Justia Criminal Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed Defendant's convictions for eight crimes relating to the break in, robbery, and murder at James Herron's home but reversed the sentence imposed on Defendant for the first-degree aggravated robbery of Herron, holding that Defendant could not properly be sentenced for both first-degree murder while committing an aggravated robbery and first-degree aggravated robbery. Specifically, the Court held (1) the district court properly admitted Spreigl evidence at trial; (2) the district court did not abuse its discretion in denying Defendant's proposed defense of duress; (3) even assuming without deciding that the district court erred by admitting evidence from Defendant's Facebook account, including business records and photos, the error was harmless; but (4) the district court erred by sentencing Defendant for more than one of the additional crimes committed against Herron after the initial burglary. View "State v. Smith" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Appellant's second petition for postconviction relief, holding that the district court properly declined to grant Appellant a new trial and that Appellant's remaining claims also did not entitle him to relief. The Supreme Court reversed in part the district court's denial of Appellant's second postconviction petition and remanded for a determination of whether an evidentiary hearing was required to consider evidence set forth in two affidavits. The district court conducted a hearing and found that the testimony set forth in the affidavits was not credible. The Supreme Court affirmed, holding (1) Appellant did not establish that he was entitled to a new trial under the tests set forth in Rainer v. State, 566 N.W.2d 692 (Minn. 1997), and State v. Caldwell, 322 N.W.2d 574 (Minn. 1982); and (2) the remainder of Appellant's claims were did not entitle Appellant to relief. View "Anderson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Appellant's petition seeking the return of seized property, holding that the district court did not clearly err in finding that the seized property was being held as potential evidence in a pending investigation and in deciding that the property was being held in good faith. Appellant, an attorney, was part of an investigation. Pursuant to a search warrant, law enforcement officers seized electronic devices containing files about Appellant's current and former clients. Appellant filed a motion seeking the return of the seized property. The district court considered the motion to be a petition under Minn. Stat. 626.04 and denied the motion on the ground that the property was being held in good faith as potential evidence in an uncharged matter. While this appeal was pending, Appellant was charged with theft by swindle. The Supreme Court affirmed without prejudice to any future challenge to the lawfulness of the search and seizure, holding that the district court did not abuse its discretion in denying the petition even though the court should have required the State to return the attorney copies of all client files seized. View "K.M. v. Burnsville Police Department" on Justia Law

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The Supreme Court dismissed Defendant's appeal from an order of the court of appeals affirming the district court's denial of Defendant's request for funding under Minn. Stat. 611.21(a) for out-of-court interpreter services to facilitate attorney-client communication with his public defender, holding that Defendant waived the interpreter-funding issue by pleading guilty before filing his petition for review. Defendant was charged with second-degree assault and attempted second-degree murder. Defendant needed an interpreter for his court appearances and meetings with his public defender. Defendant filed two ex parte applications to fund interpreter services, which the district court denied. Defendant pled guilty to second-degree assault and then filed a petition for review. The Supreme Court dismissed Defendant's appeal, holding that Defendant waived his right to challenge the denial of his request for funding by pleading guilty before filing his petition for review. View "State v. Montanez" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily denying Appellant's petition for postconviction relief, holding that the alleged facts, even when viewed in a light most favorable to Appellant, conclusively showed that he was entitled to no relief. Appellant was convicted of murder and attempted murder. Appellant later filed his postconviction petition alleging that several reversible errors were committed by the judge, prosecutor, and his counsel during his jury trial. The district court denied the petition without holding an evidentiary hearing and without addressing the ineffective assistance of appellate counsel claim. The Supreme Court affirmed, holding (1) Appellant's claims were procedurally barred by State v. Knaffla, 243 N.W.2d 737 (Minn. 1976); and (2) the failure to address the ineffective assistance of appellate counsel claim did not require a remand because the facts alleged conclusively showed that Appellant was not entitled to relief on his claim. View "Zumberge v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing Defendant's sentence on count two, first-degree criminal sexual conduct, holding that the district court abused its discretion by imposing a greater than double durational departure on count two. The district court imposed 360-month, consecutive sentences for Defendant's two convictions of first-degree criminal sexual conduct, imposing these greater-than-double durational departures on the sentences based on the aggravating factors of particular cruelty and the particular vulnerability of the victim. In reversing the sentence on count two, the court of appeals determined that imposing a greater-than-double durational departure on a consecutive sentence when both counts involved a single victim unduly exaggerated the criminality of Defendant's conduct. The Supreme Court affirmed, albeit on different grounds, holding that this was not an extremely rare case involving severe aggravating circumstances, and therefore, the district court erred in imposing a greater-than-double durational departure on count two. View "State v. Barthman" on Justia Law

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The Supreme Court affirmed the decision of the district court denying Appellant's second petition for postconviction relief, holding that the district court did not abuse its discretion when it denied Appellant's petition. Appellant was found guilty of first-degree premeditated murder and first-degree felony murder and sentenced to life imprisonment. This appeal concerned Appellant's second petition for postconviction relief, in which Appellant requested a new trial based on four theories of ineffective assistance of appellate counsel. The district court denied the petition, concluding, among other things, that Appellant's claims were time barred under Minn. Stat. 590.01, subd. 4(a). The Supreme Court affirmed, holding that Appellant's petition was time-barred and Appellant did not meet the interests of justice exception to the time bar. View "Fox v. State" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals ruling that James Bergman was not disqualified from receiving a permit to carry a firearm, holding that the sealing of judicial records under a court's inherent authority does not satisfy the federal requirement of expungement. In 2007, a Minnesota district court issued an expungement order under its inherent authority sealing the judicial records of Bergman's prior conviction of domestic assault. Thereafter, Bergman applied for a permit to carry a firearm. Bergman was granted the permit. In 2017, the Isanti County Sheriff denied Bergman's permit-to-carry application because of his prior domestic assault conviction. The district court denied Bergman's petition for a writ of mandamus. The court of appeals reversed. The Supreme Court reversed, holding that the sealing of judicial records under a district court's inherent authority is not sufficient under federal law to expunge a previous conviction and thereby reinstate an applicant's right to carry a firearm in Minnesota. View "Bergman v. Caulk" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for first-degree driving while impaired, holding that Officer Patrick Bendel of the Red Lake Police Department was acting within his proper authority when he detained Defendant and transported him to Beltrami County law enforcement. On appeal, Defendant challenged the denial of his motion to suppress, arguing that all evidence obtained as a result of his arrest should be suppressed because Officer Bendel was not a "peace officer" as defined in Minn. Stat. 169A.03, subd. 18 and therefore could not legally arrest Defendant for driving while impaired. The Supreme Court affirmed, holding (1) Officer Bendel detained and investigated Defendant and ejected him from the Red Lake Reservation pursuant to the tribal authority to detain and remove recognized by federal courts; and (2) therefore, Defendant's detention was lawful. View "State v. Thompson" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily denying Defendant's petition for postconviction relief, holding that the claims raised in the petition were procedurally barred and that the district court's failure to address Defendant's claim of ineffective assistance of appellate counsel did not require a remand. Defendant was convicted of murder and attempted murder. Defendant later filed a petition for postconviction relief alleging that counsel, the judge, and the prosecutor committed reversible errors during trial. In a supporting memorandum, Defendant alleged an additional claim of ineffective assistance of appellate counsel. The district court denied the petition without a hearing and failed to address the ineffective assistance of counsel claim. The Supreme Court affirmed, holding (1) Defendant's claims were barred by State v. Knaffla, 243 N.W.2d 737 (Minn. 1976); and (2) the facts conclusively showed that Defendant was entitled to no relief on his claims of ineffective assistance of counsel. View "Zumberge v. State" on Justia Law