Justia Criminal Law Opinion Summaries

In 2015, Appellant was charged with two counts of first-degree driving while impaired (DWI). Appellant contested the use of his 1998 conviction for criminal vehicular operation resulting in substantial bodily harm to enhance his 2015 DWI charge to a first-degree offense. The district court found sufficient probable cause for enhancement. Thereafter, Appellant pleaded guilty to one count of first-degree driving while impaired. Appellant appealed, arguing that he was entitled to withdraw his plea because his 1998 conviction was not included in the list of predicate felonies in Minn. Stat. 169A.24 that enhance a DWI charge to a first-degree DWI. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a criminal vehicular operation conviction from a year not specifically listed in the current version of the first-degree DWI statute can be used to enhance a DWI charge to a first-degree offense; and (2) accordingly, Appellant’s plea was established with an accurate factual basis. View "State v. Boecker" on Justia Law

After a bench trial, Appellant was convicted of three counts of first-degree premeditated murder. The Supreme Court affirmed on direct appeal. Appellant then filed a pro se petition for postconviction relief, arguing that he was entitled to a new trial based on newly discovered evidence in the form of affidavits signed by five alibi witnesses. Appellant also claimed ineffective assistance of trial counsel and appellate counsel. The postconviction court summarily denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by summarily denying Appellant’s request for a new trial based on newly discovered evidence and based on Appellant’s claim that both his trial counsel and appellate counsel provided ineffective assistance. View "State v. Mosley" on Justia Law

A grand jury indicted Appellant for first-degree premeditated murder. After a jury trial, Appellant was found guilty as charged. The district court sentenced Appellant to life imprisonment without the possibility of release. On appeal, Appellant argued that the district court committed reversible error in its pretrial rulings, evidentiary rulings, and instructions to the jury. The Supreme Court affirmed, holding that the district court (1) did not err by denying Appellant’s motion to quash the first-degree murder indictment as untimely; (2) did not abuse its discretion by denying Appellant’s pretrial motion to disclose the entire grand jury transcript; (3) did not err when it excluded evidence of an alternative perpetrator’s prior bad acts; (4) did not commit reversible error in its evidentiary rulings challenged on appeal; and (5) did not commit prejudicial error when it overruled Appellant’s objection to a proposed jury instruction on the law on accomplice liability. View "State v. Guzman" on Justia Law

Defendant was charged with gross misdemeanor second-degree driving while impaired. The matter proceeded to trial. After the State rested, Defendant made a motion for judgment of acquittal, arguing that there was insufficient evidence to convict him of the offense. Thereafter, the State asked to reopen its case-in-chief. The district court granted the State’s motion to reopen and then denied Defendant’s motion for judgment of acquittal. The jury found Defendant guilty as charged. The court of appeals affirmed, concluding that the district court did not err when it granted the State’s motion to reopen its case-in-chief before considering Defendant’s motion for judgment of acquittal. The Supreme Court affirmed, holding that, under the circumstances of this case, the district court did not abuse its discretion when it permitted the State to reopen its case-in-chief in response to Defendant’s motion for judgment of acquittal. View "State v. Thomas" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, two counts of attempted first-degree premeditated murder, and three drive-by-shooting counts. Defendant was sentenced to life imprisonment without the possibility of release for the murder conviction. Defendant challenged his convictions by filing a petition for postconviction relief, raising a number of claims. The postconviction court denied the petition in its entirety. The Supreme Court affirmed Defendant’s convictions of first-degree premeditated murder and attempted first-degree premeditated murder but vacated Defendant’s three drive-by-shooting convictions, holding (1) the evidence was sufficient to support the premeditated-murder counts; (2) there was no evidentiary error during trial; (3) the postconviction court did not err when it refused to review the grand-jury transcripts or disclose them to Defendant’s postconviction counsel; but (4) the drive-by-shooting counts were duplicative of the premeditated-murder and attempted-premeditated-murder counts. View "Loving v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated murder and unlawful possession of a firearm. The district court sentenced Defendant to life imprisonment without the possibility of release for the first-degree premeditated murder conviction. This appeal concerned Defendant’s second petition for postconviction relief in which he raised claims alleging newly discovered evidence and ineffective assistance of counsel. The postconviction court summarily denied Defendant’s claims of ineffective assistance of counsel and, after an evidentiary hearing, denied Defendant’s motion for a new trial based on his claim of newly discovered evidence. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied Defendant’s request for a new trial based on a claim of newly discovered evidence and when it denied Defendant’s postconviction claims asserting ineffective assistance of counsel. View "Pearson v. State" on Justia Law

Defendant was charged in May 2013 with two counts of first-degree criminal sexual conduct. When Defendant failed to appear for his first appearance, the district court issued a warrant for his arrest. In February 2015, Defendant was arrested for unrelated reasons. Before his omnibus hearing, Defendant moved to dismiss the charges, claiming that the twenty-one-month delay between the date he was charged and his eventual arrest violated his right to a speedy trial under the United States and Minnesota Constitutions. The district court granted Defendant’s motion and dismissed the charges after applying the four-factor balancing test from Barker v. Wingo. The court of appeals reversed, concluding that the third and fourth Barker factors did not weigh in Defendant’s favor, and therefore, on balance, the State had not violated Defendant’s constitutional right to a speedy trial. The Supreme Court affirmed as modified, holding that although the delay may have been attributable to the State’s negligence, Defendant’s failure to assert his speedy trial right weighed heavily against him and ultimately led to the conclusion that the State did not violate Defendant’s right to a speedy trial. View "State v. Osorio" on Justia Law

In 2005, Appellant pleaded guilty to second-degree burglary, a felony. When Appellant was released from probation the conviction was deemed a misdemeanor. In 2015, Appellant filed a petition for expungement. The district court denied the petition, concluding that Appellant was not “convicted of” a misdemeanor and therefore could not petition for expungement under Minn. Stat. 609A.02, subd. 3(a)(3). The court of appeals affirmed. The Supreme Court affirmed, holding that felony convictions later deemed misdemeanors by operation of law under Minn. Stat. 609.13, subd. 1(2) are not eligible for expungement under Minn. Stat. 609A.02, subd. 3(a)(3). View "State v. S.A.M." on Justia Law

The State charged Defendant under Minn. Stat. 609.352, subd. 2a(2) with felony communication with a child describing sexual conduct after she sent sexually explicit images and messages to a fifteen-year-old boy. Defendant filed a motion to dismiss, arguing that section 609.352, subd. 2a(2) proscribes a substantial amount of speech that the First Amendment protects and thus facially violates the First Amendment. The district court concluded that the statute violates the First Amendment, and the court of appeals affirmed. The Supreme Court reversed, holding that 609.352, subd. 2a(2) is not substantially overbroad in relation to its plainly legitimate sweep. View "State v. Muccio" on Justia Law

After Appellant pleaded guilty to third-degree criminal sexual conduct, removal proceedings were initiated against him. In an attempt to avoid deportation, Appellant filed an emergency motion to withdraw his guilty plea, arguing, inter alia, that he received ineffective assistance of counsel because counsel failed accurately to inform him that his plea would lead to his removal from the United States. Specifically, Appellant argued that Padilla v. Kentucky required his attorney to advise him that the plea would result in his deportation, rather than just the deportation was a possibility. The postconviction court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding that Padilla did not require Appellant’s counsel to do anything more than provide a general warning about the immigration consequences of entering the plea, and therefore, Appellant’s counsel satisfied his obligation under the Sixth Amendment. View "Sanchez v. State" on Justia Law