Justia Criminal Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court suppressing the results of Defendant's blood test, holding that the limited right to counsel established in Friedman v. Commissioner of Public Safety, 473 N.W.2d 828 (Minn. 1991), does not apply when an individual is asked to submit to a blood test pursuant to a warrant. After Defendant was arrested for driving while impaired, the police officer obtained a search warrant to take a sample of her blood for alcohol concentration testing. The officer read Defendant the implied-consent advisory for blood and urine tests, and Defendant allowed her blood to be drawn. Defendant moved to have the results of her blood test suppressed, arguing that, under Friedman, she had a limited constitutional right to consult with counsel before deciding whether to submit to a blood test. The district court agreed. The Supreme Court disagreed, holding that the limited right to counsel under the Minnesota Constitution recognized in Friedman does not apply when a driver is presented with the choice to submit to a blood test pursuant to a search warrant. View "State v. Rosenbush" on Justia Law

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The Supreme Court affirmed the judgment of the postconviction court summarily denying Defendant's petition for postconviction relief arguing that counsel provided ineffective assistance and that an expert witness for the State provided unreliable testimony at trial, holding that the postconviction court did not err. Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed Defendant's conviction on direct appeal. Defendant later filed a petition for postconviction relief, which the postconviction court summarily denied. The Supreme Court affirmed, holding that Defendant's claims were either meritless or time-barred. View "Odell v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of aiding and abetting first-degree murder, holding that any error in the proceedings below was harmless. Specifically, the Court held (1) the district court's admission of Spreigl evidence of three other-crimes incidents was not an abuse of discretion; (2) the testimony of Defendant's accomplice was sufficiently corroborated; (3) the district court did not abuse its discretion when it twice denied Defendant's motion for a continuance to review newly produced evidence; (4) the district court abused its discretion when it sustained a relevance objection to a question during the cross examination of a police investigator, but the error was harmless; and (5) Defendant's pro se claims were without merit. View "State v. Smith" on Justia Law

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The Supreme Court affirmed the decision of the postconviction court denying Appellant's petition for postconviction relief without holding an evidentiary hearing, holding that the petition was untimely. Defendant was convicted of first-degree premeditated murder. The conviction was affirmed on appeal. After unsuccessfully filing a petition for postconviction relief Defendant filed this instant petition for postconviction relief alleging several claims of ineffective assistance of counsel during his trial and direct appeal. The postconviction court denied the claims without an evidentiary hearing, ruling that Defendant's claims were time-barred under the two-year statute of limitations. The Supreme Court affirmed, holding that the petition was properly denied because it was filed more than two years after the disposition of Appellant's direct appeal and because the facts alleged in the petition would not have satisfied any exception to the applicable statute of limitations. View "Jackson v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions of first-degree felony murder, attempted first-degree felony murder, drive-by shooting (the underlying felony), and other offenses, holding that the evidence was sufficient to support the drive-by shooting conviction and that the prosecutor did not engage in prosecutorial misconduct. On appeal, Defendant argued, among other things, that the evidence was insufficient to prove that he discharged a firearm "at or toward" a building or vehicle and that the prosecutor committed prosecutorial misconduct when she argued in rebuttal that Defendant's closing argument was trying to play on the jury's emotions. The Supreme Court affirmed, holding (1) there was sufficient evidence for a reasonable jury to find that Defendant discharged a firearm "toward" a building; (2) the prosecutor did not commit misconduct; and (3) Defendant's remaining pro se arguments were without merit. View "State v. Waiters" on Justia Law

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The Supreme Court reversed the decision of the court of appeals concluding that two Minnesota statutes - Minn. Stat. 609.749, subd. 2(6), the stalking-by-mail provision, and Minn. Stat. 609.795, subd. 1(3), the mail-harassment statute - are constitutional under the First Amendment, holding that both statutes are facially overbroad. A.J.B. was found guilty of gross-misdemeanor stalking by use of the mail, misdemeanor harassment by use of the mail, and felony stalking. The court of appeals affirmed A.J.B.'s adjudications for stalking by mail and mail harassment, thus rejecting his constitutional challenges. On appeal, A.J.B. argued that his adjudications under the stalking-by-mail provision and mail-harassment statute must be vacated as contravening the First Amendment. The Supreme Court held (1) section 609.749, subd. 2(6), is facially overbroad and not subject to either a narrowing construction or severance of unconstitutional provisions; (2) section 609.795, subd. 1(3), is facially overbroad, but the statute can be saved through severance of the constitutionally problematic language; and (3) because it is unclear whether Defendant's adjudication of delinquency for mail-harassment is based on the severed language, Defendant's adjudication under section 609.795, subd. 1(3), is reversed and the case remanded. View "In re A.J.B." on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree sexual conduct and domestic assault by strangulation, holding that Minn. R. Crim. P. 9.01 subs. 1-1a does not authorize an inspection of a crime scene in the control of a third party and that, even if Defendant had a constitutional right to inspect the crime scene, any error in denying that right was harmless. Before trial, Defendant filed a motion to allow his counsel and investigator to enter his former residence to inspect and photograph the crime scene. The district court denied the motion. The court of appeals held that Defendant had a right under Rule 9.01, subs. 1-1a, to inspect the crime scene but was not entitled to a new trial because the denial of his motion to inspect was harmless. The Supreme Court affirmed, holding (1) Rule 9.01, subs. 1-1a, does not allow the State to allow a defendant to inspect a crime scene that is the control of a third party; and (2) even if assuming Defendant had the constitutional inspection rights he asserted here, any error in denying his motions to inspect the property was harmless beyond a reasonable doubt. View "State v. Lee" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals upholding the district court's ruling that the admission of statements made by Defendant using a foreign language interpreter did not violate the Confrontation Clause of the Sixth Amendment to the United States Constitution or hearsay rules, holding that the Confrontation Clause was not violated in this case and that the statements were not subject to the hearsay rules. The district court convicted Defendant of first-degree criminal sexual conduct and sentenced him to 144 months in prison. Defendant appealed, arguing that the admission of his translated statements violated the Confrontation Clause and hearsay rules. The court of appeals upheld the district court's ruling that the court's admission of the interpreter's translated statements were proper. The Supreme Court affirmed, holding that the translated statements did not violate the Confrontation Clause and that the district court did not abuse its discretion in admitting the translated statements into evidence over the hearsay objection by Defendant. View "State v. Lopez-Ramos" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court determining that Appellant was not entitled to custody credit against her Minnesota sentence for time spent in the custody of the Red Lake Nation, holding that Appellant was not entitled to custody credit against her Minnesota sentence for the time she spent in Red Lake custody because her Minnesota conviction was not the sole reason for her Red Lake custody. In 2011, Appellant was convicted of third-degree controlled-substance crime in Beltrami County District Court. The district court stayed imposition of Appellant's sentence and placed her on probation. In 2017, while she was still on probation, Appellant was convicted of two gross misdemeanors in Red Lake Tribal Court. After serving her sentence in the Red Lake Detention Center Appellant was released directly to Beltrami County because the district court had revoked her stay. The district court concluded that Appellant was not entitled to custody credit for her incarceration time in the Red Lake Detention Center. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant was not entitled to custody credit against her Minnesota sentence for the time she spent in Red Lake custody. View "State v. Roy" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to strike for lack of probable cause count 3, domestic assault with intent to cause fear in another of immediate bodily harm, which was charged as a felony under Minn. Stat. 609.2242, subd. 4, holding that the unambiguous language of the statute supported the felony charges. In moving to strike count 3, Defendant argued that using his previous convictions to enhance count 3 to a felony was inconsistent with Minn. Stat. 609.035, which prohibits multiple punishments for the same course of conduct. The district court granted the motion. The court of appeals reversed, concluding that section 609.035 did not prohibit enhancement under subdivision 4. The Supreme Court affirmed, holding that the domestic abuse charges against Defendant qualified for the enhancement provided by subdivision 4. View "State v. Defatte" on Justia Law