Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant’s convictions for two counts of first-degree murder, two counts of second-degree murder, and one count of attempted second-degree murder, holding that any alleged errors, whether separate or cumulative, were harmless.On appeal, Defendant argued that the district court erred by allowing the State to depose a material witness before trial, admitting a redacted transcript of the deposition at trial, and admitting evidence that, one week before the murders, Defendant had pointed a gun at two of the victims and threatened to kill everybody in the apartment. The Supreme Court held that Defendant failed to demonstrate a reasonable possibility that any of the alleged errors substantially affected the verdict, and therefore, Defendant was not entitled to a new trial. View "State v. Williams" on Justia Law

The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law

The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court’s conclusion that Respondent untimely filed his complaint challenging the forfeiture of his vehicle but reversed the district court’s conclusion that the insurance proceeds payable to Respondent under an insurance policy covering property damage to the vehicle were subject to forfeiture under Minn. Stat. 169A.63. The court held (1) Respondent’s complaint was time barred; (2) insurance payments are not subject to forfeiture under section 169A.63; and (3) therefore, the dismissal of Respondent’s complaint to the extent it challenged the forfeiture of the insurance proceeds was proper, but as to insurance payments, the complaint was dismissed for the wrong reasons. View "Briles v. 2013 GMC Terrain" on Justia Law

A person is “carry[ing] a pistol on or about the person’s clothes or person” for purposes of Minn. Stat. 624.7142(1)(4) when that person is driving a vehicle with a handgun in the center console.During an inventory search of Defendant’s vehicle after his arrest on suspension of driving while under the influence of alcohol, police discovered a loaded handgun in the center console. Defendant was charged with carrying a pistol on or about his clothes or person while under the influence of alcohol, in violation of section 624.7142(1)(4). The district court dismissed the charge for lack of probable cause, concluding that the phrase “carrying on or about the person’s clothes or person” does not extend to a pistol within the closed center console. The court of appeals affirmed. The Supreme Court reversed, holding that a pistol is carried “on or about” one’s person or clothing if there is either a physical nexus between the person and the pistol or if the pistol is carried within arm’s reach of the person. View "State v. Prigge" on Justia Law

A passenger who grabs the steering wheel of a moving vehicle is “operating” the motor vehicle under the criminal-vehicular-operation statute, Minn. Stat. 609.2113(1).Defendant was charged with criminal vehicular operation after he grabbed the steering wheel of a moving vehicle, causing the vehicle to crash and inflict great bodily harm on the three other occupants of the vehicle. Defendant moved to dismiss the complaint, arguing that he was not “operating” the motor vehicle for purposes of the statute. The district court disagreed, concluding that Defendant had operated the vehicle when he turned the steering wheel. The court of appeals affirmed. The Supreme Court affirmed, holding that the plain meaning of the term “operating” in section 609.2113(1) unambiguously included Defendant’s conduct. View "State v. Henderson" on Justia Law

The Supreme Court affirmed the denial of Appellant’s third petition for postconviction relief, which asserted several claims based on facts alleged in two sworn affidavits, holding that the affidavits were legally insufficient to establish that Appellant was innocent of the offenses of which he was convicted. The postconviction court summarily denied the postconviction petition because it was filed after the statute of limitations in Minn. Stat. 590.01(4)(a) had expired and failed to meet the newly-discovered-evidence exception in Minn. Stat. 590.01(4)(b)(2). The Supreme Court affirmed, holding that the facts were legally insufficient to show that Appellant met the newly-discovered-evidence exception, and therefore, the district court did not abuse its discretion when it summarily denied the petition as untimely filed. View "Henderson v. State" on Justia Law

Past physical abuse, standing alone, can support the issuance of an order for protection (OFP) under the Domestic Abuse Act, Minn. Stat. 518B.01, because the Act imposes no temporal requirement on when the “domestic abuse” occurred.The Supreme Court held that the court of appeals erred when it concluded, as a matter of law, that a finding of past domestic abuse alone is insufficient to support the issuance of an OFP without a showing of a present intent to cause or inflict fear of imminent physical harm. Specifically, the Supreme Court held that, under subdivision 2(a)(1) of the Act, a petition need only show that “physical harm, bodily injury, or assault” has actually occurred, regardless of when it occurred, to satisfy the first definition of “domestic abuse.” View "Thompson v. Schrimsher" on Justia Law

The Supreme Court reversed the postconviction court’s summary denial of Appellant’s pro se petition for postconviction relief, in which Appellant argued that his trial counsel was ineffective and that the prosecutor improperly refused to renew her initial plea offer.Appellant was convicted of first-degree felony murder. After Appellant filed his pro se petition for postconviction relief, Appellant asked the postconviction court to appoint counsel. The postconviction court referred Appellant’s request for counsel to the state public defender, which declined to represent Appellant. The district court then denied Appellant’s postconviction petition without holding an evidentiary hearing. The Supreme Court reversed, holding (1) Appellant was entitled to an appointed attorney for postconviction proceedings because he did not have a “review” on direct appeal; and (2) therefore, the postconviction court erred in not granting Appellant’s request for counsel. View "State v. Eason" on Justia Law

At issue in this case was whether Defendant committed burglary when he entered another guest’s hotel room without that guest’s consent and committed a crime in that room.The Supreme Court affirmed the judgment of the district court finding Defendant guilt of first-degree burglary. On appeal, Defendant argued that the State failed to prove the essential element of burglary that he entered a building without consent. Specifically, Defendant argued that, as a paying guest at the hotel, he had consent to enter the hotel building and, therefore, could not commit burglary while in the hotel. The Supreme Court disagreed, holding that when Defendant entered the victim’s hotel room he exceeded the scope of his consent to be present in the hotel building. Therefore, the evidence was sufficient to sustain Defendant’s conviction. View "State v. Lopez" on Justia Law