended shortly after the crime. At trial, Weeks raised concerns about the racial composition of the jury panel, noting that Black individuals were underrepresented compared to the county’s population. He argued that the jury pool did not reflect a fair cross-section of the community, as required by the Constitution.The Dakota County District Court denied Weeks’s request for a new jury panel and, after a jury found him guilty on all counts, entered convictions for all three murder charges. Weeks’s direct appeal was stayed to allow him to file a postconviction petition, which included an expert affidavit suggesting that the use of voter registration and driver’s license lists for jury selection systematically underrepresents Black people. The district court summarily denied the postconviction petition, finding that Weeks failed to show systematic exclusion of Black jurors under the three-prong test from State v. Williams, and cited prior Minnesota cases holding that the jury selection process does not systematically exclude people of color.The Minnesota Supreme Court reviewed the case and held that the district court abused its discretion by summarily denying the postconviction petition. The Supreme Court found that, when the facts alleged are viewed in the light most favorable to Weeks, the record does not conclusively show he is entitled to no relief, and genuine issues of material fact remain regarding systematic exclusion. The Court also held that the district court violated Minnesota Statutes section 609.04 by entering convictions for both first-degree domestic abuse murder and second-degree intentional murder in addition to first-degree premeditated murder. The Supreme Court reversed and remanded for an evidentiary hearing and ordered the vacation of the lesser murder convictions. View "State of Minnesota vs. Weeks" on Justia Law

The case concerns an individual who was convicted by a jury in Rice County District Court of 29 criminal offenses, including racketeering, theft, receiving stolen property, and falsifying information. The convictions arose from a scheme involving the purchase of used vehicles, alteration of vehicle identification numbers, and the sale of stolen vehicles. The district court sentenced the individual to 117 months in prison and ordered restitution to 13 victims, totaling over $124,000. The defendant challenged all restitution awards, specifically disputing four of them on the grounds that they were not sufficiently connected to his convictions and that he lacked the ability to pay.After a hearing, the Rice County District Court vacated the four disputed restitution awards, finding that the State had not met its burden to prove the amount of loss by a preponderance of the evidence. The State appealed, and the Minnesota Court of Appeals reinstated the four awards. The appellate court interpreted Minnesota Statutes section 611A.045, subdivision 3(a), to require that a defendant’s affidavit must specifically indicate whether the challenge is to the amount of loss, the appropriateness of restitution for the item, or both. The court concluded that the defendant’s affidavit only challenged the connection between the restitution and the convictions, not the amount of loss, and thus the burden did not shift to the State.The Minnesota Supreme Court reviewed the case and held that, under section 611A.045, subdivision 3(a), an offender’s affidavit must specify for each item whether the challenge is to the amount of loss, the appropriateness of restitution, or both, before the burden shifts to the State. However, recognizing that prior case law may have caused confusion, the Supreme Court remanded the case to the district court to allow the parties to comply with this clarified standard. The decision of the Court of Appeals was affirmed in part, reversed in part, and the case was remanded. View "State v. Seeman" on Justia Law

In this case, the appellant was convicted by a jury in Hennepin County District Court of first-degree premeditated murder and second-degree intentional murder for the shooting death of Lavelle Jackson. The conviction was based in part on testimony from a jailhouse witness, S.P., who claimed the appellant confessed to the crime. After sentencing, the appellant sought postconviction relief, arguing that newly discovered evidence—specifically, testimony from Dequarn Bell, another inmate—would have undermined S.P.’s credibility and potentially changed the outcome of the trial.Following a stay of the direct appeal, the appellant petitioned for postconviction relief in the Hennepin County District Court, presenting affidavits and testimony from Bell and his trial attorney. Bell’s testimony suggested that S.P. was motivated by self-interest and that the appellant had maintained his innocence. After an evidentiary hearing, the district court denied the petition, finding Bell’s testimony not credible. In making this determination, the district court relied on detailed information about Bell’s criminal history, including facts not presented by either party at the hearing. These extra-record facts were obtained through the judge’s own independent investigation.The Minnesota Supreme Court reviewed the denial of postconviction relief. The court held that the district court’s deliberate investigation and consideration of facts outside the record violated the appellant’s constitutional right to an impartial judge under the Due Process Clause of the Minnesota Constitution. This violation constituted structural error, requiring automatic reversal without a harmless error analysis. The Supreme Court reversed the district court’s denial of postconviction relief in part and remanded the case for a new evidentiary hearing before an impartial judge. View "State of Minnesota vs. Duol" on Justia Law

The defendant was charged with multiple counts, including first-degree and third-degree criminal sexual conduct, domestic assault, and threats of violence. During jury deliberations, a juror was exposed to COVID-19, raising concerns that continued deliberations might pressure the jury to reach a verdict. After discussing the situation with counsel, the district court decided to end deliberations, take any unanimous verdicts, and declare a mistrial on any deadlocked counts. The defendant’s attorney, at the defendant’s request, asked for a complete mistrial on all counts. The jury ultimately reported no unanimous verdicts, and the district court declared a mistrial on all counts.Following the mistrial, the State refiled the charges. The defendant moved to dismiss, arguing that a retrial would violate the Double Jeopardy Clauses of the United States and Minnesota Constitutions. The Hennepin County District Court denied the motion, finding that double jeopardy did not bar retrial. The Minnesota Court of Appeals affirmed, holding that because the defendant requested the mistrial, double jeopardy would only bar retrial if the government had intentionally provoked the request, which was not the case here.The Supreme Court of Minnesota reviewed the case and affirmed the decision of the court of appeals. The court held that when a defendant requests and receives a mistrial, double jeopardy does not bar retrial unless the government intentionally induced or provoked the request. The court found no evidence that the district court or prosecution provoked the defendant’s mistrial request. The court also rejected arguments that the defendant had withdrawn his request or preserved an objection to the mistrial. As a result, the court concluded that double jeopardy did not attach, and the defendant may be retried. View "State v. Lerma" on Justia Law

In 1998, Joel Underwood, III, pleaded guilty to third-degree assault, which is classified as a crime of violence under Minnesota law. He was convicted and placed on probation. In 2000, after completing probation, a Dakota County district court issued an order restoring his civil rights and stating that he was prohibited from possessing a firearm for 10 years, which was consistent with the law at that time. In 2003, the Minnesota Legislature amended the relevant statute to impose a lifetime ban on firearm possession for individuals convicted of a crime of violence. Underwood was not specifically notified of this change. In 2021, he was found in possession of a firearm and charged under the amended statute.After being charged, Underwood waived his right to a jury trial and pleaded guilty to being an ineligible person in possession of a firearm. During the plea, he admitted to knowingly possessing a firearm and to his prior conviction but stated he did not know he was still ineligible to possess a firearm. The Anoka County District Court accepted his plea and sentenced him to the mandatory minimum. Underwood later petitioned for postconviction relief, arguing that his conviction violated due process because he relied on the 2000 discharge order and that his plea was invalid since he did not admit knowledge of his ineligibility. The postconviction court denied relief, and the Minnesota Court of Appeals affirmed, holding that there was no due process violation and that knowledge of ineligibility was not required for conviction.The Minnesota Supreme Court reviewed the case and affirmed the Court of Appeals. The court held that when a court order accurately reflects the law at the time but the law is later amended, the State does not violate due process by prosecuting under the amended statute. The court also held that the offense of ineligible person in possession of a firearm does not require proof that the defendant knew of their ineligibility, only that they knowingly possessed a firearm and had a prior conviction for a crime of violence. View "Underwood v. State" on Justia Law

Melvin Bilbro was charged after killing Shanna Daniels in her North Saint Paul apartment and setting the apartment on fire. Evidence at trial established that Bilbro and Daniels had a significant romantic and sexual relationship, as shown by their frequent text messages, terms of endearment, and testimony from acquaintances. On the night of the murder, Daniels was found dead with multiple stab wounds, and the fire in her apartment was determined to be intentionally set. Investigators found blood evidence linking Bilbro to the scene, and Daniels’s dog was discovered in Bilbro’s apartment. Bilbro denied involvement and claimed he was not in a relationship with Daniels.The State charged Bilbro with first-degree domestic-abuse murder, second-degree intentional murder, and first-degree arson. Bilbro waived his right to a jury trial on guilt but reserved the right to a jury for any facts supporting an aggravated sentence. The trial proceeded in Ramsey County District Court as a bench trial. The State presented evidence of Bilbro’s prior acts of domestic abuse against a former girlfriend, A.B., including physical assaults and an attempted murder for which Bilbro had previously been convicted. The district court found Bilbro guilty on all counts and sentenced him to life in prison for first-degree domestic-abuse murder and a consecutive 57-month sentence for arson, finding that the arson was committed to conceal the murder.On direct appeal, Bilbro argued that the evidence was insufficient to prove a significant romantic relationship with Daniels or a past pattern of domestic abuse, and that his Sixth Amendment right to a jury was violated when the court, rather than a jury, found facts authorizing the consecutive arson sentence under Minn. Stat. § 609.035. The Minnesota Supreme Court held that the evidence was sufficient to support the murder conviction and that the Sixth Amendment right to a jury under Blakely v. Washington does not apply to the threshold question of whether a sentence may be imposed for an offense under Minn. Stat. § 609.035. The court affirmed the district court’s judgment. View "Ramsey County v. Bilbro" on Justia Law

Police officers responded to a report that a man in a yellow and black coat was pointing a handgun at people at a Minneapolis light rail station. They found the suspect inside a nearby pizza restaurant, where several other people, including 16-year-old C.T.B., were standing nearby. An officer, based on his experience that weapons can be passed among individuals in a group, conducted a pat-frisk of C.T.B. and found a handgun in his possession. C.T.B. was charged with unlawful possession of a firearm by a minor and moved to suppress the handgun, arguing that the officers lacked reasonable, articulable suspicion to frisk him.The Hennepin County District Court denied the motion to suppress, finding that C.T.B.’s proximity to the original suspect and the officer’s experience justified the frisk. After a stipulated facts trial, the court found C.T.B. guilty and stayed adjudication. The Minnesota Court of Appeals affirmed, reasoning that the totality of the circumstances—including the possibility that the original suspect had handed off the firearm—made the frisk of C.T.B. objectively reasonable.The Minnesota Supreme Court reviewed the case and held that the officers did not have reasonable, articulable suspicion that C.T.B. was armed and dangerous when they conducted the pat-frisk. The court clarified that mere proximity to a suspect in an alleged crime, even when combined with general knowledge that weapons can be passed among group members, is not sufficient to justify a warrantless pat-frisk under Terry v. Ohio. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "In the Matter of the Welfare of: C.T.B" on Justia Law

A man was involved in a single-vehicle accident in Minnesota, after which law enforcement discovered a self-assembled pistol in his car that lacked a serial number. He admitted to possessing the firearm and not having a permit to carry it. The firearm, a Glock 19-style pistol, was constructed from parts purchased in 2021, before new federal regulations required serial numbers on certain parts kits. He was charged with felony possession of a firearm without a serial number under Minnesota law, as well as carrying a pistol without a permit.The Anoka County District Court granted the defendant’s motion to dismiss the charge related to the serial number, finding that while he knowingly possessed a firearm without a serial number, the relevant Minnesota statute was unconstitutionally vague as applied. The State appealed. The Minnesota Court of Appeals reversed the district court, holding that the statute plainly applied to any firearm lacking a serial number, regardless of whether federal law required one, and remanded the case for further proceedings.The Supreme Court of Minnesota reviewed the case. It held that Minnesota Statutes section 609.667(3) criminalizes possession of a firearm without a serial number only if federal law requires that the firearm have a serial number. The court reasoned that Minnesota has no independent serial number regime and that the statute’s reference to federal law means only firearms required by federal law to have serial numbers are covered. Because the defendant’s firearm was not required by federal law to have a serial number, the Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court. View "State v. Vagle" on Justia Law

In 2014, Diamond Lee Jamal Griffin was convicted in Hennepin County District Court of first-degree intentional felony murder while committing or attempting to commit aggravated robbery, stemming from the fatal shooting of Francisco Benitez-Hernandez in Minneapolis in July 2013. Griffin appealed, and the Minnesota Supreme Court affirmed his conviction, concluding that the evidence supported a reasonable inference that Griffin shot Benitez-Hernandez with intent to kill. Griffin's subsequent petitions for postconviction relief were also denied.Griffin filed a preliminary application for relief under a 2023 Minnesota law that allows individuals convicted of certain felony murder offenses under an aiding-and-abetting theory to have their sentences vacated if they can show they neither caused the death nor intentionally aided in causing the death. The Hennepin County District Court denied Griffin's application, concluding that there was no reasonable probability that Griffin was entitled to relief under the new law, based on the application, supporting materials, and previous court decisions.The Minnesota Supreme Court reviewed the case and addressed two primary issues: the appropriate standard of review for appeals under the new law and whether the district court abused its discretion in denying Griffin's application. The court concluded that the standard of review is abuse of discretion, given the text of the law and its treatment of the application as a postconviction proceeding. The court then determined that the district court did not abuse its discretion in denying Griffin's application, as the established facts and prior court decisions supported the conclusion that Griffin caused the death of Benitez-Hernandez. The Minnesota Supreme Court affirmed the district court's decision. View "State of Minnesota vs. Griffin" on Justia Law