Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals reversing Defendant's sentence on the basis that the district court had misapplied Minn. Sent. Guidelines 2.B.7.a, holding that the classification of a prior offense is determined by reference to the statute setting forth the elements of the crime, rather than by reference to Minn. Stat. 609.02 defining "felony" and "gross misdemeanor."Defendant was convicted of first-degree sale of a controlled substance. After the district court sentenced Defendant he appealed, arguing that his criminal-history score was improperly calculated because the district court had misapplied section 2.B.7.a. The court of appeals agreed and remanded to the district court for resentencing. The Supreme Court affirmed, holding that the term "offense definitions" in section 2.B.7.a means the element-based definition of a crime under the statute setting forth a particular offense. View "State v. Strobel" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief, holding that the district court did not err in denying the petition without holding an evidentiary hearing.Defendant was convicted of first-degree murder as an accomplice. The Supreme Court affirmed on direct appeal. Thereafter, Defendant filed the present petition for postconviction relief, alleging several claims of error. The district court denied the petition without a hearing, reasoning that Defendant's arguments were either procedurally barred or lacked merit. The Supreme Court affirmed, holding that Defendant's claims were either procedurally barred or failed on the merits. View "Onyelobi v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction for third-degree murder, holding that the third-degree murder statute, Minn. Stat. 609.195(a), does not require the State to prove beyond a reasonable doubt that the defendant lacked an "intent to effect the death of any person."On appeal, Defendant argued that there was insufficient evidence to support her conviction because the State failed to prove beyond a reasonable doubt that she lacked an intent to effect the death of any person because, an an apparent suicide attempt, her driving conduct showed an intent to effect the death of herself. The court of appeals agreed and reversed Defendant's conviction. The Supreme Court reversed after applying the State v. Stokely, 16 Minn. 282 (1871), line of precedent, holding that the "without intent to effect the death of any person" clause of the third-degree murder statute does not require the State to prove beyond a reasonable doubt that the defendant lacked an "intent to effect the death of any person." View "State v. Hall" on Justia Law

The Supreme Court affirmed the judgment of the district court construing Defendant's motion to correct his sentence as a motion for postconviction relief and summarily denying postconviction relief without holding an evidentiary hearing, holding that the court did not err in treating Defendant's motion as a petition for postconviction relief and in summarily denying the petition.Defendant was found guilty of first-degree premeditated murder and second-degree murder. Defendant later filed a motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9. The district court construed the motion as a petition for postconviction relief under Minn. Stat. 590.01, determining that the motion fell outside the scope of Rule 27.03 because it implicated more than just his sentence. The court then summarily denied the petition because the petition was untimely. The Supreme Court affirmed, holding (1) the district court did not err in considering Defendant's motion to correct his sentence as a petition for postconviction relief; and (2) the district court did not abuse its discretion in summarily denying Defendant's request for postconviction relief because, even if the facts alleged in the petition were true, they were legally insufficient to entitle him to the requested relief. View "Rossberg v. State" on Justia Law

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

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

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

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

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

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