Justia Criminal Law Opinion Summaries

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

The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone.The police lawfully seized a cellphone from Defendant and attempted to execute a valid warrant to search the cellphone, which had a fingerprint-scanner security lock that prevented the search. When Defendant refused to block the cellphone with his fingerprint the district court ordered Defendant to provide his fingerprint so the police could search the cellphone’s contents. The court of appeals affirmed, concluding that providing a fingerprint was not privileged under the Fifth Amendment. The Supreme Court affirmed, holding that because providing the fingerprint elicited only physical evidence from Defendant and did not reveal the contents of his mind, no violation of the Fifth Amendment privilege against self-incrimination occurred. View "State v. Diamond" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder, holding that there was no abuse of discretion.On appeal, Defendant argued that the district court abused its discretion when it (1) declined to excuse a juror who, after the trial began, realized that she knew a witness and had been exposed to news coverage of the shooting; and (2) improperly excluded reverse-Spreigl alternative-perpetrator evidence. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion in declining to remove the juror at issue from the jury; and (2) the district court did not abuse its discretion by excluding the reverse-Spreigl evidence. View "State v. Curtis" on Justia Law

Appellant Emile Rey pleaded guilty to one count of identity theft involving eight or more direct victims. The district court ordered Rey to pay the mandatory-minimum restitution of $1,000 to each of his 66 direct victims, totaling $66,000. Rey appealed, asserting that the mandatory-minimum restitution he was ordered to pay violated his procedural and substantive due process rights and was an unconstitutional fine. The court of appeals affirmed. Rey asked the Minnesota Supreme Court to declare the statute unconstitutional, vacate the restitution order, and remand the matter for a restitution hearing or a Blakely trial. The Court declined, and affirmed the restitution order. View "Minnesota v. Rey" on Justia Law

Under the totality of the circumstances of this case, the police did not violate the Fourth Amendment when, during their execution of a warrant to search a home, they searched a purse that belonged to a guest at the home.Defendant was charged with third-degree controlled-substance crime for possessing methamphetamine. Defendant moved to suppress the methamphetamine found in her pursue, arguing that the search violated the Fourth Amendment because the search of her purse was beyond the scope of the search warrant. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, taken together, the facts showed that the search of Defendant’s purse was reasonable, and therefore, the search did not violate her Fourth Amendment rights. View "State v. Molnaux" on Justia Law

The Supreme Court reversed Defendant’s convictions of first-degree premeditated murder and second-degree intentional murder in connection with the stabbing death of Defendant’s girlfriend, holding that Defendant was entitled to a new trial because his defense counsel provided ineffective assistance by conceding the only disputed elements of the charged offenses without Defendant’s consent. Specifically, the court held (1) defense counsel conceded Defendant’s guilt to first-degree premeditated and second-degree intentional murder; and (2) Defendant was entitled to a new trial because he did not acquiesce in that concession. View "State v. Luby" on Justia Law

The postconviction court did not abuse its discretion in when it denied Appellant’s second petition for postconviction relief without holding an evidentiary hearing.Appellant was found guilty of two counts of first-degree murder and sentenced to consecutive terms of life imprisonment without the possibility of release. The Supreme Court affirmed the convictions on direct appeal. In his first petition for postconviction relief, Appellant raised claims of ineffective assistance of trial and appellate counsel. The Supreme Court affirmed the postconviction court’s summary denial of the first petition. After hiring a private investigator to look into his case, Appellant filed a second postconviction petition. The Supreme Court affirmed the postconviction court’s summary denial of the petition, holding that even if Appellant proved the facts alleged in the petition at an evidentiary hearing, the petition, files, and records of the proceedings conclusively showed that Appellant was not entitled to relief. View "Zornes v. State" on Justia Law

The chemical 1,1-difluoroethane (DFE) is not a hazardous substance under Minn. Stat. 169A.03(9) because it is not listed as a hazardous substance in Minn. R. ch. 5206.Appellant was arrested three times on suspicion of driving while impaired (DWI). An analysis of her blood showed the presence of DFE. Appellant was convicted of three counts of third-degree DWI for operating a motor vehicle while under the influence of a hazardous substance. The court of appeals affirmed. The Supreme Court reversed, holding that DFE is not a hazardous substance under the definition provided in section 169A.03(9). View "State v. Carson" on Justia Law