Justia Criminal Law Opinion Summaries

Failing to register is a continuing crime that includes the entire range of dates on which Defendant failed to register in this case, and a jury was not required to find the date of Defendant’s current offense.Defendant was convicted of knowingly failing to register as a predatory offender. Under the Minnesota Sentencing Guidelines, prior felony sentences are used to calculate criminal history scores unless a period of fifteen years has elapsed between “the date of the current offense” and the expiration of the prior felony sentence (see Minn. Stat. 243.166). Defendant argued that “the date of the current offense” for his crime was the last day the offense occurred and that a jury must decide that date. The court of appeals concluded that “the date of the current offense,” which is a continuing offense, is the first day the offense occurs. The Supreme Court affirmed, holding (1) the district court did not err in including Defendant’s 1996 felony conviction in his criminal history score because fifteen years had not elapsed between the expiration of Defendant’s sentence for his 1996 conviction and the start of his current offense; and (2) Defendant’s sentence did not violate his Sixth Amendment right to a jury trial under Blakely v. Washington, 542 U.S. 296 (2004). View "State v. Washington" on Justia Law

The warrantless search of Defendant’s property violated Defendant’s Fourth Amendment rights in this case.Here, an officer entered Defendant’s property, examined a stolen camper trailer and then, after obtaining Defendant’s consent, searched Defendant’s home. Defendant filed a motion to suppress, arguing that the officer’s examination of the camper was unconstitutional and tainted his subsequent consent to the search of his home. The district court denied the motion to suppress, concluding that because the camper was on a driveway that was impliedly open to the public, the officer’s entry onto Defendant’s property was lawful and that the officer had authority to seize the camper under the plain-view doctrine. The court of appeals reversed. The Supreme Court affirmed, holding (1) the camper was located on property that was afforded the constitutional protections of the home; and (2) the officer’s conduct was beyond the objectively reasonable scope of any implied license to enter Defendant’s property, and therefore, the warrantless search violated Defendant’s Fourth Amendment rights. View "State v. Chute" on Justia Law

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 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