Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of second-degree driving while impaired, holding that the State properly used Defendant's license revocation as an aggravating factor to enhance his charge of driving while impaired.Defendant was charged with second-degree driving while impaired for refusal to submit to chemical testing in violation of Minn. Stat. 169A.25, subd. 1(b), which requires that the defendant both refuse to submit to chemical testing and the presence of one aggravating factor. Defendant's prior license revocation was the aggravating factor, but the State waited until the license revocation was sustained to charge Defendant. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) a license revocation is "present" as an aggravating factor as of its effective date, and it may be used to enhance a charge of driving while impaired once review has occurred or the right to review has been waived; and (2) therefore, the State properly used Defendant's license revocation as an aggravating factor. View "State v. Anderson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's sentences in connection with his conviction for two counts of violating an order of protection (OFP) under Minn. Stat. 518B.01, subd. 14(d)(1), holding that the multiple-victim rule authorized two sentences in this case and that Defendant's consecutive sentences did not unfairly exaggerate the criminality of his behavior.A temporary OFP prohibited Defendant from contacting either his infant son or his son's mother. After Defendant had contact with both his son and the mother at a hotel, the State charged Defendant with two counts of violating an OFP. Defendant pleaded guilty to both counts, and the district court sentenced him to two permissive consecutive sentences. The court of appeals affirmed the sentences, concluding that Minn. Stat. 609.035, subd. 1 did not prohibit the district court from imposing multiple sentences for crimes that were committed during a single behavioral incident. The Supreme Court affirmed, holding (1) the multiple-victim rule applied in this case because Defendant made in-person contact with two protected persons, and therefore, there were two victims of the OFP-violation crime; and (2) Defendant's sentences did not exaggerate the criminality of his behavior. View "State v. Alger" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the district court's denial of Defendant's request for non-identifying information about a confidential reliable informant's relationship with police and the informant's information-gathering activities, holding that the State's common law privilege to withhold the identity of an informant does not protect non-identifying information.Defendant was charged with drug possession and sale crimes. Defendant filed discovery and suppression motions seeking information about a confidential reliable informant, on whose observations the State relied to obtain a warrant to search Defendant's home. The district court denied the motions, concluding that Defendant was not entitled to discover the informant's identity or any other information about the informant. Defendant was convicted of fifth-degree sale of a controlled substance. The court of appeals reversed, holding that the State's common law privilege did not protect non-identifying information. The Supreme Court affirmed, holding that the court of appeals (1) properly concluded that the State's common law privilege does not apply to non-identifying information; and (2) did not err in concluding that the non-identifying information Defendant requested related to the case, as required by Minn. R. Crim. P. 9.01. View "State v. Dexter" on Justia Law

The Supreme Court affirmed the decisions of the district court denying Appellant's ineffective assistance of trial counsel claim raised in his first petition for post conviction relief and the claims raised in his second petition for postconviction relief, holding that the district court did not abuse its discretion by denying Appellant's claims.After a jury trial, Appellant was found guilty of first-degree felony murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed. In his first petition for postconviction relief, Appellant raised some of the same issues addressed in his direct appeal but also claimed that he received ineffective assistance of trial counsel. The district court ordered an evidentiary hearing only on the ineffective assistance of counsel claim and, after a hearing, denied the claim. Appellant then filed a second petition for postconviction relief, which the district court summarily denied. The Supreme Court affirmed both of the district court's orders, holding (1) Appellant did not satisfy the first prong of Strickland on his ineffective assistance of counsel claim; and (2) all of Appellant's claims in his second petition were time barred. View "Griffin v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction for failure to register as a predatory offender, holding that Defendant's 1992 California conviction for sexual battery did not require him to register as a predatory offender under Minn. Stat. 234.166, subd. 1b(b).When Defendant was incarcerated in Minnesota, prison officials informed him that he was required to register as a predatory offender because of his 1992 California conviction. Because Defendant did not register in the fall of 2016 the State charged him with failing to register as a predatory offender. The district court found Defendant guilty. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant's California criminal sexual battery conviction was not an offense requiring registration in Minnesota because California's criminal sexual battery could be proven without proving a violation of Minnesota's fourth-degree criminal sexual conduct by force or coercion. View "State v. Martin" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction of felony deprivation of parenting rights in violation of Minn. Stat. 609.26, subd. 1(3) on the grounds that the evidence was insufficient because the circumstances proved supported a reasonable inference that Defendant did not have a subject intent to substantially deprive her child's father of parenting time, holding that the court of appeals erred when it concluded that the State presented insufficient evidence to support the conviction.Implicit in the court of appeals' analysis was an assumption that section 609.26, subd. 1(3) required the State to prove that Defendant had the subjective intent substantially to deprive the father of his parental rights. The Supreme Court reversed, holding (1) section 609.26, subd. 1(3) establishes an objective standard that focuses on the nature of the defendant's action; and (2) the only reasonable inference that can be drawn from the circumstances proved here was that Defendant's actions, viewed objectively, manifested an intent substantially to deprive the child's father of court-ordered parenting time. View "State v. Culver" on Justia Law

The Supreme Court affirmed Defendant's conviction of simple robbery, holding that the evidence was sufficient to support Defendant's conviction.On appeal, Defendant argued that the evidence introduced at trial was insufficient to establish that her temporary use of force overcame another person's resistance, as required by Minn. Stat. 609.24. The Supreme Court affirmed, holding (1) the force element of simple robbery is satisfied the moment an actor uses force for the purpose of overcoming another's resistance to the taking or carrying away of property; and (2) the State provided sufficient evidence of Defendant's use of force to sustain a conviction for simple robbery. View "State v. Townsend" on Justia Law

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

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

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