Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the district court’s summary denial of Appellant’s ninth petition for postconviction relief, holding that Appellant’s petition was time barred or otherwise rested upon a meritless legal theory.Appellant was convicted of first- and second-degree murder. Thirty years later, Appellant filed the instant petition for postconviction relief, arguing that he was actually innocent because the forensic scientist was unable to match his DNA profile to the male DNA found on the victim’s body. The district court summarily denied the petition, determining that lab reports did not establish Appellant’s actual innocence. The Supreme Judicial Court affirmed, holding that the district court did not abuse its discretion by summarily denying Appellant’s petition for postconviction relief without holding an evidentiary hearing. View "Wayne v. State" on Justia Law

The limited right to counsel recognized in Friedman v. Commissioner of Public Safety, 473 N.W. 2d 828 (Minn. 1991), applies only to implied-consent cases.The district court in this case suppressed the results of a urine sample provided by Defendant at a jail after his arrest for driving while impaired (DWI) because the sheriff’s deputy, when asking Defendant if he would consent to urine testing, failed to read the implied-consent advisory that would have advised Defendant of his right to counsel. The court concluded that, by failing to read the advisory, the deputy failed to allow Defendant to vindicate his right to counsel prior to testing. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the officer did not read the implied-consent advisory in this case, under Friedman, the limited right to counsel was not triggered; and (2) therefore, the district court erred in suppressing the urine test results on that ground. View "State v. Hunn" on Justia Law

A defendant who files a motion under Minn. R. Crim. P. 27.03, subd. 9 to correct a sentence after the time for direct appeal has passed bears the burden to prove the sentence was based on an incorrect criminal history score.The Supreme Court affirmed the judgments of the district courts denying Appellant’s motions to correct his sentence under Minn. R. Crim. P. 27.03(9), which Appellant filed after the time to file a direct appeal had expired. In his motions, Appellant argued that two Minnesota district courts miscalculated his criminal history score because those courts treated his two Illinois drug-related convictions as felonies. The court of appeals affirmed the denial of the motions. The Supreme Court affirmed, holding that Appellant had the burden to prove that the Illinois convictions were improperly included in his criminal history score and that Appellant failed to meet this burden. View "Williams v. State" on Justia Law

The Supreme Court affirmed a postconviction order that summarily denied Appellant’s public-trial claim on the grounds that the claim was barred by the rule announced in State v. Knaffla, 243 N.W.2d 737 (Minn. 1976).Appellant was convicted of one count of first-degree murder and two counts of attempted first-degree murder. During trial, the district court required spectators to present photographic identification before entering the courtroom. In his petition for postconviction relief Appellant asserted that the photographic-identification rule denied him his right to a public trial provided by the federal and state constitutions and that his appellate counsel was ineffective for not seeking a stay to expand the record regarding the courtroom “closure.” Relying on the rule announced in Knaffla, the postconvcition court summarily denied the petition for postconviction relief. The Supreme Court affirmed, holding (1) because Appellant’s public-trial claim was raised by Appellant and rejected by the Supreme Court on direct appeal, the postconviction court properly concluded that Knaffla barred the claim; and (2) Appellant forfeited appellate review of his argument that the interests-of-justice exception applied in his case. View "Taylor v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder and his sentence of life in prison without the possibility of release.The State in this case initially filed a complaint charging defendant with second-degree intentional murder. Defendant attempted to plead guilty to the charge, but the district court refused to accept the plea when it learned that the State had amended its complaint to charge first-degree premeditated murder. Contrary to Defendant’s arguments on appeal, the Supreme Court held (1) the district court did not abuse its discretion under the circumstances of this case when it did not accept Defendant’s straight guilty plea to second-degree intentional murder; and (2) sufficient evidence supported the district court’s conclusion of law that the State proved premeditation beyond a reasonable doubt. View "State v. Petersen" on Justia Law

Law enforcement officers did not violate Defendant’s Fifth Amendment privilege against self-incrimination when, after Defendant invoked his privilege against self-incrimination, they later asked him if he was willing to sign a written consent to the taking of a DNA sample and explained to him why they sought the sample.Defendant was charged with possession of a firearm by an ineligible person and possession of a short-barreled shotgun. Defendant filed a motion to suppress DNA evidence and his admission that he had handled the shotgun, claiming that the officers conducted a second custodial interrogation after he had invoked his privilege against self-incrimination. The district court denied the motion. The Supreme Court affirmed, holding that the officers did not violate Defendant’s constitutional privilege against self-incrimination because, although Defendant’s statements that he had already handled the shotgun were incriminating testimonial communications, none of the officers’ actions were reasonably likely to elicit an incriminating testimonial communication. Therefore, a Miranda warning was not required. View "State v. Heinonen" on Justia Law

In this case where a petitioner’s former attorneys appealed an order of the district court dismissing a postconviction petition as moot following the death of the petitioner, the Supreme Court dismissed the appeal, holding that the attorneys did not have standing to seek review of the district court’s order.Here, Petitioner died after filing an amended petition for postconviction relief. The district court granted the State’s motion to dismiss, concluding that the petition was technically moot due to Petitioner’s death and that the significant-public-interest exception to the mootness doctrine was not satisfied. Petitioner’s former attorneys appealed. The Supreme Court held that it lacked appellate jurisdiction and dismissed the appeal because the attorneys, whose attorney-client relationship with Petitioner terminated on his death and who were not aggrieved parties themselves, lacked standing. View "Glaze v. State" on Justia Law

In this case where a petitioner’s former attorneys appealed an order of the district court dismissing a postconviction petition as moot following the death of the petitioner, the Supreme Court dismissed the appeal, holding that the attorneys did not have standing to seek review of the district court’s order.Here, Petitioner died after filing an amended petition for postconviction relief. The district court granted the State’s motion to dismiss, concluding that the petition was technically moot due to Petitioner’s death and that the significant-public-interest exception to the mootness doctrine was not satisfied. Petitioner’s former attorneys appealed. The Supreme Court held that it lacked appellate jurisdiction and dismissed the appeal because the attorneys, whose attorney-client relationship with Petitioner terminated on his death and who were not aggrieved parties themselves, lacked standing. View "Glaze v. State" on Justia Law

A district court “participates” in a plea bargaining negotiation (see State v. Johnson, 156 N.W.2d 218 (Minn. 1968) when it provides unsolicited comments regarding the propriety of the parties’ competing settlement offers. When a defendant successfully challenges the validity of a guilty plea because of the district court’s participation, the plea is only invalid if it was involuntary under the totality of the circumstances.The district court in Appellant’s case made unsolicited comments about the propriety of the parties’ competing settlement offers before the parties reached an agreement for the court to accept or reject. Appellant later filed a petition for postconviction relief alleging that the court’s participation in the plea negotiations made her plea invalid and required a remedy of automatic plea vacated. The postconviction court disagreed and denied relief. The court of appeals affirmed. Because the law in existence at the time Appellant filed her postconviction petition did not require a defendant to establish that her guilty plea was involuntary, the Supreme Court reversed and remanded to the district court to give Appellant an opportunity to amend her postconviction petition in light of the holdings announced today. View "Wheeler v. State" on Justia Law

A district court “participates” in a plea bargaining negotiation (see State v. Johnson, 156 N.W.2d 218 (Minn. 1968) when it provides unsolicited comments regarding the propriety of the parties’ competing settlement offers. When a defendant successfully challenges the validity of a guilty plea because of the district court’s participation, the plea is only invalid if it was involuntary under the totality of the circumstances.The district court in Appellant’s case made unsolicited comments about the propriety of the parties’ competing settlement offers before the parties reached an agreement for the court to accept or reject. Appellant later filed a petition for postconviction relief alleging that the court’s participation in the plea negotiations made her plea invalid and required a remedy of automatic plea vacated. The postconviction court disagreed and denied relief. The court of appeals affirmed. Because the law in existence at the time Appellant filed her postconviction petition did not require a defendant to establish that her guilty plea was involuntary, the Supreme Court reversed and remanded to the district court to give Appellant an opportunity to amend her postconviction petition in light of the holdings announced today. View "Wheeler v. State" on Justia Law