Justia Criminal Law Opinion Summaries

In a case heard by the Supreme Court of Minnesota, the defendant, Christian Portillo, was charged with two counts of second-degree criminal sexual conduct. During the trial, the prosecutor elicited testimony from the State’s witnesses regarding evidence that the district court had previously ruled as inadmissible. The defendant's motion for a mistrial was denied by the district court. During the closing-argument rebuttal, the prosecutor told the jury that the defendant no longer held the presumption of innocence based on the evidence presented during the trial. The defendant did not object to this statement. The jury found the defendant guilty of one count of second-degree criminal sexual conduct.The defendant appealed, arguing that he was denied a fair trial due to prosecutorial errors committed by the State. The court of appeals affirmed the district court's decision, concluding that the prosecutor's misstatement of the law did not affect the defendant's substantial rights.Upon review, the Supreme Court of Minnesota reversed the decision of the court of appeals. The Supreme Court found that the prosecutor’s misstatement of the law during the closing-argument rebuttal was a plain error that affected the defendant’s substantial rights. The court held that the defendant is entitled to a new trial as the error must be addressed to ensure the fairness and integrity of the judicial proceedings. View "State of Minnesota vs. Portillo" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree felony murder but reversed and vacated his conviction for second-degree murder, holding that it was error to convict Defendant of first-degree murder as well as the lesser-included offense of second-degree murder.After a jury trial, Defendant was found guilty of both first-degree felony murder and second-degree intentional murder and sentenced to life in prison with the possibility of release after thirty years. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not abuse its discretion by prohibiting Defendant from asserting his entrapment defense at trial and denying his request for jury instructions on the lesser-included offenses; (2) the evidence was sufficient to support the jury's guilty verdicts; but (3) the district court erred by entering convictions for both first-degree felony murder and second-degree intentional murder after the jury returned the guilty verdicts. View "State v. Cruz" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree intentional felony murder while committing burglary, holding that the State presented sufficient evidence to sustain Defendant's conviction.After a jury trial, Defendant was found guilty of three counts, including first-degree intentional felony murder while committing burglary. The trial court imposed a life sentence with eligibility for release after thirty years. Defendant appealed, arguing that the State presented insufficient evidence to prove his intent to kill. The Supreme Court affirmed, holding that the circumstantial evidence presented by the State was sufficient to support Defendant's conviction for first-degree intentional felony murder. View "State v. Colgrove" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of one count of possession of a firearm by an ineligible person under Minn. Stat. 609.165, subd. 1b(a), holding that a dissembled and incomplete shotgun can meet the plain language definition of a firearm under section 609.165, subd. 1b(a).Law enforcement officers discovered a disassembled twenty-gauge shotgun in Defendant's backpack, and a forensic scientist used a bolt and washer from a similar firearm to assembly and successfully fire the shotgun at issue. Defendant was found guilty of one count of possession of a firearm by an ineligible person. The court of appeals affirmed. The Supreme Court affirmed, holding that the evidence was sufficient for the jury to reach the commonsense verdict that it did. View "State v. Stone" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress evidence found during a search of his vehicle, holding that the odor of marijuana emanating from a vehicle, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement.After a traffic stop and subsequent search of his vehicle Defendant was convicting of possession of methamphetamine paraphernalia in the presence of a minor and fifth-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the odor of marijuana, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement. The district court granted the motion and dismissed the complaint. The court of appeals affirmed. The Supreme Court affirmed, holding that evidence of medium-strength odor of marijuana, on its own, is insufficient to establish a fair probability that the search would yield evidence of criminally-illegal conduct or drug-related contraband. View "State v. Torgerson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of falsely reporting a crime to a police officer, holding that the evidence was sufficient to support the conviction and that venue was proper in Waseca County.Defendant's conviction was based on her false report to police that the father of her child had abused their child. Because Defendant was in Blue Earth County when she made the report she argued on appeal that venue was improper in Waseca County and that the evidence was insufficient to sustain her conviction. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the State met its burden to show venue based on the location of the officer receiving the false report; and (2) the evidence was sufficient to support Defendant's conviction. View "State v. Johnson" on Justia Law

The Supreme Court affirmed Defendant's conviction, following a jury trial, of gross-misdemeanor indecent exposure, holding that an individually who willfully and lewdly exposes himself in the privately-owned, partially-enclosed backyard of his home has done so in a "in any place where others are present" within the meaning of the indecent-exposure statute, Minn. Stat. 617.23, subd. 1.After he was convicted, Defendant filed a petition for postconviction relief, arguing that the State failed to prove that he was in a "public place, or in any place where others are present" within the meaning of the statute. The district court denied the petition, concluding that Defendant's actions occurred in a public place. The court of appeals affirmed. The Supreme Court affirmed, holding that the privately-owned, partially-enclosed backyard of a home satisfies the "place" element of the indecent-exposure statute. View "Fordyce v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress evidence discovered in the vehicle that Defendant was driving, holding that the totality of the circumstances supported probable cause to search the vehicle.Law enforcement initiated a traffic stop after receiving a tip from an informant that a male in possession of a firearm was in the vehicle Defendant was driving. The district court granted Defendant's motion to suppress the firearm on the grounds that the officers lacked probable cause to search the vehicle. The court of appeals affirmed. The Supreme Court reversed, holding that the State met its burden and established probable cause to search the vehicle that Defendant was driving. View "State v. Mosley" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant postconviction relief by ordering a substantive sentencing hearing, holding that, under the circumstances of this case, it would be manifestly unfair for the district court not to hold a substantive sentencing hearing in accordance with State v. Warren, 592 N.W.2d 440 (Minn. 1999).After a jury trial, Defendant was convicted of two counts of first-degree murder. Defendant was seventeen years old when he committed the offenses. The district court sentenced Defendant to two consecutive sentences of life in prison without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, the district court resentenced Defendant to two consecutive sentences of life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant subsequently filed his postconviction petition requesting a substantive hearing to consider whether, pursuant to the test articulated in Warren, his modified sentences should be served concurrently rather than consecutively. The district court granted the petition. The Supreme Court affirmed, holding that the unique circumstances of this case warranted the exercise of this Court's inherent supervisory powers to direct that the district court hold a substantive sentencing hearing in accordance with Warren. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of felony domestic assault-harm under Minn. Stat. 609.2242, subds. 1(2), 4, holding that there was no error in the proceedings below and that the evidence was sufficient to support the conviction.On appeal, the court of appeals concluded that the district court erred by instructing the jury that Defendant could use reasonable force to resist an "assault against the person" rather than to resist any "offense against the person" but that the error was not plain and that sufficient evidence supported the conviction. The Supreme Court affirmed, holding (1) use of nonlethal self-defense under section 609.06, subd. 1(3) requires a person to resist an offense carrying the threat of bodily harm; (2) the district court's use of the phrase "assault against the person" in the jury instruction at issue was not error; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Lampkin" on Justia Law