Justia Criminal Law Opinion Summaries

The part of Minnesota’s disorderly-conduct statute that prohibits “disturb[ing]” assemblies or meetings, Minn. Stat. 609.72(1)(2), violates the First Amendment.Defendant was convicted of disorderly conduct under section 609.72(1)(2) after a jury trial. On appeal, Defendant argued that the statute violates the First Amendment because it is unconstitutionally overbroad, unconstitutionally vague, and unconstitutional as applied. The court of appeals affirmed, concluding that the constitute was constitutional and was not subject to standard overbreadth analysis. The Supreme Court reversed, holding that the statute suffers from substantial overbreadth and that there is no reasonable narrowing construction of the statute. View "State v. Hensel" on Justia Law

An individual may commit motor vehicle theft without moving the vehicle.Defendant was charged with theft of a motor vehicle under Minn. Stat. 609.52(2)(a)(17) even though he never moved the vehicle. The district court dismissed the charge for lack of probable cause, concluding that the word “takes” in the statute required Defendant to move the vehicle. The court of appeals affirmed the dismissal of the motor vehicle theft charge due to the absence of any evidence that Defendant moved the vehicle at issue. The Supreme Court reversed, holding that to “take” a motor vehicle under section 609.52(2)(a)(17), an individual must only adversely possess it. View "State v. Thonesavanh" on Justia Law

The Supreme Court affirmed Defendant’s conviction, rendered after a jury trial, of first-degree premeditated murder on an accomplice-liability theory. The court held (1) the district court did not commit clear error by denying Defendant’s Batson objection to the State’s peremptory challenge to exclude a black prospective juror trial because Defendant failed to establish a prima facie case of racial discrimination; and (2) the district court did not abuse its discretion or violate Defendant’s right to present a complete defense by refusing to allow Defendant to develop an alternative theory to explain why the murder weapon was found in a storage unit rented to an alleged accomplice. View "State v. Wilson" on Justia Law

The Supreme Court affirmed the sentence imposed by the district court for Defendant’s convictions for third- and fourth-degree criminal sexual conduct on an accomplice-liability theory. The district court granted Defendant’s motion for a downward dispositional departure, stayed execution of a 140-month sentence for fifteen years, and required Defendant to comply with several probationary conditions. The court of appeals affirmed, concluding that an offender’s minor or passive role is an adequate reason for a downward dispositional departure and that the record supported the district court’s finding that Defendant played a minor or passive role in the third- and fourth-degree criminal sexual conduct. The Supreme Court affirmed, holding that the district court did not abuse its discretion by finding that Defendant’s minor or passive role in the offense was a substantial and compelling reason to depart from the Minnesota Sentencing Guidelines. View "State v. Stempfley" on Justia Law

The Supreme Court vacated Defendant’s sentence of 135 months in prison for his conviction for first-degree possession of methamphetamine, holding that resentencing was required under sentencing grid as amended by the Drug Sentencing Reform Act (DSRA). The DSRA, which took effect after Defendant committed his offense, reduced the presumptive sentencing range under the Minnesota Sentencing Guidelines drug offender sentencing grid for Defendant’s crime. The Supreme Court held that Defendant must be resentenced under the DSRA-amended sentencing grid, holding that the amelioration doctrine required that Defendant be resentenced. View "State v. Otto" on Justia Law

The Supreme Court reversed the court of appeals affirming the district court’s dismissal of the State’s amended complaint against Minnesota School of Business and Globe University (the Schools). The State alleged that the Schools charged usurious interest rates and made loans without the required license for making private student loans at interest rates of up to eighteen percent. The State’s amended complaint sought permanent statutory injunctive relief to stop the Schools from engaging in unlicensed and usurious lending. The district court granted summary judgment for the Schools. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Schools charged usurious interest rates in violation of Minn. Stat. 334.01(1); and (2) the Schools were required to obtain a lending license under Minn. Stat. 56.01(a), and their failure to do so meant that they engaged in unlicensed lending. View "State v. Minnesota School of Business, Inc." on Justia Law

The Supreme Court vacated Defendant’s sentence of 161 months in prison for his conviction of first-degree possession of methamphetamine, holding that resentencing was required under sentencing grid as amended by the Drug Sentencing Reform Act (DSRA). The DSRA, which took effect while Defendant’s case was on appeal, reduced the presumptive sentencing range under the Minnesota Sentencing Guidelines drug offender sentencing grid for Defendant’s crime. The Supreme Court held that Defendant must be resentenced under the DSRA-amended sentencing grid because the amelioration doctrine applied to Defendant, whose conviction was not yet final when the DSRA took effect. View "State v. Kirby" on Justia Law

The Supreme Court affirmed Appellant’s conviction for two counts of theft by false representation, holding that, even assuming that the trial court’s omission of the phrase “with intent to defraud” from the jury instructions on the elements of theft by false representation was error, the error was harmless. Appellant's convictions were based on her acts of submitting timesheets and receiving payments for personal care assistant services that she did not perform. The court of appeals affirmed the convictions, concluding that, when viewed as a whole, the district court’s jury instructions fairly and adequately explained the law. The Supreme Court agreed, holding that any alleged error in the jury instructions was harmless beyond a reasonable doubt. View "State v. Schoenrock" on Justia Law

The Supreme Court reversed Appellant’s conviction of first-degree driving while impaired, holding that Appellant’s 2005 gross-misdemeanor conviction of criminal vehicular operation was not a qualified prior impaired driving incident and was therefore improperly used to enhance Appellant’s offense to a first-degree crime. Appellant’s current offense of driving while impaired was enhanced to a first-degree crime based on the existence of three prior impaired-driving convictions, including the 2005 conviction at issue. The court of appeals affirmed, ruling that Appellant’s current offense was properly charged and adjudicated as a first-degree crime because his 2005 conviction was a qualifying offense. In reversing the court of appeals, the Supreme Court held that the evidence was insufficient to convict Appellant of first-degree driving while impaired because, under the plain language of Minn. Stat. 169A.03, subd. 20, Appellant’s 2005 criminal vehicular operation conviction did not qualify as a prior impaired driving conviction. View "State v. Smith" on Justia Law

Minn. R. Evid. 1101 requires application of the Minnesota Rules of Evidence to restitution hearings.After a jury trial, Defendant was found guilty of aggravated forgery. At a restitution hearing, Defendant objected to the admissibility of certain e-mails on hearsay grounds. The trial court overruled the objection, concluding that the Rules of Evidence did not apply. The court of appeals affirmed the district court’s evidentiary rulings, concluding that the evidentiary rules do not apply to restitution hearings because the obligation to pay restitution is a part a sentence and the Rules of Evidence do not apply to sentencing proceedings. The Supreme Court reversed, holding that the Rules of Evidence apply to all cases and proceedings unless the rules provide otherwise, and because the language of rule 1101(b)(3) does not preclude their application to restitution hearings, the Minnesota Rules of Evidence apply to such hearings. View "State v. Willis" on Justia Law